ir 05000271-10-003, on 04/01/2010 - 06/30/2010; vermont ... · • advanced off-gas system (aog)...
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I 475 ALLENDALE ROAD
KING OF PRUSSIA PA 19406-1415
July 29 2010
Mr Michael Colomb Site Vice President Entergy Nuclear Operations Inc Vermont Yankee Nuclear Power Station Vernon VT 05354
SUBJECT VERMONT YANKEE NUCLEAR POWER STATION - NRC INTEGRATED INSPECTION REPORT 050002712010003
Dear Mr Colomb
On June 30 2010 the US NUclear Regulatory Commission (NRC) completed an inspection at your Vermont Yankee Nuclear Power Station The enclosed inspection report documents the inspection results which were discussed on July 26 2010 with you and other members of your staff
The inspection examined activities performed under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license The inspectors reviewed selected procedures and records observed activities and interviewed personnel
This report documents one self-revealing finding of very low safety significance (Green) This finding was determined to involve a violation of NRC requirements However because of the very low safety significance and because it has been entered into your corrective action program (CAP) the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VLA1 of the NRCs Enforcement Policy If you contest any 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 20555shy0001 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 Senior Resident Inspector at Vermont Yankee In addition if you disagree with the crossshycutting aspect assigned to the finding in this report you should provide a response within 30 days of the date of this inspection report with the basis for your disagreement to the Regional Administrator Region I and the NRC Senior Resident Inspector at Vermont Yankee
M Colomb 2
n(~~-
In accordance with 10 CFR 2390 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 document system (ADAMS) ADAMS is accessible from the NRC Web Site at httpwwwnrcgovreading-rmadamshtml(the Public Electronic Reading Room
Donald E J k n Chief Reactor Pro s Branch 5 Division of Reactor Projects
Docket No 50-271 License Nos DPR-28
Enclosure Inspection Report No 050002712010003 wI Attachment Supplemental Information
cc wencl Distribution via ListServ
I I
M Colomb 2
In accordance with 10 CFR 2390 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 document system (ADAMS) ADAMS is accessible from the NRC Web Site at
httpwwwnrcgovreading-rmadamshtml (the Public Electronic Reading Room)
Sincerely
IRAt
Donald E Jackson Chief Projects Branch 5 Division of Reactor Projects
Docket No 50-271 License Nos DPR-28
Enclosure Inspection Report No 050002712010003 wi Attachment Supplemental Information
Distribution wencl (via Email) M Oapas Acting RA (R10RAMAIL RESOURCE) D Lew Acting DRA (R10RAMAIL RESOURCE) J Clifford DR (R1DRPMAIL RESOURCE) D Collins DRP (R1DRPMAIL RESOURCE) D Roberts DRS (R1DRSMAILResource) P Wilson DRS (R1 DRSMAILResource) L Trocine RI DEDO D Jackson DRP
D Spindler DRP SRI T Setzer DRP J Heinly DRP H Jones DRP RI A Rancourt DRP DA RidsNrrPMVermontYankee Resource RidsNrrDorlL11-1 Resource ROPreportsResourcenrcgov
SUNSI Review Complete __-TCS-__ (Reviewers Initials)
Adams Accession No ML 102100320
DOCUMENT NAME GORPBRANCH5ReportsOraftsVYIR2010003revOdocm After declaring this document An Official Agency Record it will be released to the Public To receive a copy of this document indicate in the box C = Copy without attachmentenclosure
E = Copy with attachmentenclosure N = No copy
FICE RIDRP lhP RIDRP I RIIDRP I RIIDRPI
NAME DSpindlertcs for TSetzertcs DJacksontcs
DATE 072810 072810 072910
Enclosure
Docket No
license No
Report No
licensee
Facility
Location
Dates
Inspectors
Approved by
1
US NUCLEAR REGULATORY COMMISSION
REGION I
50-271
DPR-28
050002712010003
Entergy Nuclear Operations Inc
Vermont Yankee Nuclear Power Station
Vernon Vermont 05354-9766
April 1 2010 through June 30 2010
D Spindler Sr Resident Inspector DRP H Jones Resident Inspector ORP J Noggle Sr Health Physicist DRS T Burns Reactor Inspector DRS M Reichard Health Physicist DNMS
Donald E Jackson Chief Projects Branch 5 Division of Reactor Projects
i
Enclosure
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TABLE OF CONTENTS
SUMMARY OF FINDINGS 111 bullbullbullbullbullbullbullbullbullbullbull3_
REPORT DETAILS bull bullbullbull 4
1 REACTOR SAFEfYbullbullbullbullbull a 4 1R01 Adverse Weather Protection 4 1R04 Equipment Alignment 5 1R05 Fire Protection 5 1R07 Heat Sink Performance 6 1R08 Inservice Inspection lSi) 7 1R11 Licensed Operator Requalification Program 9 1R12 Maintenance Effectiveness 9 1R13 Maintenance Risk Assessments and Emergent Work Control 10 1R15 Operability Evaluations 10 1R18 Plant Modifications 11 1R19 Post-Maintenance Testing 12 1R20 Refueling and Other Outage Activities 13 1R22 Surveillance Testing 16 1EP6 Drill Evaluation bullbullbullbullbullbullbullbull bullbullbullbullbullbullbullbull bull 16
2 RADIATION SAFEfY 17 2RS01 Radiological Hazard Assessment and Exposure Controls 17 2RS02 Occupational ALARA Planning and Controls 19 2RS04 Occupational Dose Assessment 19 2RS05 Radiation Monitoring Instruments 20
4 OTHER ACTIVITIES lOA] 23 4OA1 Performance Indicator (PI) Verification 23 40A2 Identification and Resolution of Problems 24 4OA5 Other Activities 26 40A6 Meetings including Exit 27
AITACHMENT SUPPLEMENTAL INFORMATION 27
KEY POINTS OF CONTACT Amiddot1
LIST OF ITEMS OPENED CLOSED AND DISCUSSED A-2
LIST OF DOCUMENTS REVIEWED A-2
LIST OF ACRONYMS I0~ t bullbullbull bullbull A11
Enclosure
3
SUMMARY OF FINDINGS
IR 050002712010003 04012010 - 06302010 Vermont Yankee Nuclear Power Station Refueling and Other Outage Activities
This report covered a three-month period of inspection by resident inspector staff and regionshybased inspectors One Green self-revealing finding which was determined to be a non-cited
I violation (NCV) was identified The significance of most findings is indicated by their coor (Green White Yellow Red) using Inspection Manua Chapter (IMC) 0609 Significance Determination Process The cross-cutting aspect for the finding was determined using IMC 0310 Components Within The Cross-Cutting Areas Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649 Reactor Oversight Process Revision 4 dated December 2006
Cornerstone Mitigating Systems
Green A self-revealing NCV of very low safety significance (Green) of Technical Specification (TS) 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECGS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages
The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining RCS inventory [H2(c)] (Section 1R20)
Enclosure
1
4
REPORT DETAILS
Summary of Plant Status
Vermont Yankee (VY) Nuclear Power Station began the inspection period operating at 100 percent power On April 24 2010 VY performed a planned power reduction to support the refueling and maintenance outage On May 26 2010 VY began power ascension after completion of the refueling outage however the unit automatically shut down at 70 percent power due to a recent modification design issue After correcting the modification issue VY began power ascension on May 29 2010 VY reached 100 percent power on June 1 2010 and remained at or near 100 percent power for the duration of the inspection period
1 REACTOR SAFETY
Cornerstones Initiating Events Mitigating Systems Barrier Integrity
1R01 Adverse Weather Protection (7111101-1 sample)
Grid Stability - Summer Readiness of Offsite and Alternate AC Power Systems
a Inspection Scoge
The inspectors performed a review of Entergys offsite and alternate AC power system readiness for adverse weather The inspectors reviewed Entergys plant features and procedures for operation and continued availability of their AC power systems to determine if they were appropriate The inspection focused on Entergys procedures for communication protocols with the transmission system operator (TSO) to determine if appropriate information would be exchanged when issues arise that could impact the offsite power system The inspectors also reviewed Entergys procedures to determine if they addressed necessary actions to be taken if notified by the TSO that they needed to transfer safety-related loads to the onsite power supply compensatory actions to be taken if it were not possible to predict grid conditions and required communications between Entergy and the TSO The inspectors interviewed personnel and performed a walkdown of the switchyard A list of documents reviewed is provided in the Attachment
b Findings
No findings were identified
Enclosure
1
5
1 R04 Equipment Alignment (7111104 - 4 samples)
Partial Equipment Alignment
a Inspection ScoQe
The inspectors performed four partial system walk downs to verify correct system alignment and to identify any discrepancies that could impact system operability Observed plant conditions were compared to the standby alignment of equipment specified in applicable piping and instrumentation drawings and operating procedures (OPs) The inspectors verified valve positions and the general condition of selected components Finally the inspectors evaluated material condition housekeeping and component labeling The documents reviewed are listed in the Attachment The following systems were inspected
bull A train residual heal removal service water (RHRSW) system during B train RHRSW system testing
bull A train residual heat removal (RHR) during B train RHR testing bull S train emergency diesel generator (EDG) system during A train EDG system
maintenance and bull Advanced off-gas system (AOG) after maintenance
b Findings
No findings were identified
1 R05 Fire Protection (7111105 - 7 samples)
Quarterly Inspection (7111105Q - 6 samples)
a Inspection ScoQe
The inspectors performed inspections of six fire areas based on a review of the Vermont Yankee Safe Shutdown Capability Analysis the Fire Hazards Analysis and the Individual Plant Examination for External Events (IPEEE) The inspectors reviewed Entergys fire protection program to determine the specified fire protection design features fire area boundaries and combustible loading requirements for the selected areas The inspectors verified consistent with applicable administrative procedures that combustibles and ignition sources were adequately controlled passive fire barriers manual fire-fighting equipment and detection and suppression equipment were appropriately maintained and compensatory measures for out-ot-service degraded or inoperable fire protection equipment were implemented in accordance with Entergys fire protection program The inspectors evaluated the fire protection program for conformance with the requirements of License Condition 3F The documents reviewed are listed in the Attachment The following fire areas were inspected
Enclosure
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bull Fire area FA-8 elevation 252 A EDG bull Fire area FA-9 elevation 252 B EDG bull Fire zone FZ-7 elevation 228 condenser bay basement bull Fire zone FZ- elevation 248 condenser bay and ground floor bull Reactor building RB-4 elevation 252 reactor building south and bull Reactor building RB-4 elevation 213 high pressure coolant injection (HPCI)
b Findings
No findings were identified
2 Annual Inspection (7111105A - 1 sample)
The inspectors evaluated Entergys fire brigade performance by observing an announced fire brigade drill on April 2 2010 The inspectors verified that the number of individuals assigned to the fire brigade response met the minimum specified number each member donned the protective clothing tumout gear and self-contained breathing apparatus the fire brigade leader exhibited command of the fire brigade and had copies of the pre-fire plans the fire brigade arrived at the fire scene in a timely manner the licensees drill scenario was followed and acceptance criteria for the drill objectives were met and the licensee performed a post-drill critique to discuss any failures and weaknesses associated with the fire drill performance
b Findings
No findings were identified
1RO Heat Sink Performance (7111107 - 2 samples)
Annual Inspection
a Inspection Scope
The inspectors reviewed the results of the thermal performance tests of emergency diesel generator heat exchangers for DG-1-1A and DG-1-1B including the scavenging air cooler lubricating oil cooler and jacket water cooler for each diesel The inspectors discussed the test results with the system engineer and reviewed the completed surveillance data to determine whether test results met acceptance criteria which considered differences between test and design basis accident conditions The inspectors also reviewed Entergys corrective action program (CAP) to ensure significant heat exchanger performance problems were appropriately identified and documented and that corrective actions assigned if any were appropriate A list of documents reviewed is provided in the Attachment to this report
b Findings
No findings were identified
Enclosure
7
1 R08 Inservice Inspection (lSI) (7111108 -1 sample)
a Inspection Scope
The purpose of this inspection was to assess the effectiveness of the licensees lSI program for monitoring degradation of reactor pressure vessel internals reactor coolant system boundary risk significant piping system boundaries and the containment boundary The inspector assessed the inservice inspection activities using requirements and acceptance criteria for component examination specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI and applicable NRC Regulatory Requirements
The inspector selected a sample of nondestructive examination (NDE) activities to perform a documentation review of those NDE activities for compliance with the requirements of the ASME Boiler and Pressure Vessel Code Section XI The sample selection was based on the inspection procedure objectives sample availability and risk priority of those components and systems where degradation could result in a significant increase in risk of core damage The inspector verified by documentation review that test procedures and examiner qualifications had been reviewed and approved for use by the licensee The inspector reviewed a sample of these procedures and qualifications to determine they were current and in accordance with the ASME Code requirements In addition the inspector performed this review to determine that examiners had been trained and qualified for use of the performance demonstration initiative (PDI) manual ultrasonic test procedures The inspector selected a sample of Indication Notification Reports (INR) and Condition Reports (CRs) to evaluate the licensees effectiveness in the identification and resolution of relevant indications discovered during the observed lSI activities The inspectors documentation review of non-destructive testing included the following
bull Ultrasonic test (UT) manual PDI-UT of weld overlay applied to core spray nozzles N5A-SE and N5B-SE (Examination data was reviewed for comparative evaluation with the UT examinations performed in 1993 1998 and 2004)
bull Magnetic particle test (MT) of sweep weld RH17-S-349A to the RHR piping drawing G191172 lSI Isometric ISI-5920-9212
bull Visual examination (VT-3) of component supports on torus suppression chamber (NB-H1951-TSS10 drawings 5920-914461359131 and 9133) and
bull Liquid Penetrant test (PT) of nozzle to safe end dissimilar butt weld N10-SE drawing ISI-RPV-103 location elevation 269 ft azimuth 350 degrees
The inspector reviewed the visual inspection results of various in-vessel components including jet pump structural members leveling devices miscellaneous fasteners and tack welds made to secure components in place These observations were made to determine the examiner skill and to assess the test equipment performance examination technique and the quality of the inspection environment (water clarity) The inspector performed a review of in-vessel component non-conforming conditions identified in CRs 2010-020112010-02016 and INR-VYR 28-0528-0628-0728-08 28-09 28-10 and 28-11 Additional CRs listed in the Attachment to this report were
Enclosure
8
reviewed by the inspector to evaluate the characterization and disposition of relevant indications identified during the in-vessel visual inspection (IWI) of structural components within the vessel
The inspector selected three ASME Section XI repairreplacement plans-for review where welding on a safety related pressure boundary was performed The review was performed to evaluate qualification and control of the welding process specified in the work order Also to determine that the weld procedures and welders assigned to perform this special process are qualified in accordance with the requirements of ASME Section XI and that specified weld examinations are done in accordance with the ASME code requirements The three ASME Section XI repairreplacement work orders reviewed were
bull W0184964-06 was developed for welding of fitting to service water (SW) piping to facilitate installation of valve V70-164C This welding was of stainless steel base materials welded in line 34SW-18A by groove welding using weld procedure specification (WPS) SS-88-8 Rev 21 Welds 48 and 49 added to the service water system as shown on Weld Map 184964-10 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3
bull W0178169-01 was developed to replace fourteen inch 0 service water pump discharge valve V70-2D Welding was of carbon steel to carbon steel using WPS CS-11-A Rev 3 by groove welding of pipe to valve and pipe to pipe (3 welds) as shown on weld map 178169-1 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3 and
bull W0184964-06 was developed to replace pipe to socket weld 47 in service water system line 34 SW-18A using WPS BM-81-A Rev 2 stainless to carbon steel as shown on weld map 184964-10RO Applicable Code for acceptance was ASME Section XI lSI Class 3
Additionally the inspector performed a visual evaluation of the primary containment liner and additional structural members attached to the liner to assess the condition of the protective coating The evaluation included accessible locations on elevations 252 thru 266 The inspector performed this visual evaluation to determine the extent of any peeling blistering coating loss or other damage as a result of corrosion foreign material impact or lack of maintenance Condition Report CR-VTY-2010-02337 was initiated to describe the results of this visual examination
b Findings
No findings were identified
Enclosure
9
1R11 Licensed Operator Requalification Program (71111110 - 1 sample)
Ouarterly Inspection
a Insgection Scoge
The inspectors observed a simulator-based licensed operator requalification (LOR) exam on June 10 2010 The inspectors assessed the performance of risk significant operator actions including the use of emergency operating procedures The inspectors evaluated crew performance in the areas of clarity and formality of communications ability to take timely actions prioritization interpretation and verification of alarms procedure usage control board manipulations and command and control The inspectors also compared the simulator configuration with the actual control board configuration Finally the inspectors verified that evaluators were identifying and documenting crew performance problems The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R12 Maintenance Effectiveness (71111120 - 3 samples)
a Inspection Scope
The inspectors reviewed performance-based problems involving selected in-scope structures systems and components (SSCs) to assess the effectiveness of the maintenance program The reviews focused on the following aspects when applicable
bull Proper maintenance rule scoping in accordance with 10 CFR 5065 bull Characterization of reliability issues bull Changing system and component unavailability bull 10 CFR 5065 (a)1) and (a)(2) classifications bull Identifying and addressing common cause failures bull Trending of system flow and temperature values bull Appropriateness of performance criteria for SSCs classified (a)(2) and bull Adequacy of goals and corrective actions for SSCs classified (a)(1)
The inspectors reviewed the applicable system health reports maintenance backlogs and Maintenance Rule basis documents The documents reviewed are listed in the Attachment The following structures systems and components were inspected
bull Residual Heat Removal (RHR) relief valves bull Core Spray CS and bull A recirculation pump motor generator set scoop tube positioner
Enclosure
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b Findings
No findings were identified
1R13 Maintenance Risk Assessments and Emergent Work Control (7111113 -7 samples)
a Inspection Scope
The inspectors evaluated seven maintenance risk assessments for planned and emergent maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work The inspectors reviewed maintenance risk evaluations maintenance plans work schedules and control room logs to determine if concurrent or emergent maintenance or surveillance activities significantly increased the plant risk The inspectors reviewed risk assessments to determine if they were performed as required by 10 CFR 5065a)(4) and implemented in accordance with Entergys administrative procedures (AP) 0125 Plant Equipment and AP 0172 Work Schedule Risk Management - Online When emergent work was performed the inspectors observed activities to determine if plant risk was promptly reassessed and managed The documents reviewed are listed in the Attachment The following maintenance activities were inspected
bull On April 28 2010 increased risk due to removing the A station battery from service for planned maintenance
bull The week of May 32010 increased (yellow) risk due to refueling outage activities bull The week of May 10 2010 increased risk due to electrical bus outages to support
planned maintenance bull The week of May 17 2010 increased risk due to vessel drain down activities
installation of the reactor vessel head installation of the drywell vessel head and integrated leak rate testing to support outage activities
bull On June 8 2010 increased (yellow) risk due to primary containment being declared inoperable
bull On June 10 2010 high risk evolution associated with the CS system and bull On June 24 2010 high risk evolution associated with the A recirculation pump
motor~generator set scoop tube repair activities
b Findings
No findings were identified
1R15 Operability Evaluations (7111115 - 5 samples)
a Inspection Scope
The inspectors reviewed five operability evaluations associated with degraded or nonshyconforming conditions to assess the acceptability of the evaluations the use and control of applicable compensatory measures and compliance with Technical Specifications The inspectors reviewed and compared the technical adequacy of the evaluations with
Enclosure
1
11
the Technical Specifications Updated Final Safety Analysis Report associated design basis documents and Entergys procedure EN-OP-104 Operability Determinations The documents reviewed are listed in the Attachment The inspectors reviewed evaluations of the following degraded or non-conforming conditions
bull CR 2010-01686 pitting found on the RHRSW pump P-8-1C discharge piping bull CR 2010-01821 drywell dome gasket damage bull CR 2010-01944 SW strainer pitting below minimum wall thickness bull CR 2010-02285 S emergency diesel generator cylinder 10 temperature differs
from other cylinders by more than 300 degrees Fahrenheit and bull CR 2010-03202 GNF-2 (nuclear) fuel defect in the spacer springs at certain fuel pin
locations
b Findings
No findings were identified
1R18 Plant Modifications (7111118 - 3 samples)
Temporary Plant Modifications
a Inspection Scope (2 samples)
The inspectors reviewed two temporary modifications to ensure they did not adversely affect the availability reliability or functional capability of any risk-significant SSCs and assessed the adequacy of the 10 CFR 5059 evaluations The inspectors reviewed the engineering change package walked down the area interviewed various personnel and compared the installation and control of the modification to the procedural requirements The inspectors also verified that the installation was consistent with the modification documentation that the drawings and procedures were updated as applicable and that the post-installation testing was adequate The documents reviewed are listed in the Attachment The following two temporary modifications were reviewed
bull Engineering change (EC) 16583 temporary modification to provide power to 480VAC bus-710ads during a bus-7 outage and
bull EC 22659 temporary modification for the leak repair on the AOG two (2) inch pipe 2 CNPE-172A
b Findings
No findings were identified
Enclosure
2
12
Permanent Plant Modifications
a Inspection Scol2e (1 sample)
The inspectors reviewed EC16322 Replacement of Standby Fuel Pool Cooling Service Water Piping to ensure it did not adversely affect the availability reliability or functional capability of any risk-significant SSCs The inspectors reviewed the engineering change package and completed post-maintenance testing (PMT) package and observed the system in operation following the installation of the modification The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R19 Post-Maintenance Testing (7111119 - 10 samples)
a Inspection Scope
The inspectors reviewed ten post-maintenance test (PMT) activities on risk-significant systems The inspectors reviewed these activities to determine whether test acceptance criteria were clear and consistent with design basis documents When testing was directly observed the inspectors determined whether installed test equipment was appropriate and controlled and whether the test was performed in accordance with 10 CFR Part 50 Appendix B Criterion XI ~Test Control and applicable station procedures Upon completion the inspectors performed a walkdown to verify that equipment was returned to the proper alignment necessary to perform its safety function and evaluated whether conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the PMTs performed for the following maintenance activities
bull On April 9 2010 B normal fuel pool cooling pump seal replacement bull On April 21 2010 hydraulic control unit HCU-2235 valve (111 ) replacement bull On April 22 2010 A reactor water clean up pump seal replacement bull On May 32010 startup transformer (T-3-1B) refuel outage maintenance activities bull On May 2 2010 c service water pump discharge valve replacement
bull On May 16 2010 A EDG service water piping replacement bull On May 18 2010 post maintenance examination during RPV operational pressure
test following RPV relief valve replacement bull On June 8 2010 B RHR safety relief valve (SR-10-86B) replacement bull On June 10 2010 B core spray discharge piping safety relief valve (SR-14-20B)
replacement and bull On June 222010 B EDG fuel rack and governor maintenance
b Findings
No findings were identified
Enclosure
13
1 R20 Refueling and Other Outage Activities (7111120 -1 sample)
a Inspection Scope
The inspectors evaluated VY refueling outage (RFO) 28 activities to verify that Entergy considered risk when developing outage schedules adhered to administrative risk reduction methodologies for plant configuration control and adhered to their operating license TS requirements and approved procedures A list of documents reviewed is provided in the Attachment The following activities were inspected
bull Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 28 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions electrical power availability inventory control decay heat removal reactivity control and containment The daily risk assessments accounting for schedule changes and unplanned activities were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate
bull Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations As soon as practical following the shutdown the inspectors performed walkdown inspections of the primary containment
bull Electrical Power - The inspectors reviewed the status and configuration of safetyshyrelated buses throughout RFO 28 The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers the auxiliary transformer and the emergency diesel generators
bull Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (Le shutdown cooling) status on a daily basis Monitoring included daily reviews of residual heat removal system alignment reviews of spent fuel pool cooling system alignment and reviews of RCS time-to-boil calculations and results
bull Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan
bull Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling eVolutions including procedure place keeping communications with refueling floor personnel monitoring of source range nuclear instrumentation and monitoring of individual control rod positions
bull Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage The inspectors
Enclosure
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performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
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conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
M Colomb 2
n(~~-
In accordance with 10 CFR 2390 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 document system (ADAMS) ADAMS is accessible from the NRC Web Site at httpwwwnrcgovreading-rmadamshtml(the Public Electronic Reading Room
Donald E J k n Chief Reactor Pro s Branch 5 Division of Reactor Projects
Docket No 50-271 License Nos DPR-28
Enclosure Inspection Report No 050002712010003 wI Attachment Supplemental Information
cc wencl Distribution via ListServ
I I
M Colomb 2
In accordance with 10 CFR 2390 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 document system (ADAMS) ADAMS is accessible from the NRC Web Site at
httpwwwnrcgovreading-rmadamshtml (the Public Electronic Reading Room)
Sincerely
IRAt
Donald E Jackson Chief Projects Branch 5 Division of Reactor Projects
Docket No 50-271 License Nos DPR-28
Enclosure Inspection Report No 050002712010003 wi Attachment Supplemental Information
Distribution wencl (via Email) M Oapas Acting RA (R10RAMAIL RESOURCE) D Lew Acting DRA (R10RAMAIL RESOURCE) J Clifford DR (R1DRPMAIL RESOURCE) D Collins DRP (R1DRPMAIL RESOURCE) D Roberts DRS (R1DRSMAILResource) P Wilson DRS (R1 DRSMAILResource) L Trocine RI DEDO D Jackson DRP
D Spindler DRP SRI T Setzer DRP J Heinly DRP H Jones DRP RI A Rancourt DRP DA RidsNrrPMVermontYankee Resource RidsNrrDorlL11-1 Resource ROPreportsResourcenrcgov
SUNSI Review Complete __-TCS-__ (Reviewers Initials)
Adams Accession No ML 102100320
DOCUMENT NAME GORPBRANCH5ReportsOraftsVYIR2010003revOdocm After declaring this document An Official Agency Record it will be released to the Public To receive a copy of this document indicate in the box C = Copy without attachmentenclosure
E = Copy with attachmentenclosure N = No copy
FICE RIDRP lhP RIDRP I RIIDRP I RIIDRPI
NAME DSpindlertcs for TSetzertcs DJacksontcs
DATE 072810 072810 072910
Enclosure
Docket No
license No
Report No
licensee
Facility
Location
Dates
Inspectors
Approved by
1
US NUCLEAR REGULATORY COMMISSION
REGION I
50-271
DPR-28
050002712010003
Entergy Nuclear Operations Inc
Vermont Yankee Nuclear Power Station
Vernon Vermont 05354-9766
April 1 2010 through June 30 2010
D Spindler Sr Resident Inspector DRP H Jones Resident Inspector ORP J Noggle Sr Health Physicist DRS T Burns Reactor Inspector DRS M Reichard Health Physicist DNMS
Donald E Jackson Chief Projects Branch 5 Division of Reactor Projects
i
Enclosure
2
TABLE OF CONTENTS
SUMMARY OF FINDINGS 111 bullbullbullbullbullbullbullbullbullbullbull3_
REPORT DETAILS bull bullbullbull 4
1 REACTOR SAFEfYbullbullbullbullbull a 4 1R01 Adverse Weather Protection 4 1R04 Equipment Alignment 5 1R05 Fire Protection 5 1R07 Heat Sink Performance 6 1R08 Inservice Inspection lSi) 7 1R11 Licensed Operator Requalification Program 9 1R12 Maintenance Effectiveness 9 1R13 Maintenance Risk Assessments and Emergent Work Control 10 1R15 Operability Evaluations 10 1R18 Plant Modifications 11 1R19 Post-Maintenance Testing 12 1R20 Refueling and Other Outage Activities 13 1R22 Surveillance Testing 16 1EP6 Drill Evaluation bullbullbullbullbullbullbullbull bullbullbullbullbullbullbullbull bull 16
2 RADIATION SAFEfY 17 2RS01 Radiological Hazard Assessment and Exposure Controls 17 2RS02 Occupational ALARA Planning and Controls 19 2RS04 Occupational Dose Assessment 19 2RS05 Radiation Monitoring Instruments 20
4 OTHER ACTIVITIES lOA] 23 4OA1 Performance Indicator (PI) Verification 23 40A2 Identification and Resolution of Problems 24 4OA5 Other Activities 26 40A6 Meetings including Exit 27
AITACHMENT SUPPLEMENTAL INFORMATION 27
KEY POINTS OF CONTACT Amiddot1
LIST OF ITEMS OPENED CLOSED AND DISCUSSED A-2
LIST OF DOCUMENTS REVIEWED A-2
LIST OF ACRONYMS I0~ t bullbullbull bullbull A11
Enclosure
3
SUMMARY OF FINDINGS
IR 050002712010003 04012010 - 06302010 Vermont Yankee Nuclear Power Station Refueling and Other Outage Activities
This report covered a three-month period of inspection by resident inspector staff and regionshybased inspectors One Green self-revealing finding which was determined to be a non-cited
I violation (NCV) was identified The significance of most findings is indicated by their coor (Green White Yellow Red) using Inspection Manua Chapter (IMC) 0609 Significance Determination Process The cross-cutting aspect for the finding was determined using IMC 0310 Components Within The Cross-Cutting Areas Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649 Reactor Oversight Process Revision 4 dated December 2006
Cornerstone Mitigating Systems
Green A self-revealing NCV of very low safety significance (Green) of Technical Specification (TS) 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECGS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages
The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining RCS inventory [H2(c)] (Section 1R20)
Enclosure
1
4
REPORT DETAILS
Summary of Plant Status
Vermont Yankee (VY) Nuclear Power Station began the inspection period operating at 100 percent power On April 24 2010 VY performed a planned power reduction to support the refueling and maintenance outage On May 26 2010 VY began power ascension after completion of the refueling outage however the unit automatically shut down at 70 percent power due to a recent modification design issue After correcting the modification issue VY began power ascension on May 29 2010 VY reached 100 percent power on June 1 2010 and remained at or near 100 percent power for the duration of the inspection period
1 REACTOR SAFETY
Cornerstones Initiating Events Mitigating Systems Barrier Integrity
1R01 Adverse Weather Protection (7111101-1 sample)
Grid Stability - Summer Readiness of Offsite and Alternate AC Power Systems
a Inspection Scoge
The inspectors performed a review of Entergys offsite and alternate AC power system readiness for adverse weather The inspectors reviewed Entergys plant features and procedures for operation and continued availability of their AC power systems to determine if they were appropriate The inspection focused on Entergys procedures for communication protocols with the transmission system operator (TSO) to determine if appropriate information would be exchanged when issues arise that could impact the offsite power system The inspectors also reviewed Entergys procedures to determine if they addressed necessary actions to be taken if notified by the TSO that they needed to transfer safety-related loads to the onsite power supply compensatory actions to be taken if it were not possible to predict grid conditions and required communications between Entergy and the TSO The inspectors interviewed personnel and performed a walkdown of the switchyard A list of documents reviewed is provided in the Attachment
b Findings
No findings were identified
Enclosure
1
5
1 R04 Equipment Alignment (7111104 - 4 samples)
Partial Equipment Alignment
a Inspection ScoQe
The inspectors performed four partial system walk downs to verify correct system alignment and to identify any discrepancies that could impact system operability Observed plant conditions were compared to the standby alignment of equipment specified in applicable piping and instrumentation drawings and operating procedures (OPs) The inspectors verified valve positions and the general condition of selected components Finally the inspectors evaluated material condition housekeeping and component labeling The documents reviewed are listed in the Attachment The following systems were inspected
bull A train residual heal removal service water (RHRSW) system during B train RHRSW system testing
bull A train residual heat removal (RHR) during B train RHR testing bull S train emergency diesel generator (EDG) system during A train EDG system
maintenance and bull Advanced off-gas system (AOG) after maintenance
b Findings
No findings were identified
1 R05 Fire Protection (7111105 - 7 samples)
Quarterly Inspection (7111105Q - 6 samples)
a Inspection ScoQe
The inspectors performed inspections of six fire areas based on a review of the Vermont Yankee Safe Shutdown Capability Analysis the Fire Hazards Analysis and the Individual Plant Examination for External Events (IPEEE) The inspectors reviewed Entergys fire protection program to determine the specified fire protection design features fire area boundaries and combustible loading requirements for the selected areas The inspectors verified consistent with applicable administrative procedures that combustibles and ignition sources were adequately controlled passive fire barriers manual fire-fighting equipment and detection and suppression equipment were appropriately maintained and compensatory measures for out-ot-service degraded or inoperable fire protection equipment were implemented in accordance with Entergys fire protection program The inspectors evaluated the fire protection program for conformance with the requirements of License Condition 3F The documents reviewed are listed in the Attachment The following fire areas were inspected
Enclosure
6
bull Fire area FA-8 elevation 252 A EDG bull Fire area FA-9 elevation 252 B EDG bull Fire zone FZ-7 elevation 228 condenser bay basement bull Fire zone FZ- elevation 248 condenser bay and ground floor bull Reactor building RB-4 elevation 252 reactor building south and bull Reactor building RB-4 elevation 213 high pressure coolant injection (HPCI)
b Findings
No findings were identified
2 Annual Inspection (7111105A - 1 sample)
The inspectors evaluated Entergys fire brigade performance by observing an announced fire brigade drill on April 2 2010 The inspectors verified that the number of individuals assigned to the fire brigade response met the minimum specified number each member donned the protective clothing tumout gear and self-contained breathing apparatus the fire brigade leader exhibited command of the fire brigade and had copies of the pre-fire plans the fire brigade arrived at the fire scene in a timely manner the licensees drill scenario was followed and acceptance criteria for the drill objectives were met and the licensee performed a post-drill critique to discuss any failures and weaknesses associated with the fire drill performance
b Findings
No findings were identified
1RO Heat Sink Performance (7111107 - 2 samples)
Annual Inspection
a Inspection Scope
The inspectors reviewed the results of the thermal performance tests of emergency diesel generator heat exchangers for DG-1-1A and DG-1-1B including the scavenging air cooler lubricating oil cooler and jacket water cooler for each diesel The inspectors discussed the test results with the system engineer and reviewed the completed surveillance data to determine whether test results met acceptance criteria which considered differences between test and design basis accident conditions The inspectors also reviewed Entergys corrective action program (CAP) to ensure significant heat exchanger performance problems were appropriately identified and documented and that corrective actions assigned if any were appropriate A list of documents reviewed is provided in the Attachment to this report
b Findings
No findings were identified
Enclosure
7
1 R08 Inservice Inspection (lSI) (7111108 -1 sample)
a Inspection Scope
The purpose of this inspection was to assess the effectiveness of the licensees lSI program for monitoring degradation of reactor pressure vessel internals reactor coolant system boundary risk significant piping system boundaries and the containment boundary The inspector assessed the inservice inspection activities using requirements and acceptance criteria for component examination specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI and applicable NRC Regulatory Requirements
The inspector selected a sample of nondestructive examination (NDE) activities to perform a documentation review of those NDE activities for compliance with the requirements of the ASME Boiler and Pressure Vessel Code Section XI The sample selection was based on the inspection procedure objectives sample availability and risk priority of those components and systems where degradation could result in a significant increase in risk of core damage The inspector verified by documentation review that test procedures and examiner qualifications had been reviewed and approved for use by the licensee The inspector reviewed a sample of these procedures and qualifications to determine they were current and in accordance with the ASME Code requirements In addition the inspector performed this review to determine that examiners had been trained and qualified for use of the performance demonstration initiative (PDI) manual ultrasonic test procedures The inspector selected a sample of Indication Notification Reports (INR) and Condition Reports (CRs) to evaluate the licensees effectiveness in the identification and resolution of relevant indications discovered during the observed lSI activities The inspectors documentation review of non-destructive testing included the following
bull Ultrasonic test (UT) manual PDI-UT of weld overlay applied to core spray nozzles N5A-SE and N5B-SE (Examination data was reviewed for comparative evaluation with the UT examinations performed in 1993 1998 and 2004)
bull Magnetic particle test (MT) of sweep weld RH17-S-349A to the RHR piping drawing G191172 lSI Isometric ISI-5920-9212
bull Visual examination (VT-3) of component supports on torus suppression chamber (NB-H1951-TSS10 drawings 5920-914461359131 and 9133) and
bull Liquid Penetrant test (PT) of nozzle to safe end dissimilar butt weld N10-SE drawing ISI-RPV-103 location elevation 269 ft azimuth 350 degrees
The inspector reviewed the visual inspection results of various in-vessel components including jet pump structural members leveling devices miscellaneous fasteners and tack welds made to secure components in place These observations were made to determine the examiner skill and to assess the test equipment performance examination technique and the quality of the inspection environment (water clarity) The inspector performed a review of in-vessel component non-conforming conditions identified in CRs 2010-020112010-02016 and INR-VYR 28-0528-0628-0728-08 28-09 28-10 and 28-11 Additional CRs listed in the Attachment to this report were
Enclosure
8
reviewed by the inspector to evaluate the characterization and disposition of relevant indications identified during the in-vessel visual inspection (IWI) of structural components within the vessel
The inspector selected three ASME Section XI repairreplacement plans-for review where welding on a safety related pressure boundary was performed The review was performed to evaluate qualification and control of the welding process specified in the work order Also to determine that the weld procedures and welders assigned to perform this special process are qualified in accordance with the requirements of ASME Section XI and that specified weld examinations are done in accordance with the ASME code requirements The three ASME Section XI repairreplacement work orders reviewed were
bull W0184964-06 was developed for welding of fitting to service water (SW) piping to facilitate installation of valve V70-164C This welding was of stainless steel base materials welded in line 34SW-18A by groove welding using weld procedure specification (WPS) SS-88-8 Rev 21 Welds 48 and 49 added to the service water system as shown on Weld Map 184964-10 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3
bull W0178169-01 was developed to replace fourteen inch 0 service water pump discharge valve V70-2D Welding was of carbon steel to carbon steel using WPS CS-11-A Rev 3 by groove welding of pipe to valve and pipe to pipe (3 welds) as shown on weld map 178169-1 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3 and
bull W0184964-06 was developed to replace pipe to socket weld 47 in service water system line 34 SW-18A using WPS BM-81-A Rev 2 stainless to carbon steel as shown on weld map 184964-10RO Applicable Code for acceptance was ASME Section XI lSI Class 3
Additionally the inspector performed a visual evaluation of the primary containment liner and additional structural members attached to the liner to assess the condition of the protective coating The evaluation included accessible locations on elevations 252 thru 266 The inspector performed this visual evaluation to determine the extent of any peeling blistering coating loss or other damage as a result of corrosion foreign material impact or lack of maintenance Condition Report CR-VTY-2010-02337 was initiated to describe the results of this visual examination
b Findings
No findings were identified
Enclosure
9
1R11 Licensed Operator Requalification Program (71111110 - 1 sample)
Ouarterly Inspection
a Insgection Scoge
The inspectors observed a simulator-based licensed operator requalification (LOR) exam on June 10 2010 The inspectors assessed the performance of risk significant operator actions including the use of emergency operating procedures The inspectors evaluated crew performance in the areas of clarity and formality of communications ability to take timely actions prioritization interpretation and verification of alarms procedure usage control board manipulations and command and control The inspectors also compared the simulator configuration with the actual control board configuration Finally the inspectors verified that evaluators were identifying and documenting crew performance problems The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R12 Maintenance Effectiveness (71111120 - 3 samples)
a Inspection Scope
The inspectors reviewed performance-based problems involving selected in-scope structures systems and components (SSCs) to assess the effectiveness of the maintenance program The reviews focused on the following aspects when applicable
bull Proper maintenance rule scoping in accordance with 10 CFR 5065 bull Characterization of reliability issues bull Changing system and component unavailability bull 10 CFR 5065 (a)1) and (a)(2) classifications bull Identifying and addressing common cause failures bull Trending of system flow and temperature values bull Appropriateness of performance criteria for SSCs classified (a)(2) and bull Adequacy of goals and corrective actions for SSCs classified (a)(1)
The inspectors reviewed the applicable system health reports maintenance backlogs and Maintenance Rule basis documents The documents reviewed are listed in the Attachment The following structures systems and components were inspected
bull Residual Heat Removal (RHR) relief valves bull Core Spray CS and bull A recirculation pump motor generator set scoop tube positioner
Enclosure
10
b Findings
No findings were identified
1R13 Maintenance Risk Assessments and Emergent Work Control (7111113 -7 samples)
a Inspection Scope
The inspectors evaluated seven maintenance risk assessments for planned and emergent maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work The inspectors reviewed maintenance risk evaluations maintenance plans work schedules and control room logs to determine if concurrent or emergent maintenance or surveillance activities significantly increased the plant risk The inspectors reviewed risk assessments to determine if they were performed as required by 10 CFR 5065a)(4) and implemented in accordance with Entergys administrative procedures (AP) 0125 Plant Equipment and AP 0172 Work Schedule Risk Management - Online When emergent work was performed the inspectors observed activities to determine if plant risk was promptly reassessed and managed The documents reviewed are listed in the Attachment The following maintenance activities were inspected
bull On April 28 2010 increased risk due to removing the A station battery from service for planned maintenance
bull The week of May 32010 increased (yellow) risk due to refueling outage activities bull The week of May 10 2010 increased risk due to electrical bus outages to support
planned maintenance bull The week of May 17 2010 increased risk due to vessel drain down activities
installation of the reactor vessel head installation of the drywell vessel head and integrated leak rate testing to support outage activities
bull On June 8 2010 increased (yellow) risk due to primary containment being declared inoperable
bull On June 10 2010 high risk evolution associated with the CS system and bull On June 24 2010 high risk evolution associated with the A recirculation pump
motor~generator set scoop tube repair activities
b Findings
No findings were identified
1R15 Operability Evaluations (7111115 - 5 samples)
a Inspection Scope
The inspectors reviewed five operability evaluations associated with degraded or nonshyconforming conditions to assess the acceptability of the evaluations the use and control of applicable compensatory measures and compliance with Technical Specifications The inspectors reviewed and compared the technical adequacy of the evaluations with
Enclosure
1
11
the Technical Specifications Updated Final Safety Analysis Report associated design basis documents and Entergys procedure EN-OP-104 Operability Determinations The documents reviewed are listed in the Attachment The inspectors reviewed evaluations of the following degraded or non-conforming conditions
bull CR 2010-01686 pitting found on the RHRSW pump P-8-1C discharge piping bull CR 2010-01821 drywell dome gasket damage bull CR 2010-01944 SW strainer pitting below minimum wall thickness bull CR 2010-02285 S emergency diesel generator cylinder 10 temperature differs
from other cylinders by more than 300 degrees Fahrenheit and bull CR 2010-03202 GNF-2 (nuclear) fuel defect in the spacer springs at certain fuel pin
locations
b Findings
No findings were identified
1R18 Plant Modifications (7111118 - 3 samples)
Temporary Plant Modifications
a Inspection Scope (2 samples)
The inspectors reviewed two temporary modifications to ensure they did not adversely affect the availability reliability or functional capability of any risk-significant SSCs and assessed the adequacy of the 10 CFR 5059 evaluations The inspectors reviewed the engineering change package walked down the area interviewed various personnel and compared the installation and control of the modification to the procedural requirements The inspectors also verified that the installation was consistent with the modification documentation that the drawings and procedures were updated as applicable and that the post-installation testing was adequate The documents reviewed are listed in the Attachment The following two temporary modifications were reviewed
bull Engineering change (EC) 16583 temporary modification to provide power to 480VAC bus-710ads during a bus-7 outage and
bull EC 22659 temporary modification for the leak repair on the AOG two (2) inch pipe 2 CNPE-172A
b Findings
No findings were identified
Enclosure
2
12
Permanent Plant Modifications
a Inspection Scol2e (1 sample)
The inspectors reviewed EC16322 Replacement of Standby Fuel Pool Cooling Service Water Piping to ensure it did not adversely affect the availability reliability or functional capability of any risk-significant SSCs The inspectors reviewed the engineering change package and completed post-maintenance testing (PMT) package and observed the system in operation following the installation of the modification The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R19 Post-Maintenance Testing (7111119 - 10 samples)
a Inspection Scope
The inspectors reviewed ten post-maintenance test (PMT) activities on risk-significant systems The inspectors reviewed these activities to determine whether test acceptance criteria were clear and consistent with design basis documents When testing was directly observed the inspectors determined whether installed test equipment was appropriate and controlled and whether the test was performed in accordance with 10 CFR Part 50 Appendix B Criterion XI ~Test Control and applicable station procedures Upon completion the inspectors performed a walkdown to verify that equipment was returned to the proper alignment necessary to perform its safety function and evaluated whether conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the PMTs performed for the following maintenance activities
bull On April 9 2010 B normal fuel pool cooling pump seal replacement bull On April 21 2010 hydraulic control unit HCU-2235 valve (111 ) replacement bull On April 22 2010 A reactor water clean up pump seal replacement bull On May 32010 startup transformer (T-3-1B) refuel outage maintenance activities bull On May 2 2010 c service water pump discharge valve replacement
bull On May 16 2010 A EDG service water piping replacement bull On May 18 2010 post maintenance examination during RPV operational pressure
test following RPV relief valve replacement bull On June 8 2010 B RHR safety relief valve (SR-10-86B) replacement bull On June 10 2010 B core spray discharge piping safety relief valve (SR-14-20B)
replacement and bull On June 222010 B EDG fuel rack and governor maintenance
b Findings
No findings were identified
Enclosure
13
1 R20 Refueling and Other Outage Activities (7111120 -1 sample)
a Inspection Scope
The inspectors evaluated VY refueling outage (RFO) 28 activities to verify that Entergy considered risk when developing outage schedules adhered to administrative risk reduction methodologies for plant configuration control and adhered to their operating license TS requirements and approved procedures A list of documents reviewed is provided in the Attachment The following activities were inspected
bull Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 28 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions electrical power availability inventory control decay heat removal reactivity control and containment The daily risk assessments accounting for schedule changes and unplanned activities were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate
bull Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations As soon as practical following the shutdown the inspectors performed walkdown inspections of the primary containment
bull Electrical Power - The inspectors reviewed the status and configuration of safetyshyrelated buses throughout RFO 28 The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers the auxiliary transformer and the emergency diesel generators
bull Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (Le shutdown cooling) status on a daily basis Monitoring included daily reviews of residual heat removal system alignment reviews of spent fuel pool cooling system alignment and reviews of RCS time-to-boil calculations and results
bull Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan
bull Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling eVolutions including procedure place keeping communications with refueling floor personnel monitoring of source range nuclear instrumentation and monitoring of individual control rod positions
bull Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage The inspectors
Enclosure
14
performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
15
conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
I I
M Colomb 2
In accordance with 10 CFR 2390 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 document system (ADAMS) ADAMS is accessible from the NRC Web Site at
httpwwwnrcgovreading-rmadamshtml (the Public Electronic Reading Room)
Sincerely
IRAt
Donald E Jackson Chief Projects Branch 5 Division of Reactor Projects
Docket No 50-271 License Nos DPR-28
Enclosure Inspection Report No 050002712010003 wi Attachment Supplemental Information
Distribution wencl (via Email) M Oapas Acting RA (R10RAMAIL RESOURCE) D Lew Acting DRA (R10RAMAIL RESOURCE) J Clifford DR (R1DRPMAIL RESOURCE) D Collins DRP (R1DRPMAIL RESOURCE) D Roberts DRS (R1DRSMAILResource) P Wilson DRS (R1 DRSMAILResource) L Trocine RI DEDO D Jackson DRP
D Spindler DRP SRI T Setzer DRP J Heinly DRP H Jones DRP RI A Rancourt DRP DA RidsNrrPMVermontYankee Resource RidsNrrDorlL11-1 Resource ROPreportsResourcenrcgov
SUNSI Review Complete __-TCS-__ (Reviewers Initials)
Adams Accession No ML 102100320
DOCUMENT NAME GORPBRANCH5ReportsOraftsVYIR2010003revOdocm After declaring this document An Official Agency Record it will be released to the Public To receive a copy of this document indicate in the box C = Copy without attachmentenclosure
E = Copy with attachmentenclosure N = No copy
FICE RIDRP lhP RIDRP I RIIDRP I RIIDRPI
NAME DSpindlertcs for TSetzertcs DJacksontcs
DATE 072810 072810 072910
Enclosure
Docket No
license No
Report No
licensee
Facility
Location
Dates
Inspectors
Approved by
1
US NUCLEAR REGULATORY COMMISSION
REGION I
50-271
DPR-28
050002712010003
Entergy Nuclear Operations Inc
Vermont Yankee Nuclear Power Station
Vernon Vermont 05354-9766
April 1 2010 through June 30 2010
D Spindler Sr Resident Inspector DRP H Jones Resident Inspector ORP J Noggle Sr Health Physicist DRS T Burns Reactor Inspector DRS M Reichard Health Physicist DNMS
Donald E Jackson Chief Projects Branch 5 Division of Reactor Projects
i
Enclosure
2
TABLE OF CONTENTS
SUMMARY OF FINDINGS 111 bullbullbullbullbullbullbullbullbullbullbull3_
REPORT DETAILS bull bullbullbull 4
1 REACTOR SAFEfYbullbullbullbullbull a 4 1R01 Adverse Weather Protection 4 1R04 Equipment Alignment 5 1R05 Fire Protection 5 1R07 Heat Sink Performance 6 1R08 Inservice Inspection lSi) 7 1R11 Licensed Operator Requalification Program 9 1R12 Maintenance Effectiveness 9 1R13 Maintenance Risk Assessments and Emergent Work Control 10 1R15 Operability Evaluations 10 1R18 Plant Modifications 11 1R19 Post-Maintenance Testing 12 1R20 Refueling and Other Outage Activities 13 1R22 Surveillance Testing 16 1EP6 Drill Evaluation bullbullbullbullbullbullbullbull bullbullbullbullbullbullbullbull bull 16
2 RADIATION SAFEfY 17 2RS01 Radiological Hazard Assessment and Exposure Controls 17 2RS02 Occupational ALARA Planning and Controls 19 2RS04 Occupational Dose Assessment 19 2RS05 Radiation Monitoring Instruments 20
4 OTHER ACTIVITIES lOA] 23 4OA1 Performance Indicator (PI) Verification 23 40A2 Identification and Resolution of Problems 24 4OA5 Other Activities 26 40A6 Meetings including Exit 27
AITACHMENT SUPPLEMENTAL INFORMATION 27
KEY POINTS OF CONTACT Amiddot1
LIST OF ITEMS OPENED CLOSED AND DISCUSSED A-2
LIST OF DOCUMENTS REVIEWED A-2
LIST OF ACRONYMS I0~ t bullbullbull bullbull A11
Enclosure
3
SUMMARY OF FINDINGS
IR 050002712010003 04012010 - 06302010 Vermont Yankee Nuclear Power Station Refueling and Other Outage Activities
This report covered a three-month period of inspection by resident inspector staff and regionshybased inspectors One Green self-revealing finding which was determined to be a non-cited
I violation (NCV) was identified The significance of most findings is indicated by their coor (Green White Yellow Red) using Inspection Manua Chapter (IMC) 0609 Significance Determination Process The cross-cutting aspect for the finding was determined using IMC 0310 Components Within The Cross-Cutting Areas Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649 Reactor Oversight Process Revision 4 dated December 2006
Cornerstone Mitigating Systems
Green A self-revealing NCV of very low safety significance (Green) of Technical Specification (TS) 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECGS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages
The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining RCS inventory [H2(c)] (Section 1R20)
Enclosure
1
4
REPORT DETAILS
Summary of Plant Status
Vermont Yankee (VY) Nuclear Power Station began the inspection period operating at 100 percent power On April 24 2010 VY performed a planned power reduction to support the refueling and maintenance outage On May 26 2010 VY began power ascension after completion of the refueling outage however the unit automatically shut down at 70 percent power due to a recent modification design issue After correcting the modification issue VY began power ascension on May 29 2010 VY reached 100 percent power on June 1 2010 and remained at or near 100 percent power for the duration of the inspection period
1 REACTOR SAFETY
Cornerstones Initiating Events Mitigating Systems Barrier Integrity
1R01 Adverse Weather Protection (7111101-1 sample)
Grid Stability - Summer Readiness of Offsite and Alternate AC Power Systems
a Inspection Scoge
The inspectors performed a review of Entergys offsite and alternate AC power system readiness for adverse weather The inspectors reviewed Entergys plant features and procedures for operation and continued availability of their AC power systems to determine if they were appropriate The inspection focused on Entergys procedures for communication protocols with the transmission system operator (TSO) to determine if appropriate information would be exchanged when issues arise that could impact the offsite power system The inspectors also reviewed Entergys procedures to determine if they addressed necessary actions to be taken if notified by the TSO that they needed to transfer safety-related loads to the onsite power supply compensatory actions to be taken if it were not possible to predict grid conditions and required communications between Entergy and the TSO The inspectors interviewed personnel and performed a walkdown of the switchyard A list of documents reviewed is provided in the Attachment
b Findings
No findings were identified
Enclosure
1
5
1 R04 Equipment Alignment (7111104 - 4 samples)
Partial Equipment Alignment
a Inspection ScoQe
The inspectors performed four partial system walk downs to verify correct system alignment and to identify any discrepancies that could impact system operability Observed plant conditions were compared to the standby alignment of equipment specified in applicable piping and instrumentation drawings and operating procedures (OPs) The inspectors verified valve positions and the general condition of selected components Finally the inspectors evaluated material condition housekeeping and component labeling The documents reviewed are listed in the Attachment The following systems were inspected
bull A train residual heal removal service water (RHRSW) system during B train RHRSW system testing
bull A train residual heat removal (RHR) during B train RHR testing bull S train emergency diesel generator (EDG) system during A train EDG system
maintenance and bull Advanced off-gas system (AOG) after maintenance
b Findings
No findings were identified
1 R05 Fire Protection (7111105 - 7 samples)
Quarterly Inspection (7111105Q - 6 samples)
a Inspection ScoQe
The inspectors performed inspections of six fire areas based on a review of the Vermont Yankee Safe Shutdown Capability Analysis the Fire Hazards Analysis and the Individual Plant Examination for External Events (IPEEE) The inspectors reviewed Entergys fire protection program to determine the specified fire protection design features fire area boundaries and combustible loading requirements for the selected areas The inspectors verified consistent with applicable administrative procedures that combustibles and ignition sources were adequately controlled passive fire barriers manual fire-fighting equipment and detection and suppression equipment were appropriately maintained and compensatory measures for out-ot-service degraded or inoperable fire protection equipment were implemented in accordance with Entergys fire protection program The inspectors evaluated the fire protection program for conformance with the requirements of License Condition 3F The documents reviewed are listed in the Attachment The following fire areas were inspected
Enclosure
6
bull Fire area FA-8 elevation 252 A EDG bull Fire area FA-9 elevation 252 B EDG bull Fire zone FZ-7 elevation 228 condenser bay basement bull Fire zone FZ- elevation 248 condenser bay and ground floor bull Reactor building RB-4 elevation 252 reactor building south and bull Reactor building RB-4 elevation 213 high pressure coolant injection (HPCI)
b Findings
No findings were identified
2 Annual Inspection (7111105A - 1 sample)
The inspectors evaluated Entergys fire brigade performance by observing an announced fire brigade drill on April 2 2010 The inspectors verified that the number of individuals assigned to the fire brigade response met the minimum specified number each member donned the protective clothing tumout gear and self-contained breathing apparatus the fire brigade leader exhibited command of the fire brigade and had copies of the pre-fire plans the fire brigade arrived at the fire scene in a timely manner the licensees drill scenario was followed and acceptance criteria for the drill objectives were met and the licensee performed a post-drill critique to discuss any failures and weaknesses associated with the fire drill performance
b Findings
No findings were identified
1RO Heat Sink Performance (7111107 - 2 samples)
Annual Inspection
a Inspection Scope
The inspectors reviewed the results of the thermal performance tests of emergency diesel generator heat exchangers for DG-1-1A and DG-1-1B including the scavenging air cooler lubricating oil cooler and jacket water cooler for each diesel The inspectors discussed the test results with the system engineer and reviewed the completed surveillance data to determine whether test results met acceptance criteria which considered differences between test and design basis accident conditions The inspectors also reviewed Entergys corrective action program (CAP) to ensure significant heat exchanger performance problems were appropriately identified and documented and that corrective actions assigned if any were appropriate A list of documents reviewed is provided in the Attachment to this report
b Findings
No findings were identified
Enclosure
7
1 R08 Inservice Inspection (lSI) (7111108 -1 sample)
a Inspection Scope
The purpose of this inspection was to assess the effectiveness of the licensees lSI program for monitoring degradation of reactor pressure vessel internals reactor coolant system boundary risk significant piping system boundaries and the containment boundary The inspector assessed the inservice inspection activities using requirements and acceptance criteria for component examination specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI and applicable NRC Regulatory Requirements
The inspector selected a sample of nondestructive examination (NDE) activities to perform a documentation review of those NDE activities for compliance with the requirements of the ASME Boiler and Pressure Vessel Code Section XI The sample selection was based on the inspection procedure objectives sample availability and risk priority of those components and systems where degradation could result in a significant increase in risk of core damage The inspector verified by documentation review that test procedures and examiner qualifications had been reviewed and approved for use by the licensee The inspector reviewed a sample of these procedures and qualifications to determine they were current and in accordance with the ASME Code requirements In addition the inspector performed this review to determine that examiners had been trained and qualified for use of the performance demonstration initiative (PDI) manual ultrasonic test procedures The inspector selected a sample of Indication Notification Reports (INR) and Condition Reports (CRs) to evaluate the licensees effectiveness in the identification and resolution of relevant indications discovered during the observed lSI activities The inspectors documentation review of non-destructive testing included the following
bull Ultrasonic test (UT) manual PDI-UT of weld overlay applied to core spray nozzles N5A-SE and N5B-SE (Examination data was reviewed for comparative evaluation with the UT examinations performed in 1993 1998 and 2004)
bull Magnetic particle test (MT) of sweep weld RH17-S-349A to the RHR piping drawing G191172 lSI Isometric ISI-5920-9212
bull Visual examination (VT-3) of component supports on torus suppression chamber (NB-H1951-TSS10 drawings 5920-914461359131 and 9133) and
bull Liquid Penetrant test (PT) of nozzle to safe end dissimilar butt weld N10-SE drawing ISI-RPV-103 location elevation 269 ft azimuth 350 degrees
The inspector reviewed the visual inspection results of various in-vessel components including jet pump structural members leveling devices miscellaneous fasteners and tack welds made to secure components in place These observations were made to determine the examiner skill and to assess the test equipment performance examination technique and the quality of the inspection environment (water clarity) The inspector performed a review of in-vessel component non-conforming conditions identified in CRs 2010-020112010-02016 and INR-VYR 28-0528-0628-0728-08 28-09 28-10 and 28-11 Additional CRs listed in the Attachment to this report were
Enclosure
8
reviewed by the inspector to evaluate the characterization and disposition of relevant indications identified during the in-vessel visual inspection (IWI) of structural components within the vessel
The inspector selected three ASME Section XI repairreplacement plans-for review where welding on a safety related pressure boundary was performed The review was performed to evaluate qualification and control of the welding process specified in the work order Also to determine that the weld procedures and welders assigned to perform this special process are qualified in accordance with the requirements of ASME Section XI and that specified weld examinations are done in accordance with the ASME code requirements The three ASME Section XI repairreplacement work orders reviewed were
bull W0184964-06 was developed for welding of fitting to service water (SW) piping to facilitate installation of valve V70-164C This welding was of stainless steel base materials welded in line 34SW-18A by groove welding using weld procedure specification (WPS) SS-88-8 Rev 21 Welds 48 and 49 added to the service water system as shown on Weld Map 184964-10 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3
bull W0178169-01 was developed to replace fourteen inch 0 service water pump discharge valve V70-2D Welding was of carbon steel to carbon steel using WPS CS-11-A Rev 3 by groove welding of pipe to valve and pipe to pipe (3 welds) as shown on weld map 178169-1 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3 and
bull W0184964-06 was developed to replace pipe to socket weld 47 in service water system line 34 SW-18A using WPS BM-81-A Rev 2 stainless to carbon steel as shown on weld map 184964-10RO Applicable Code for acceptance was ASME Section XI lSI Class 3
Additionally the inspector performed a visual evaluation of the primary containment liner and additional structural members attached to the liner to assess the condition of the protective coating The evaluation included accessible locations on elevations 252 thru 266 The inspector performed this visual evaluation to determine the extent of any peeling blistering coating loss or other damage as a result of corrosion foreign material impact or lack of maintenance Condition Report CR-VTY-2010-02337 was initiated to describe the results of this visual examination
b Findings
No findings were identified
Enclosure
9
1R11 Licensed Operator Requalification Program (71111110 - 1 sample)
Ouarterly Inspection
a Insgection Scoge
The inspectors observed a simulator-based licensed operator requalification (LOR) exam on June 10 2010 The inspectors assessed the performance of risk significant operator actions including the use of emergency operating procedures The inspectors evaluated crew performance in the areas of clarity and formality of communications ability to take timely actions prioritization interpretation and verification of alarms procedure usage control board manipulations and command and control The inspectors also compared the simulator configuration with the actual control board configuration Finally the inspectors verified that evaluators were identifying and documenting crew performance problems The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R12 Maintenance Effectiveness (71111120 - 3 samples)
a Inspection Scope
The inspectors reviewed performance-based problems involving selected in-scope structures systems and components (SSCs) to assess the effectiveness of the maintenance program The reviews focused on the following aspects when applicable
bull Proper maintenance rule scoping in accordance with 10 CFR 5065 bull Characterization of reliability issues bull Changing system and component unavailability bull 10 CFR 5065 (a)1) and (a)(2) classifications bull Identifying and addressing common cause failures bull Trending of system flow and temperature values bull Appropriateness of performance criteria for SSCs classified (a)(2) and bull Adequacy of goals and corrective actions for SSCs classified (a)(1)
The inspectors reviewed the applicable system health reports maintenance backlogs and Maintenance Rule basis documents The documents reviewed are listed in the Attachment The following structures systems and components were inspected
bull Residual Heat Removal (RHR) relief valves bull Core Spray CS and bull A recirculation pump motor generator set scoop tube positioner
Enclosure
10
b Findings
No findings were identified
1R13 Maintenance Risk Assessments and Emergent Work Control (7111113 -7 samples)
a Inspection Scope
The inspectors evaluated seven maintenance risk assessments for planned and emergent maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work The inspectors reviewed maintenance risk evaluations maintenance plans work schedules and control room logs to determine if concurrent or emergent maintenance or surveillance activities significantly increased the plant risk The inspectors reviewed risk assessments to determine if they were performed as required by 10 CFR 5065a)(4) and implemented in accordance with Entergys administrative procedures (AP) 0125 Plant Equipment and AP 0172 Work Schedule Risk Management - Online When emergent work was performed the inspectors observed activities to determine if plant risk was promptly reassessed and managed The documents reviewed are listed in the Attachment The following maintenance activities were inspected
bull On April 28 2010 increased risk due to removing the A station battery from service for planned maintenance
bull The week of May 32010 increased (yellow) risk due to refueling outage activities bull The week of May 10 2010 increased risk due to electrical bus outages to support
planned maintenance bull The week of May 17 2010 increased risk due to vessel drain down activities
installation of the reactor vessel head installation of the drywell vessel head and integrated leak rate testing to support outage activities
bull On June 8 2010 increased (yellow) risk due to primary containment being declared inoperable
bull On June 10 2010 high risk evolution associated with the CS system and bull On June 24 2010 high risk evolution associated with the A recirculation pump
motor~generator set scoop tube repair activities
b Findings
No findings were identified
1R15 Operability Evaluations (7111115 - 5 samples)
a Inspection Scope
The inspectors reviewed five operability evaluations associated with degraded or nonshyconforming conditions to assess the acceptability of the evaluations the use and control of applicable compensatory measures and compliance with Technical Specifications The inspectors reviewed and compared the technical adequacy of the evaluations with
Enclosure
1
11
the Technical Specifications Updated Final Safety Analysis Report associated design basis documents and Entergys procedure EN-OP-104 Operability Determinations The documents reviewed are listed in the Attachment The inspectors reviewed evaluations of the following degraded or non-conforming conditions
bull CR 2010-01686 pitting found on the RHRSW pump P-8-1C discharge piping bull CR 2010-01821 drywell dome gasket damage bull CR 2010-01944 SW strainer pitting below minimum wall thickness bull CR 2010-02285 S emergency diesel generator cylinder 10 temperature differs
from other cylinders by more than 300 degrees Fahrenheit and bull CR 2010-03202 GNF-2 (nuclear) fuel defect in the spacer springs at certain fuel pin
locations
b Findings
No findings were identified
1R18 Plant Modifications (7111118 - 3 samples)
Temporary Plant Modifications
a Inspection Scope (2 samples)
The inspectors reviewed two temporary modifications to ensure they did not adversely affect the availability reliability or functional capability of any risk-significant SSCs and assessed the adequacy of the 10 CFR 5059 evaluations The inspectors reviewed the engineering change package walked down the area interviewed various personnel and compared the installation and control of the modification to the procedural requirements The inspectors also verified that the installation was consistent with the modification documentation that the drawings and procedures were updated as applicable and that the post-installation testing was adequate The documents reviewed are listed in the Attachment The following two temporary modifications were reviewed
bull Engineering change (EC) 16583 temporary modification to provide power to 480VAC bus-710ads during a bus-7 outage and
bull EC 22659 temporary modification for the leak repair on the AOG two (2) inch pipe 2 CNPE-172A
b Findings
No findings were identified
Enclosure
2
12
Permanent Plant Modifications
a Inspection Scol2e (1 sample)
The inspectors reviewed EC16322 Replacement of Standby Fuel Pool Cooling Service Water Piping to ensure it did not adversely affect the availability reliability or functional capability of any risk-significant SSCs The inspectors reviewed the engineering change package and completed post-maintenance testing (PMT) package and observed the system in operation following the installation of the modification The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R19 Post-Maintenance Testing (7111119 - 10 samples)
a Inspection Scope
The inspectors reviewed ten post-maintenance test (PMT) activities on risk-significant systems The inspectors reviewed these activities to determine whether test acceptance criteria were clear and consistent with design basis documents When testing was directly observed the inspectors determined whether installed test equipment was appropriate and controlled and whether the test was performed in accordance with 10 CFR Part 50 Appendix B Criterion XI ~Test Control and applicable station procedures Upon completion the inspectors performed a walkdown to verify that equipment was returned to the proper alignment necessary to perform its safety function and evaluated whether conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the PMTs performed for the following maintenance activities
bull On April 9 2010 B normal fuel pool cooling pump seal replacement bull On April 21 2010 hydraulic control unit HCU-2235 valve (111 ) replacement bull On April 22 2010 A reactor water clean up pump seal replacement bull On May 32010 startup transformer (T-3-1B) refuel outage maintenance activities bull On May 2 2010 c service water pump discharge valve replacement
bull On May 16 2010 A EDG service water piping replacement bull On May 18 2010 post maintenance examination during RPV operational pressure
test following RPV relief valve replacement bull On June 8 2010 B RHR safety relief valve (SR-10-86B) replacement bull On June 10 2010 B core spray discharge piping safety relief valve (SR-14-20B)
replacement and bull On June 222010 B EDG fuel rack and governor maintenance
b Findings
No findings were identified
Enclosure
13
1 R20 Refueling and Other Outage Activities (7111120 -1 sample)
a Inspection Scope
The inspectors evaluated VY refueling outage (RFO) 28 activities to verify that Entergy considered risk when developing outage schedules adhered to administrative risk reduction methodologies for plant configuration control and adhered to their operating license TS requirements and approved procedures A list of documents reviewed is provided in the Attachment The following activities were inspected
bull Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 28 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions electrical power availability inventory control decay heat removal reactivity control and containment The daily risk assessments accounting for schedule changes and unplanned activities were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate
bull Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations As soon as practical following the shutdown the inspectors performed walkdown inspections of the primary containment
bull Electrical Power - The inspectors reviewed the status and configuration of safetyshyrelated buses throughout RFO 28 The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers the auxiliary transformer and the emergency diesel generators
bull Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (Le shutdown cooling) status on a daily basis Monitoring included daily reviews of residual heat removal system alignment reviews of spent fuel pool cooling system alignment and reviews of RCS time-to-boil calculations and results
bull Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan
bull Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling eVolutions including procedure place keeping communications with refueling floor personnel monitoring of source range nuclear instrumentation and monitoring of individual control rod positions
bull Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage The inspectors
Enclosure
14
performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
15
conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
Docket No
license No
Report No
licensee
Facility
Location
Dates
Inspectors
Approved by
1
US NUCLEAR REGULATORY COMMISSION
REGION I
50-271
DPR-28
050002712010003
Entergy Nuclear Operations Inc
Vermont Yankee Nuclear Power Station
Vernon Vermont 05354-9766
April 1 2010 through June 30 2010
D Spindler Sr Resident Inspector DRP H Jones Resident Inspector ORP J Noggle Sr Health Physicist DRS T Burns Reactor Inspector DRS M Reichard Health Physicist DNMS
Donald E Jackson Chief Projects Branch 5 Division of Reactor Projects
i
Enclosure
2
TABLE OF CONTENTS
SUMMARY OF FINDINGS 111 bullbullbullbullbullbullbullbullbullbullbull3_
REPORT DETAILS bull bullbullbull 4
1 REACTOR SAFEfYbullbullbullbullbull a 4 1R01 Adverse Weather Protection 4 1R04 Equipment Alignment 5 1R05 Fire Protection 5 1R07 Heat Sink Performance 6 1R08 Inservice Inspection lSi) 7 1R11 Licensed Operator Requalification Program 9 1R12 Maintenance Effectiveness 9 1R13 Maintenance Risk Assessments and Emergent Work Control 10 1R15 Operability Evaluations 10 1R18 Plant Modifications 11 1R19 Post-Maintenance Testing 12 1R20 Refueling and Other Outage Activities 13 1R22 Surveillance Testing 16 1EP6 Drill Evaluation bullbullbullbullbullbullbullbull bullbullbullbullbullbullbullbull bull 16
2 RADIATION SAFEfY 17 2RS01 Radiological Hazard Assessment and Exposure Controls 17 2RS02 Occupational ALARA Planning and Controls 19 2RS04 Occupational Dose Assessment 19 2RS05 Radiation Monitoring Instruments 20
4 OTHER ACTIVITIES lOA] 23 4OA1 Performance Indicator (PI) Verification 23 40A2 Identification and Resolution of Problems 24 4OA5 Other Activities 26 40A6 Meetings including Exit 27
AITACHMENT SUPPLEMENTAL INFORMATION 27
KEY POINTS OF CONTACT Amiddot1
LIST OF ITEMS OPENED CLOSED AND DISCUSSED A-2
LIST OF DOCUMENTS REVIEWED A-2
LIST OF ACRONYMS I0~ t bullbullbull bullbull A11
Enclosure
3
SUMMARY OF FINDINGS
IR 050002712010003 04012010 - 06302010 Vermont Yankee Nuclear Power Station Refueling and Other Outage Activities
This report covered a three-month period of inspection by resident inspector staff and regionshybased inspectors One Green self-revealing finding which was determined to be a non-cited
I violation (NCV) was identified The significance of most findings is indicated by their coor (Green White Yellow Red) using Inspection Manua Chapter (IMC) 0609 Significance Determination Process The cross-cutting aspect for the finding was determined using IMC 0310 Components Within The Cross-Cutting Areas Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649 Reactor Oversight Process Revision 4 dated December 2006
Cornerstone Mitigating Systems
Green A self-revealing NCV of very low safety significance (Green) of Technical Specification (TS) 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECGS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages
The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining RCS inventory [H2(c)] (Section 1R20)
Enclosure
1
4
REPORT DETAILS
Summary of Plant Status
Vermont Yankee (VY) Nuclear Power Station began the inspection period operating at 100 percent power On April 24 2010 VY performed a planned power reduction to support the refueling and maintenance outage On May 26 2010 VY began power ascension after completion of the refueling outage however the unit automatically shut down at 70 percent power due to a recent modification design issue After correcting the modification issue VY began power ascension on May 29 2010 VY reached 100 percent power on June 1 2010 and remained at or near 100 percent power for the duration of the inspection period
1 REACTOR SAFETY
Cornerstones Initiating Events Mitigating Systems Barrier Integrity
1R01 Adverse Weather Protection (7111101-1 sample)
Grid Stability - Summer Readiness of Offsite and Alternate AC Power Systems
a Inspection Scoge
The inspectors performed a review of Entergys offsite and alternate AC power system readiness for adverse weather The inspectors reviewed Entergys plant features and procedures for operation and continued availability of their AC power systems to determine if they were appropriate The inspection focused on Entergys procedures for communication protocols with the transmission system operator (TSO) to determine if appropriate information would be exchanged when issues arise that could impact the offsite power system The inspectors also reviewed Entergys procedures to determine if they addressed necessary actions to be taken if notified by the TSO that they needed to transfer safety-related loads to the onsite power supply compensatory actions to be taken if it were not possible to predict grid conditions and required communications between Entergy and the TSO The inspectors interviewed personnel and performed a walkdown of the switchyard A list of documents reviewed is provided in the Attachment
b Findings
No findings were identified
Enclosure
1
5
1 R04 Equipment Alignment (7111104 - 4 samples)
Partial Equipment Alignment
a Inspection ScoQe
The inspectors performed four partial system walk downs to verify correct system alignment and to identify any discrepancies that could impact system operability Observed plant conditions were compared to the standby alignment of equipment specified in applicable piping and instrumentation drawings and operating procedures (OPs) The inspectors verified valve positions and the general condition of selected components Finally the inspectors evaluated material condition housekeeping and component labeling The documents reviewed are listed in the Attachment The following systems were inspected
bull A train residual heal removal service water (RHRSW) system during B train RHRSW system testing
bull A train residual heat removal (RHR) during B train RHR testing bull S train emergency diesel generator (EDG) system during A train EDG system
maintenance and bull Advanced off-gas system (AOG) after maintenance
b Findings
No findings were identified
1 R05 Fire Protection (7111105 - 7 samples)
Quarterly Inspection (7111105Q - 6 samples)
a Inspection ScoQe
The inspectors performed inspections of six fire areas based on a review of the Vermont Yankee Safe Shutdown Capability Analysis the Fire Hazards Analysis and the Individual Plant Examination for External Events (IPEEE) The inspectors reviewed Entergys fire protection program to determine the specified fire protection design features fire area boundaries and combustible loading requirements for the selected areas The inspectors verified consistent with applicable administrative procedures that combustibles and ignition sources were adequately controlled passive fire barriers manual fire-fighting equipment and detection and suppression equipment were appropriately maintained and compensatory measures for out-ot-service degraded or inoperable fire protection equipment were implemented in accordance with Entergys fire protection program The inspectors evaluated the fire protection program for conformance with the requirements of License Condition 3F The documents reviewed are listed in the Attachment The following fire areas were inspected
Enclosure
6
bull Fire area FA-8 elevation 252 A EDG bull Fire area FA-9 elevation 252 B EDG bull Fire zone FZ-7 elevation 228 condenser bay basement bull Fire zone FZ- elevation 248 condenser bay and ground floor bull Reactor building RB-4 elevation 252 reactor building south and bull Reactor building RB-4 elevation 213 high pressure coolant injection (HPCI)
b Findings
No findings were identified
2 Annual Inspection (7111105A - 1 sample)
The inspectors evaluated Entergys fire brigade performance by observing an announced fire brigade drill on April 2 2010 The inspectors verified that the number of individuals assigned to the fire brigade response met the minimum specified number each member donned the protective clothing tumout gear and self-contained breathing apparatus the fire brigade leader exhibited command of the fire brigade and had copies of the pre-fire plans the fire brigade arrived at the fire scene in a timely manner the licensees drill scenario was followed and acceptance criteria for the drill objectives were met and the licensee performed a post-drill critique to discuss any failures and weaknesses associated with the fire drill performance
b Findings
No findings were identified
1RO Heat Sink Performance (7111107 - 2 samples)
Annual Inspection
a Inspection Scope
The inspectors reviewed the results of the thermal performance tests of emergency diesel generator heat exchangers for DG-1-1A and DG-1-1B including the scavenging air cooler lubricating oil cooler and jacket water cooler for each diesel The inspectors discussed the test results with the system engineer and reviewed the completed surveillance data to determine whether test results met acceptance criteria which considered differences between test and design basis accident conditions The inspectors also reviewed Entergys corrective action program (CAP) to ensure significant heat exchanger performance problems were appropriately identified and documented and that corrective actions assigned if any were appropriate A list of documents reviewed is provided in the Attachment to this report
b Findings
No findings were identified
Enclosure
7
1 R08 Inservice Inspection (lSI) (7111108 -1 sample)
a Inspection Scope
The purpose of this inspection was to assess the effectiveness of the licensees lSI program for monitoring degradation of reactor pressure vessel internals reactor coolant system boundary risk significant piping system boundaries and the containment boundary The inspector assessed the inservice inspection activities using requirements and acceptance criteria for component examination specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI and applicable NRC Regulatory Requirements
The inspector selected a sample of nondestructive examination (NDE) activities to perform a documentation review of those NDE activities for compliance with the requirements of the ASME Boiler and Pressure Vessel Code Section XI The sample selection was based on the inspection procedure objectives sample availability and risk priority of those components and systems where degradation could result in a significant increase in risk of core damage The inspector verified by documentation review that test procedures and examiner qualifications had been reviewed and approved for use by the licensee The inspector reviewed a sample of these procedures and qualifications to determine they were current and in accordance with the ASME Code requirements In addition the inspector performed this review to determine that examiners had been trained and qualified for use of the performance demonstration initiative (PDI) manual ultrasonic test procedures The inspector selected a sample of Indication Notification Reports (INR) and Condition Reports (CRs) to evaluate the licensees effectiveness in the identification and resolution of relevant indications discovered during the observed lSI activities The inspectors documentation review of non-destructive testing included the following
bull Ultrasonic test (UT) manual PDI-UT of weld overlay applied to core spray nozzles N5A-SE and N5B-SE (Examination data was reviewed for comparative evaluation with the UT examinations performed in 1993 1998 and 2004)
bull Magnetic particle test (MT) of sweep weld RH17-S-349A to the RHR piping drawing G191172 lSI Isometric ISI-5920-9212
bull Visual examination (VT-3) of component supports on torus suppression chamber (NB-H1951-TSS10 drawings 5920-914461359131 and 9133) and
bull Liquid Penetrant test (PT) of nozzle to safe end dissimilar butt weld N10-SE drawing ISI-RPV-103 location elevation 269 ft azimuth 350 degrees
The inspector reviewed the visual inspection results of various in-vessel components including jet pump structural members leveling devices miscellaneous fasteners and tack welds made to secure components in place These observations were made to determine the examiner skill and to assess the test equipment performance examination technique and the quality of the inspection environment (water clarity) The inspector performed a review of in-vessel component non-conforming conditions identified in CRs 2010-020112010-02016 and INR-VYR 28-0528-0628-0728-08 28-09 28-10 and 28-11 Additional CRs listed in the Attachment to this report were
Enclosure
8
reviewed by the inspector to evaluate the characterization and disposition of relevant indications identified during the in-vessel visual inspection (IWI) of structural components within the vessel
The inspector selected three ASME Section XI repairreplacement plans-for review where welding on a safety related pressure boundary was performed The review was performed to evaluate qualification and control of the welding process specified in the work order Also to determine that the weld procedures and welders assigned to perform this special process are qualified in accordance with the requirements of ASME Section XI and that specified weld examinations are done in accordance with the ASME code requirements The three ASME Section XI repairreplacement work orders reviewed were
bull W0184964-06 was developed for welding of fitting to service water (SW) piping to facilitate installation of valve V70-164C This welding was of stainless steel base materials welded in line 34SW-18A by groove welding using weld procedure specification (WPS) SS-88-8 Rev 21 Welds 48 and 49 added to the service water system as shown on Weld Map 184964-10 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3
bull W0178169-01 was developed to replace fourteen inch 0 service water pump discharge valve V70-2D Welding was of carbon steel to carbon steel using WPS CS-11-A Rev 3 by groove welding of pipe to valve and pipe to pipe (3 welds) as shown on weld map 178169-1 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3 and
bull W0184964-06 was developed to replace pipe to socket weld 47 in service water system line 34 SW-18A using WPS BM-81-A Rev 2 stainless to carbon steel as shown on weld map 184964-10RO Applicable Code for acceptance was ASME Section XI lSI Class 3
Additionally the inspector performed a visual evaluation of the primary containment liner and additional structural members attached to the liner to assess the condition of the protective coating The evaluation included accessible locations on elevations 252 thru 266 The inspector performed this visual evaluation to determine the extent of any peeling blistering coating loss or other damage as a result of corrosion foreign material impact or lack of maintenance Condition Report CR-VTY-2010-02337 was initiated to describe the results of this visual examination
b Findings
No findings were identified
Enclosure
9
1R11 Licensed Operator Requalification Program (71111110 - 1 sample)
Ouarterly Inspection
a Insgection Scoge
The inspectors observed a simulator-based licensed operator requalification (LOR) exam on June 10 2010 The inspectors assessed the performance of risk significant operator actions including the use of emergency operating procedures The inspectors evaluated crew performance in the areas of clarity and formality of communications ability to take timely actions prioritization interpretation and verification of alarms procedure usage control board manipulations and command and control The inspectors also compared the simulator configuration with the actual control board configuration Finally the inspectors verified that evaluators were identifying and documenting crew performance problems The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R12 Maintenance Effectiveness (71111120 - 3 samples)
a Inspection Scope
The inspectors reviewed performance-based problems involving selected in-scope structures systems and components (SSCs) to assess the effectiveness of the maintenance program The reviews focused on the following aspects when applicable
bull Proper maintenance rule scoping in accordance with 10 CFR 5065 bull Characterization of reliability issues bull Changing system and component unavailability bull 10 CFR 5065 (a)1) and (a)(2) classifications bull Identifying and addressing common cause failures bull Trending of system flow and temperature values bull Appropriateness of performance criteria for SSCs classified (a)(2) and bull Adequacy of goals and corrective actions for SSCs classified (a)(1)
The inspectors reviewed the applicable system health reports maintenance backlogs and Maintenance Rule basis documents The documents reviewed are listed in the Attachment The following structures systems and components were inspected
bull Residual Heat Removal (RHR) relief valves bull Core Spray CS and bull A recirculation pump motor generator set scoop tube positioner
Enclosure
10
b Findings
No findings were identified
1R13 Maintenance Risk Assessments and Emergent Work Control (7111113 -7 samples)
a Inspection Scope
The inspectors evaluated seven maintenance risk assessments for planned and emergent maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work The inspectors reviewed maintenance risk evaluations maintenance plans work schedules and control room logs to determine if concurrent or emergent maintenance or surveillance activities significantly increased the plant risk The inspectors reviewed risk assessments to determine if they were performed as required by 10 CFR 5065a)(4) and implemented in accordance with Entergys administrative procedures (AP) 0125 Plant Equipment and AP 0172 Work Schedule Risk Management - Online When emergent work was performed the inspectors observed activities to determine if plant risk was promptly reassessed and managed The documents reviewed are listed in the Attachment The following maintenance activities were inspected
bull On April 28 2010 increased risk due to removing the A station battery from service for planned maintenance
bull The week of May 32010 increased (yellow) risk due to refueling outage activities bull The week of May 10 2010 increased risk due to electrical bus outages to support
planned maintenance bull The week of May 17 2010 increased risk due to vessel drain down activities
installation of the reactor vessel head installation of the drywell vessel head and integrated leak rate testing to support outage activities
bull On June 8 2010 increased (yellow) risk due to primary containment being declared inoperable
bull On June 10 2010 high risk evolution associated with the CS system and bull On June 24 2010 high risk evolution associated with the A recirculation pump
motor~generator set scoop tube repair activities
b Findings
No findings were identified
1R15 Operability Evaluations (7111115 - 5 samples)
a Inspection Scope
The inspectors reviewed five operability evaluations associated with degraded or nonshyconforming conditions to assess the acceptability of the evaluations the use and control of applicable compensatory measures and compliance with Technical Specifications The inspectors reviewed and compared the technical adequacy of the evaluations with
Enclosure
1
11
the Technical Specifications Updated Final Safety Analysis Report associated design basis documents and Entergys procedure EN-OP-104 Operability Determinations The documents reviewed are listed in the Attachment The inspectors reviewed evaluations of the following degraded or non-conforming conditions
bull CR 2010-01686 pitting found on the RHRSW pump P-8-1C discharge piping bull CR 2010-01821 drywell dome gasket damage bull CR 2010-01944 SW strainer pitting below minimum wall thickness bull CR 2010-02285 S emergency diesel generator cylinder 10 temperature differs
from other cylinders by more than 300 degrees Fahrenheit and bull CR 2010-03202 GNF-2 (nuclear) fuel defect in the spacer springs at certain fuel pin
locations
b Findings
No findings were identified
1R18 Plant Modifications (7111118 - 3 samples)
Temporary Plant Modifications
a Inspection Scope (2 samples)
The inspectors reviewed two temporary modifications to ensure they did not adversely affect the availability reliability or functional capability of any risk-significant SSCs and assessed the adequacy of the 10 CFR 5059 evaluations The inspectors reviewed the engineering change package walked down the area interviewed various personnel and compared the installation and control of the modification to the procedural requirements The inspectors also verified that the installation was consistent with the modification documentation that the drawings and procedures were updated as applicable and that the post-installation testing was adequate The documents reviewed are listed in the Attachment The following two temporary modifications were reviewed
bull Engineering change (EC) 16583 temporary modification to provide power to 480VAC bus-710ads during a bus-7 outage and
bull EC 22659 temporary modification for the leak repair on the AOG two (2) inch pipe 2 CNPE-172A
b Findings
No findings were identified
Enclosure
2
12
Permanent Plant Modifications
a Inspection Scol2e (1 sample)
The inspectors reviewed EC16322 Replacement of Standby Fuel Pool Cooling Service Water Piping to ensure it did not adversely affect the availability reliability or functional capability of any risk-significant SSCs The inspectors reviewed the engineering change package and completed post-maintenance testing (PMT) package and observed the system in operation following the installation of the modification The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R19 Post-Maintenance Testing (7111119 - 10 samples)
a Inspection Scope
The inspectors reviewed ten post-maintenance test (PMT) activities on risk-significant systems The inspectors reviewed these activities to determine whether test acceptance criteria were clear and consistent with design basis documents When testing was directly observed the inspectors determined whether installed test equipment was appropriate and controlled and whether the test was performed in accordance with 10 CFR Part 50 Appendix B Criterion XI ~Test Control and applicable station procedures Upon completion the inspectors performed a walkdown to verify that equipment was returned to the proper alignment necessary to perform its safety function and evaluated whether conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the PMTs performed for the following maintenance activities
bull On April 9 2010 B normal fuel pool cooling pump seal replacement bull On April 21 2010 hydraulic control unit HCU-2235 valve (111 ) replacement bull On April 22 2010 A reactor water clean up pump seal replacement bull On May 32010 startup transformer (T-3-1B) refuel outage maintenance activities bull On May 2 2010 c service water pump discharge valve replacement
bull On May 16 2010 A EDG service water piping replacement bull On May 18 2010 post maintenance examination during RPV operational pressure
test following RPV relief valve replacement bull On June 8 2010 B RHR safety relief valve (SR-10-86B) replacement bull On June 10 2010 B core spray discharge piping safety relief valve (SR-14-20B)
replacement and bull On June 222010 B EDG fuel rack and governor maintenance
b Findings
No findings were identified
Enclosure
13
1 R20 Refueling and Other Outage Activities (7111120 -1 sample)
a Inspection Scope
The inspectors evaluated VY refueling outage (RFO) 28 activities to verify that Entergy considered risk when developing outage schedules adhered to administrative risk reduction methodologies for plant configuration control and adhered to their operating license TS requirements and approved procedures A list of documents reviewed is provided in the Attachment The following activities were inspected
bull Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 28 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions electrical power availability inventory control decay heat removal reactivity control and containment The daily risk assessments accounting for schedule changes and unplanned activities were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate
bull Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations As soon as practical following the shutdown the inspectors performed walkdown inspections of the primary containment
bull Electrical Power - The inspectors reviewed the status and configuration of safetyshyrelated buses throughout RFO 28 The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers the auxiliary transformer and the emergency diesel generators
bull Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (Le shutdown cooling) status on a daily basis Monitoring included daily reviews of residual heat removal system alignment reviews of spent fuel pool cooling system alignment and reviews of RCS time-to-boil calculations and results
bull Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan
bull Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling eVolutions including procedure place keeping communications with refueling floor personnel monitoring of source range nuclear instrumentation and monitoring of individual control rod positions
bull Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage The inspectors
Enclosure
14
performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
15
conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
2
TABLE OF CONTENTS
SUMMARY OF FINDINGS 111 bullbullbullbullbullbullbullbullbullbullbull3_
REPORT DETAILS bull bullbullbull 4
1 REACTOR SAFEfYbullbullbullbullbull a 4 1R01 Adverse Weather Protection 4 1R04 Equipment Alignment 5 1R05 Fire Protection 5 1R07 Heat Sink Performance 6 1R08 Inservice Inspection lSi) 7 1R11 Licensed Operator Requalification Program 9 1R12 Maintenance Effectiveness 9 1R13 Maintenance Risk Assessments and Emergent Work Control 10 1R15 Operability Evaluations 10 1R18 Plant Modifications 11 1R19 Post-Maintenance Testing 12 1R20 Refueling and Other Outage Activities 13 1R22 Surveillance Testing 16 1EP6 Drill Evaluation bullbullbullbullbullbullbullbull bullbullbullbullbullbullbullbull bull 16
2 RADIATION SAFEfY 17 2RS01 Radiological Hazard Assessment and Exposure Controls 17 2RS02 Occupational ALARA Planning and Controls 19 2RS04 Occupational Dose Assessment 19 2RS05 Radiation Monitoring Instruments 20
4 OTHER ACTIVITIES lOA] 23 4OA1 Performance Indicator (PI) Verification 23 40A2 Identification and Resolution of Problems 24 4OA5 Other Activities 26 40A6 Meetings including Exit 27
AITACHMENT SUPPLEMENTAL INFORMATION 27
KEY POINTS OF CONTACT Amiddot1
LIST OF ITEMS OPENED CLOSED AND DISCUSSED A-2
LIST OF DOCUMENTS REVIEWED A-2
LIST OF ACRONYMS I0~ t bullbullbull bullbull A11
Enclosure
3
SUMMARY OF FINDINGS
IR 050002712010003 04012010 - 06302010 Vermont Yankee Nuclear Power Station Refueling and Other Outage Activities
This report covered a three-month period of inspection by resident inspector staff and regionshybased inspectors One Green self-revealing finding which was determined to be a non-cited
I violation (NCV) was identified The significance of most findings is indicated by their coor (Green White Yellow Red) using Inspection Manua Chapter (IMC) 0609 Significance Determination Process The cross-cutting aspect for the finding was determined using IMC 0310 Components Within The Cross-Cutting Areas Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649 Reactor Oversight Process Revision 4 dated December 2006
Cornerstone Mitigating Systems
Green A self-revealing NCV of very low safety significance (Green) of Technical Specification (TS) 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECGS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages
The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining RCS inventory [H2(c)] (Section 1R20)
Enclosure
1
4
REPORT DETAILS
Summary of Plant Status
Vermont Yankee (VY) Nuclear Power Station began the inspection period operating at 100 percent power On April 24 2010 VY performed a planned power reduction to support the refueling and maintenance outage On May 26 2010 VY began power ascension after completion of the refueling outage however the unit automatically shut down at 70 percent power due to a recent modification design issue After correcting the modification issue VY began power ascension on May 29 2010 VY reached 100 percent power on June 1 2010 and remained at or near 100 percent power for the duration of the inspection period
1 REACTOR SAFETY
Cornerstones Initiating Events Mitigating Systems Barrier Integrity
1R01 Adverse Weather Protection (7111101-1 sample)
Grid Stability - Summer Readiness of Offsite and Alternate AC Power Systems
a Inspection Scoge
The inspectors performed a review of Entergys offsite and alternate AC power system readiness for adverse weather The inspectors reviewed Entergys plant features and procedures for operation and continued availability of their AC power systems to determine if they were appropriate The inspection focused on Entergys procedures for communication protocols with the transmission system operator (TSO) to determine if appropriate information would be exchanged when issues arise that could impact the offsite power system The inspectors also reviewed Entergys procedures to determine if they addressed necessary actions to be taken if notified by the TSO that they needed to transfer safety-related loads to the onsite power supply compensatory actions to be taken if it were not possible to predict grid conditions and required communications between Entergy and the TSO The inspectors interviewed personnel and performed a walkdown of the switchyard A list of documents reviewed is provided in the Attachment
b Findings
No findings were identified
Enclosure
1
5
1 R04 Equipment Alignment (7111104 - 4 samples)
Partial Equipment Alignment
a Inspection ScoQe
The inspectors performed four partial system walk downs to verify correct system alignment and to identify any discrepancies that could impact system operability Observed plant conditions were compared to the standby alignment of equipment specified in applicable piping and instrumentation drawings and operating procedures (OPs) The inspectors verified valve positions and the general condition of selected components Finally the inspectors evaluated material condition housekeeping and component labeling The documents reviewed are listed in the Attachment The following systems were inspected
bull A train residual heal removal service water (RHRSW) system during B train RHRSW system testing
bull A train residual heat removal (RHR) during B train RHR testing bull S train emergency diesel generator (EDG) system during A train EDG system
maintenance and bull Advanced off-gas system (AOG) after maintenance
b Findings
No findings were identified
1 R05 Fire Protection (7111105 - 7 samples)
Quarterly Inspection (7111105Q - 6 samples)
a Inspection ScoQe
The inspectors performed inspections of six fire areas based on a review of the Vermont Yankee Safe Shutdown Capability Analysis the Fire Hazards Analysis and the Individual Plant Examination for External Events (IPEEE) The inspectors reviewed Entergys fire protection program to determine the specified fire protection design features fire area boundaries and combustible loading requirements for the selected areas The inspectors verified consistent with applicable administrative procedures that combustibles and ignition sources were adequately controlled passive fire barriers manual fire-fighting equipment and detection and suppression equipment were appropriately maintained and compensatory measures for out-ot-service degraded or inoperable fire protection equipment were implemented in accordance with Entergys fire protection program The inspectors evaluated the fire protection program for conformance with the requirements of License Condition 3F The documents reviewed are listed in the Attachment The following fire areas were inspected
Enclosure
6
bull Fire area FA-8 elevation 252 A EDG bull Fire area FA-9 elevation 252 B EDG bull Fire zone FZ-7 elevation 228 condenser bay basement bull Fire zone FZ- elevation 248 condenser bay and ground floor bull Reactor building RB-4 elevation 252 reactor building south and bull Reactor building RB-4 elevation 213 high pressure coolant injection (HPCI)
b Findings
No findings were identified
2 Annual Inspection (7111105A - 1 sample)
The inspectors evaluated Entergys fire brigade performance by observing an announced fire brigade drill on April 2 2010 The inspectors verified that the number of individuals assigned to the fire brigade response met the minimum specified number each member donned the protective clothing tumout gear and self-contained breathing apparatus the fire brigade leader exhibited command of the fire brigade and had copies of the pre-fire plans the fire brigade arrived at the fire scene in a timely manner the licensees drill scenario was followed and acceptance criteria for the drill objectives were met and the licensee performed a post-drill critique to discuss any failures and weaknesses associated with the fire drill performance
b Findings
No findings were identified
1RO Heat Sink Performance (7111107 - 2 samples)
Annual Inspection
a Inspection Scope
The inspectors reviewed the results of the thermal performance tests of emergency diesel generator heat exchangers for DG-1-1A and DG-1-1B including the scavenging air cooler lubricating oil cooler and jacket water cooler for each diesel The inspectors discussed the test results with the system engineer and reviewed the completed surveillance data to determine whether test results met acceptance criteria which considered differences between test and design basis accident conditions The inspectors also reviewed Entergys corrective action program (CAP) to ensure significant heat exchanger performance problems were appropriately identified and documented and that corrective actions assigned if any were appropriate A list of documents reviewed is provided in the Attachment to this report
b Findings
No findings were identified
Enclosure
7
1 R08 Inservice Inspection (lSI) (7111108 -1 sample)
a Inspection Scope
The purpose of this inspection was to assess the effectiveness of the licensees lSI program for monitoring degradation of reactor pressure vessel internals reactor coolant system boundary risk significant piping system boundaries and the containment boundary The inspector assessed the inservice inspection activities using requirements and acceptance criteria for component examination specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI and applicable NRC Regulatory Requirements
The inspector selected a sample of nondestructive examination (NDE) activities to perform a documentation review of those NDE activities for compliance with the requirements of the ASME Boiler and Pressure Vessel Code Section XI The sample selection was based on the inspection procedure objectives sample availability and risk priority of those components and systems where degradation could result in a significant increase in risk of core damage The inspector verified by documentation review that test procedures and examiner qualifications had been reviewed and approved for use by the licensee The inspector reviewed a sample of these procedures and qualifications to determine they were current and in accordance with the ASME Code requirements In addition the inspector performed this review to determine that examiners had been trained and qualified for use of the performance demonstration initiative (PDI) manual ultrasonic test procedures The inspector selected a sample of Indication Notification Reports (INR) and Condition Reports (CRs) to evaluate the licensees effectiveness in the identification and resolution of relevant indications discovered during the observed lSI activities The inspectors documentation review of non-destructive testing included the following
bull Ultrasonic test (UT) manual PDI-UT of weld overlay applied to core spray nozzles N5A-SE and N5B-SE (Examination data was reviewed for comparative evaluation with the UT examinations performed in 1993 1998 and 2004)
bull Magnetic particle test (MT) of sweep weld RH17-S-349A to the RHR piping drawing G191172 lSI Isometric ISI-5920-9212
bull Visual examination (VT-3) of component supports on torus suppression chamber (NB-H1951-TSS10 drawings 5920-914461359131 and 9133) and
bull Liquid Penetrant test (PT) of nozzle to safe end dissimilar butt weld N10-SE drawing ISI-RPV-103 location elevation 269 ft azimuth 350 degrees
The inspector reviewed the visual inspection results of various in-vessel components including jet pump structural members leveling devices miscellaneous fasteners and tack welds made to secure components in place These observations were made to determine the examiner skill and to assess the test equipment performance examination technique and the quality of the inspection environment (water clarity) The inspector performed a review of in-vessel component non-conforming conditions identified in CRs 2010-020112010-02016 and INR-VYR 28-0528-0628-0728-08 28-09 28-10 and 28-11 Additional CRs listed in the Attachment to this report were
Enclosure
8
reviewed by the inspector to evaluate the characterization and disposition of relevant indications identified during the in-vessel visual inspection (IWI) of structural components within the vessel
The inspector selected three ASME Section XI repairreplacement plans-for review where welding on a safety related pressure boundary was performed The review was performed to evaluate qualification and control of the welding process specified in the work order Also to determine that the weld procedures and welders assigned to perform this special process are qualified in accordance with the requirements of ASME Section XI and that specified weld examinations are done in accordance with the ASME code requirements The three ASME Section XI repairreplacement work orders reviewed were
bull W0184964-06 was developed for welding of fitting to service water (SW) piping to facilitate installation of valve V70-164C This welding was of stainless steel base materials welded in line 34SW-18A by groove welding using weld procedure specification (WPS) SS-88-8 Rev 21 Welds 48 and 49 added to the service water system as shown on Weld Map 184964-10 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3
bull W0178169-01 was developed to replace fourteen inch 0 service water pump discharge valve V70-2D Welding was of carbon steel to carbon steel using WPS CS-11-A Rev 3 by groove welding of pipe to valve and pipe to pipe (3 welds) as shown on weld map 178169-1 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3 and
bull W0184964-06 was developed to replace pipe to socket weld 47 in service water system line 34 SW-18A using WPS BM-81-A Rev 2 stainless to carbon steel as shown on weld map 184964-10RO Applicable Code for acceptance was ASME Section XI lSI Class 3
Additionally the inspector performed a visual evaluation of the primary containment liner and additional structural members attached to the liner to assess the condition of the protective coating The evaluation included accessible locations on elevations 252 thru 266 The inspector performed this visual evaluation to determine the extent of any peeling blistering coating loss or other damage as a result of corrosion foreign material impact or lack of maintenance Condition Report CR-VTY-2010-02337 was initiated to describe the results of this visual examination
b Findings
No findings were identified
Enclosure
9
1R11 Licensed Operator Requalification Program (71111110 - 1 sample)
Ouarterly Inspection
a Insgection Scoge
The inspectors observed a simulator-based licensed operator requalification (LOR) exam on June 10 2010 The inspectors assessed the performance of risk significant operator actions including the use of emergency operating procedures The inspectors evaluated crew performance in the areas of clarity and formality of communications ability to take timely actions prioritization interpretation and verification of alarms procedure usage control board manipulations and command and control The inspectors also compared the simulator configuration with the actual control board configuration Finally the inspectors verified that evaluators were identifying and documenting crew performance problems The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R12 Maintenance Effectiveness (71111120 - 3 samples)
a Inspection Scope
The inspectors reviewed performance-based problems involving selected in-scope structures systems and components (SSCs) to assess the effectiveness of the maintenance program The reviews focused on the following aspects when applicable
bull Proper maintenance rule scoping in accordance with 10 CFR 5065 bull Characterization of reliability issues bull Changing system and component unavailability bull 10 CFR 5065 (a)1) and (a)(2) classifications bull Identifying and addressing common cause failures bull Trending of system flow and temperature values bull Appropriateness of performance criteria for SSCs classified (a)(2) and bull Adequacy of goals and corrective actions for SSCs classified (a)(1)
The inspectors reviewed the applicable system health reports maintenance backlogs and Maintenance Rule basis documents The documents reviewed are listed in the Attachment The following structures systems and components were inspected
bull Residual Heat Removal (RHR) relief valves bull Core Spray CS and bull A recirculation pump motor generator set scoop tube positioner
Enclosure
10
b Findings
No findings were identified
1R13 Maintenance Risk Assessments and Emergent Work Control (7111113 -7 samples)
a Inspection Scope
The inspectors evaluated seven maintenance risk assessments for planned and emergent maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work The inspectors reviewed maintenance risk evaluations maintenance plans work schedules and control room logs to determine if concurrent or emergent maintenance or surveillance activities significantly increased the plant risk The inspectors reviewed risk assessments to determine if they were performed as required by 10 CFR 5065a)(4) and implemented in accordance with Entergys administrative procedures (AP) 0125 Plant Equipment and AP 0172 Work Schedule Risk Management - Online When emergent work was performed the inspectors observed activities to determine if plant risk was promptly reassessed and managed The documents reviewed are listed in the Attachment The following maintenance activities were inspected
bull On April 28 2010 increased risk due to removing the A station battery from service for planned maintenance
bull The week of May 32010 increased (yellow) risk due to refueling outage activities bull The week of May 10 2010 increased risk due to electrical bus outages to support
planned maintenance bull The week of May 17 2010 increased risk due to vessel drain down activities
installation of the reactor vessel head installation of the drywell vessel head and integrated leak rate testing to support outage activities
bull On June 8 2010 increased (yellow) risk due to primary containment being declared inoperable
bull On June 10 2010 high risk evolution associated with the CS system and bull On June 24 2010 high risk evolution associated with the A recirculation pump
motor~generator set scoop tube repair activities
b Findings
No findings were identified
1R15 Operability Evaluations (7111115 - 5 samples)
a Inspection Scope
The inspectors reviewed five operability evaluations associated with degraded or nonshyconforming conditions to assess the acceptability of the evaluations the use and control of applicable compensatory measures and compliance with Technical Specifications The inspectors reviewed and compared the technical adequacy of the evaluations with
Enclosure
1
11
the Technical Specifications Updated Final Safety Analysis Report associated design basis documents and Entergys procedure EN-OP-104 Operability Determinations The documents reviewed are listed in the Attachment The inspectors reviewed evaluations of the following degraded or non-conforming conditions
bull CR 2010-01686 pitting found on the RHRSW pump P-8-1C discharge piping bull CR 2010-01821 drywell dome gasket damage bull CR 2010-01944 SW strainer pitting below minimum wall thickness bull CR 2010-02285 S emergency diesel generator cylinder 10 temperature differs
from other cylinders by more than 300 degrees Fahrenheit and bull CR 2010-03202 GNF-2 (nuclear) fuel defect in the spacer springs at certain fuel pin
locations
b Findings
No findings were identified
1R18 Plant Modifications (7111118 - 3 samples)
Temporary Plant Modifications
a Inspection Scope (2 samples)
The inspectors reviewed two temporary modifications to ensure they did not adversely affect the availability reliability or functional capability of any risk-significant SSCs and assessed the adequacy of the 10 CFR 5059 evaluations The inspectors reviewed the engineering change package walked down the area interviewed various personnel and compared the installation and control of the modification to the procedural requirements The inspectors also verified that the installation was consistent with the modification documentation that the drawings and procedures were updated as applicable and that the post-installation testing was adequate The documents reviewed are listed in the Attachment The following two temporary modifications were reviewed
bull Engineering change (EC) 16583 temporary modification to provide power to 480VAC bus-710ads during a bus-7 outage and
bull EC 22659 temporary modification for the leak repair on the AOG two (2) inch pipe 2 CNPE-172A
b Findings
No findings were identified
Enclosure
2
12
Permanent Plant Modifications
a Inspection Scol2e (1 sample)
The inspectors reviewed EC16322 Replacement of Standby Fuel Pool Cooling Service Water Piping to ensure it did not adversely affect the availability reliability or functional capability of any risk-significant SSCs The inspectors reviewed the engineering change package and completed post-maintenance testing (PMT) package and observed the system in operation following the installation of the modification The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R19 Post-Maintenance Testing (7111119 - 10 samples)
a Inspection Scope
The inspectors reviewed ten post-maintenance test (PMT) activities on risk-significant systems The inspectors reviewed these activities to determine whether test acceptance criteria were clear and consistent with design basis documents When testing was directly observed the inspectors determined whether installed test equipment was appropriate and controlled and whether the test was performed in accordance with 10 CFR Part 50 Appendix B Criterion XI ~Test Control and applicable station procedures Upon completion the inspectors performed a walkdown to verify that equipment was returned to the proper alignment necessary to perform its safety function and evaluated whether conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the PMTs performed for the following maintenance activities
bull On April 9 2010 B normal fuel pool cooling pump seal replacement bull On April 21 2010 hydraulic control unit HCU-2235 valve (111 ) replacement bull On April 22 2010 A reactor water clean up pump seal replacement bull On May 32010 startup transformer (T-3-1B) refuel outage maintenance activities bull On May 2 2010 c service water pump discharge valve replacement
bull On May 16 2010 A EDG service water piping replacement bull On May 18 2010 post maintenance examination during RPV operational pressure
test following RPV relief valve replacement bull On June 8 2010 B RHR safety relief valve (SR-10-86B) replacement bull On June 10 2010 B core spray discharge piping safety relief valve (SR-14-20B)
replacement and bull On June 222010 B EDG fuel rack and governor maintenance
b Findings
No findings were identified
Enclosure
13
1 R20 Refueling and Other Outage Activities (7111120 -1 sample)
a Inspection Scope
The inspectors evaluated VY refueling outage (RFO) 28 activities to verify that Entergy considered risk when developing outage schedules adhered to administrative risk reduction methodologies for plant configuration control and adhered to their operating license TS requirements and approved procedures A list of documents reviewed is provided in the Attachment The following activities were inspected
bull Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 28 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions electrical power availability inventory control decay heat removal reactivity control and containment The daily risk assessments accounting for schedule changes and unplanned activities were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate
bull Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations As soon as practical following the shutdown the inspectors performed walkdown inspections of the primary containment
bull Electrical Power - The inspectors reviewed the status and configuration of safetyshyrelated buses throughout RFO 28 The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers the auxiliary transformer and the emergency diesel generators
bull Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (Le shutdown cooling) status on a daily basis Monitoring included daily reviews of residual heat removal system alignment reviews of spent fuel pool cooling system alignment and reviews of RCS time-to-boil calculations and results
bull Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan
bull Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling eVolutions including procedure place keeping communications with refueling floor personnel monitoring of source range nuclear instrumentation and monitoring of individual control rod positions
bull Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage The inspectors
Enclosure
14
performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
15
conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
3
SUMMARY OF FINDINGS
IR 050002712010003 04012010 - 06302010 Vermont Yankee Nuclear Power Station Refueling and Other Outage Activities
This report covered a three-month period of inspection by resident inspector staff and regionshybased inspectors One Green self-revealing finding which was determined to be a non-cited
I violation (NCV) was identified The significance of most findings is indicated by their coor (Green White Yellow Red) using Inspection Manua Chapter (IMC) 0609 Significance Determination Process The cross-cutting aspect for the finding was determined using IMC 0310 Components Within The Cross-Cutting Areas Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649 Reactor Oversight Process Revision 4 dated December 2006
Cornerstone Mitigating Systems
Green A self-revealing NCV of very low safety significance (Green) of Technical Specification (TS) 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECGS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages
The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining RCS inventory [H2(c)] (Section 1R20)
Enclosure
1
4
REPORT DETAILS
Summary of Plant Status
Vermont Yankee (VY) Nuclear Power Station began the inspection period operating at 100 percent power On April 24 2010 VY performed a planned power reduction to support the refueling and maintenance outage On May 26 2010 VY began power ascension after completion of the refueling outage however the unit automatically shut down at 70 percent power due to a recent modification design issue After correcting the modification issue VY began power ascension on May 29 2010 VY reached 100 percent power on June 1 2010 and remained at or near 100 percent power for the duration of the inspection period
1 REACTOR SAFETY
Cornerstones Initiating Events Mitigating Systems Barrier Integrity
1R01 Adverse Weather Protection (7111101-1 sample)
Grid Stability - Summer Readiness of Offsite and Alternate AC Power Systems
a Inspection Scoge
The inspectors performed a review of Entergys offsite and alternate AC power system readiness for adverse weather The inspectors reviewed Entergys plant features and procedures for operation and continued availability of their AC power systems to determine if they were appropriate The inspection focused on Entergys procedures for communication protocols with the transmission system operator (TSO) to determine if appropriate information would be exchanged when issues arise that could impact the offsite power system The inspectors also reviewed Entergys procedures to determine if they addressed necessary actions to be taken if notified by the TSO that they needed to transfer safety-related loads to the onsite power supply compensatory actions to be taken if it were not possible to predict grid conditions and required communications between Entergy and the TSO The inspectors interviewed personnel and performed a walkdown of the switchyard A list of documents reviewed is provided in the Attachment
b Findings
No findings were identified
Enclosure
1
5
1 R04 Equipment Alignment (7111104 - 4 samples)
Partial Equipment Alignment
a Inspection ScoQe
The inspectors performed four partial system walk downs to verify correct system alignment and to identify any discrepancies that could impact system operability Observed plant conditions were compared to the standby alignment of equipment specified in applicable piping and instrumentation drawings and operating procedures (OPs) The inspectors verified valve positions and the general condition of selected components Finally the inspectors evaluated material condition housekeeping and component labeling The documents reviewed are listed in the Attachment The following systems were inspected
bull A train residual heal removal service water (RHRSW) system during B train RHRSW system testing
bull A train residual heat removal (RHR) during B train RHR testing bull S train emergency diesel generator (EDG) system during A train EDG system
maintenance and bull Advanced off-gas system (AOG) after maintenance
b Findings
No findings were identified
1 R05 Fire Protection (7111105 - 7 samples)
Quarterly Inspection (7111105Q - 6 samples)
a Inspection ScoQe
The inspectors performed inspections of six fire areas based on a review of the Vermont Yankee Safe Shutdown Capability Analysis the Fire Hazards Analysis and the Individual Plant Examination for External Events (IPEEE) The inspectors reviewed Entergys fire protection program to determine the specified fire protection design features fire area boundaries and combustible loading requirements for the selected areas The inspectors verified consistent with applicable administrative procedures that combustibles and ignition sources were adequately controlled passive fire barriers manual fire-fighting equipment and detection and suppression equipment were appropriately maintained and compensatory measures for out-ot-service degraded or inoperable fire protection equipment were implemented in accordance with Entergys fire protection program The inspectors evaluated the fire protection program for conformance with the requirements of License Condition 3F The documents reviewed are listed in the Attachment The following fire areas were inspected
Enclosure
6
bull Fire area FA-8 elevation 252 A EDG bull Fire area FA-9 elevation 252 B EDG bull Fire zone FZ-7 elevation 228 condenser bay basement bull Fire zone FZ- elevation 248 condenser bay and ground floor bull Reactor building RB-4 elevation 252 reactor building south and bull Reactor building RB-4 elevation 213 high pressure coolant injection (HPCI)
b Findings
No findings were identified
2 Annual Inspection (7111105A - 1 sample)
The inspectors evaluated Entergys fire brigade performance by observing an announced fire brigade drill on April 2 2010 The inspectors verified that the number of individuals assigned to the fire brigade response met the minimum specified number each member donned the protective clothing tumout gear and self-contained breathing apparatus the fire brigade leader exhibited command of the fire brigade and had copies of the pre-fire plans the fire brigade arrived at the fire scene in a timely manner the licensees drill scenario was followed and acceptance criteria for the drill objectives were met and the licensee performed a post-drill critique to discuss any failures and weaknesses associated with the fire drill performance
b Findings
No findings were identified
1RO Heat Sink Performance (7111107 - 2 samples)
Annual Inspection
a Inspection Scope
The inspectors reviewed the results of the thermal performance tests of emergency diesel generator heat exchangers for DG-1-1A and DG-1-1B including the scavenging air cooler lubricating oil cooler and jacket water cooler for each diesel The inspectors discussed the test results with the system engineer and reviewed the completed surveillance data to determine whether test results met acceptance criteria which considered differences between test and design basis accident conditions The inspectors also reviewed Entergys corrective action program (CAP) to ensure significant heat exchanger performance problems were appropriately identified and documented and that corrective actions assigned if any were appropriate A list of documents reviewed is provided in the Attachment to this report
b Findings
No findings were identified
Enclosure
7
1 R08 Inservice Inspection (lSI) (7111108 -1 sample)
a Inspection Scope
The purpose of this inspection was to assess the effectiveness of the licensees lSI program for monitoring degradation of reactor pressure vessel internals reactor coolant system boundary risk significant piping system boundaries and the containment boundary The inspector assessed the inservice inspection activities using requirements and acceptance criteria for component examination specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI and applicable NRC Regulatory Requirements
The inspector selected a sample of nondestructive examination (NDE) activities to perform a documentation review of those NDE activities for compliance with the requirements of the ASME Boiler and Pressure Vessel Code Section XI The sample selection was based on the inspection procedure objectives sample availability and risk priority of those components and systems where degradation could result in a significant increase in risk of core damage The inspector verified by documentation review that test procedures and examiner qualifications had been reviewed and approved for use by the licensee The inspector reviewed a sample of these procedures and qualifications to determine they were current and in accordance with the ASME Code requirements In addition the inspector performed this review to determine that examiners had been trained and qualified for use of the performance demonstration initiative (PDI) manual ultrasonic test procedures The inspector selected a sample of Indication Notification Reports (INR) and Condition Reports (CRs) to evaluate the licensees effectiveness in the identification and resolution of relevant indications discovered during the observed lSI activities The inspectors documentation review of non-destructive testing included the following
bull Ultrasonic test (UT) manual PDI-UT of weld overlay applied to core spray nozzles N5A-SE and N5B-SE (Examination data was reviewed for comparative evaluation with the UT examinations performed in 1993 1998 and 2004)
bull Magnetic particle test (MT) of sweep weld RH17-S-349A to the RHR piping drawing G191172 lSI Isometric ISI-5920-9212
bull Visual examination (VT-3) of component supports on torus suppression chamber (NB-H1951-TSS10 drawings 5920-914461359131 and 9133) and
bull Liquid Penetrant test (PT) of nozzle to safe end dissimilar butt weld N10-SE drawing ISI-RPV-103 location elevation 269 ft azimuth 350 degrees
The inspector reviewed the visual inspection results of various in-vessel components including jet pump structural members leveling devices miscellaneous fasteners and tack welds made to secure components in place These observations were made to determine the examiner skill and to assess the test equipment performance examination technique and the quality of the inspection environment (water clarity) The inspector performed a review of in-vessel component non-conforming conditions identified in CRs 2010-020112010-02016 and INR-VYR 28-0528-0628-0728-08 28-09 28-10 and 28-11 Additional CRs listed in the Attachment to this report were
Enclosure
8
reviewed by the inspector to evaluate the characterization and disposition of relevant indications identified during the in-vessel visual inspection (IWI) of structural components within the vessel
The inspector selected three ASME Section XI repairreplacement plans-for review where welding on a safety related pressure boundary was performed The review was performed to evaluate qualification and control of the welding process specified in the work order Also to determine that the weld procedures and welders assigned to perform this special process are qualified in accordance with the requirements of ASME Section XI and that specified weld examinations are done in accordance with the ASME code requirements The three ASME Section XI repairreplacement work orders reviewed were
bull W0184964-06 was developed for welding of fitting to service water (SW) piping to facilitate installation of valve V70-164C This welding was of stainless steel base materials welded in line 34SW-18A by groove welding using weld procedure specification (WPS) SS-88-8 Rev 21 Welds 48 and 49 added to the service water system as shown on Weld Map 184964-10 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3
bull W0178169-01 was developed to replace fourteen inch 0 service water pump discharge valve V70-2D Welding was of carbon steel to carbon steel using WPS CS-11-A Rev 3 by groove welding of pipe to valve and pipe to pipe (3 welds) as shown on weld map 178169-1 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3 and
bull W0184964-06 was developed to replace pipe to socket weld 47 in service water system line 34 SW-18A using WPS BM-81-A Rev 2 stainless to carbon steel as shown on weld map 184964-10RO Applicable Code for acceptance was ASME Section XI lSI Class 3
Additionally the inspector performed a visual evaluation of the primary containment liner and additional structural members attached to the liner to assess the condition of the protective coating The evaluation included accessible locations on elevations 252 thru 266 The inspector performed this visual evaluation to determine the extent of any peeling blistering coating loss or other damage as a result of corrosion foreign material impact or lack of maintenance Condition Report CR-VTY-2010-02337 was initiated to describe the results of this visual examination
b Findings
No findings were identified
Enclosure
9
1R11 Licensed Operator Requalification Program (71111110 - 1 sample)
Ouarterly Inspection
a Insgection Scoge
The inspectors observed a simulator-based licensed operator requalification (LOR) exam on June 10 2010 The inspectors assessed the performance of risk significant operator actions including the use of emergency operating procedures The inspectors evaluated crew performance in the areas of clarity and formality of communications ability to take timely actions prioritization interpretation and verification of alarms procedure usage control board manipulations and command and control The inspectors also compared the simulator configuration with the actual control board configuration Finally the inspectors verified that evaluators were identifying and documenting crew performance problems The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R12 Maintenance Effectiveness (71111120 - 3 samples)
a Inspection Scope
The inspectors reviewed performance-based problems involving selected in-scope structures systems and components (SSCs) to assess the effectiveness of the maintenance program The reviews focused on the following aspects when applicable
bull Proper maintenance rule scoping in accordance with 10 CFR 5065 bull Characterization of reliability issues bull Changing system and component unavailability bull 10 CFR 5065 (a)1) and (a)(2) classifications bull Identifying and addressing common cause failures bull Trending of system flow and temperature values bull Appropriateness of performance criteria for SSCs classified (a)(2) and bull Adequacy of goals and corrective actions for SSCs classified (a)(1)
The inspectors reviewed the applicable system health reports maintenance backlogs and Maintenance Rule basis documents The documents reviewed are listed in the Attachment The following structures systems and components were inspected
bull Residual Heat Removal (RHR) relief valves bull Core Spray CS and bull A recirculation pump motor generator set scoop tube positioner
Enclosure
10
b Findings
No findings were identified
1R13 Maintenance Risk Assessments and Emergent Work Control (7111113 -7 samples)
a Inspection Scope
The inspectors evaluated seven maintenance risk assessments for planned and emergent maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work The inspectors reviewed maintenance risk evaluations maintenance plans work schedules and control room logs to determine if concurrent or emergent maintenance or surveillance activities significantly increased the plant risk The inspectors reviewed risk assessments to determine if they were performed as required by 10 CFR 5065a)(4) and implemented in accordance with Entergys administrative procedures (AP) 0125 Plant Equipment and AP 0172 Work Schedule Risk Management - Online When emergent work was performed the inspectors observed activities to determine if plant risk was promptly reassessed and managed The documents reviewed are listed in the Attachment The following maintenance activities were inspected
bull On April 28 2010 increased risk due to removing the A station battery from service for planned maintenance
bull The week of May 32010 increased (yellow) risk due to refueling outage activities bull The week of May 10 2010 increased risk due to electrical bus outages to support
planned maintenance bull The week of May 17 2010 increased risk due to vessel drain down activities
installation of the reactor vessel head installation of the drywell vessel head and integrated leak rate testing to support outage activities
bull On June 8 2010 increased (yellow) risk due to primary containment being declared inoperable
bull On June 10 2010 high risk evolution associated with the CS system and bull On June 24 2010 high risk evolution associated with the A recirculation pump
motor~generator set scoop tube repair activities
b Findings
No findings were identified
1R15 Operability Evaluations (7111115 - 5 samples)
a Inspection Scope
The inspectors reviewed five operability evaluations associated with degraded or nonshyconforming conditions to assess the acceptability of the evaluations the use and control of applicable compensatory measures and compliance with Technical Specifications The inspectors reviewed and compared the technical adequacy of the evaluations with
Enclosure
1
11
the Technical Specifications Updated Final Safety Analysis Report associated design basis documents and Entergys procedure EN-OP-104 Operability Determinations The documents reviewed are listed in the Attachment The inspectors reviewed evaluations of the following degraded or non-conforming conditions
bull CR 2010-01686 pitting found on the RHRSW pump P-8-1C discharge piping bull CR 2010-01821 drywell dome gasket damage bull CR 2010-01944 SW strainer pitting below minimum wall thickness bull CR 2010-02285 S emergency diesel generator cylinder 10 temperature differs
from other cylinders by more than 300 degrees Fahrenheit and bull CR 2010-03202 GNF-2 (nuclear) fuel defect in the spacer springs at certain fuel pin
locations
b Findings
No findings were identified
1R18 Plant Modifications (7111118 - 3 samples)
Temporary Plant Modifications
a Inspection Scope (2 samples)
The inspectors reviewed two temporary modifications to ensure they did not adversely affect the availability reliability or functional capability of any risk-significant SSCs and assessed the adequacy of the 10 CFR 5059 evaluations The inspectors reviewed the engineering change package walked down the area interviewed various personnel and compared the installation and control of the modification to the procedural requirements The inspectors also verified that the installation was consistent with the modification documentation that the drawings and procedures were updated as applicable and that the post-installation testing was adequate The documents reviewed are listed in the Attachment The following two temporary modifications were reviewed
bull Engineering change (EC) 16583 temporary modification to provide power to 480VAC bus-710ads during a bus-7 outage and
bull EC 22659 temporary modification for the leak repair on the AOG two (2) inch pipe 2 CNPE-172A
b Findings
No findings were identified
Enclosure
2
12
Permanent Plant Modifications
a Inspection Scol2e (1 sample)
The inspectors reviewed EC16322 Replacement of Standby Fuel Pool Cooling Service Water Piping to ensure it did not adversely affect the availability reliability or functional capability of any risk-significant SSCs The inspectors reviewed the engineering change package and completed post-maintenance testing (PMT) package and observed the system in operation following the installation of the modification The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R19 Post-Maintenance Testing (7111119 - 10 samples)
a Inspection Scope
The inspectors reviewed ten post-maintenance test (PMT) activities on risk-significant systems The inspectors reviewed these activities to determine whether test acceptance criteria were clear and consistent with design basis documents When testing was directly observed the inspectors determined whether installed test equipment was appropriate and controlled and whether the test was performed in accordance with 10 CFR Part 50 Appendix B Criterion XI ~Test Control and applicable station procedures Upon completion the inspectors performed a walkdown to verify that equipment was returned to the proper alignment necessary to perform its safety function and evaluated whether conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the PMTs performed for the following maintenance activities
bull On April 9 2010 B normal fuel pool cooling pump seal replacement bull On April 21 2010 hydraulic control unit HCU-2235 valve (111 ) replacement bull On April 22 2010 A reactor water clean up pump seal replacement bull On May 32010 startup transformer (T-3-1B) refuel outage maintenance activities bull On May 2 2010 c service water pump discharge valve replacement
bull On May 16 2010 A EDG service water piping replacement bull On May 18 2010 post maintenance examination during RPV operational pressure
test following RPV relief valve replacement bull On June 8 2010 B RHR safety relief valve (SR-10-86B) replacement bull On June 10 2010 B core spray discharge piping safety relief valve (SR-14-20B)
replacement and bull On June 222010 B EDG fuel rack and governor maintenance
b Findings
No findings were identified
Enclosure
13
1 R20 Refueling and Other Outage Activities (7111120 -1 sample)
a Inspection Scope
The inspectors evaluated VY refueling outage (RFO) 28 activities to verify that Entergy considered risk when developing outage schedules adhered to administrative risk reduction methodologies for plant configuration control and adhered to their operating license TS requirements and approved procedures A list of documents reviewed is provided in the Attachment The following activities were inspected
bull Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 28 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions electrical power availability inventory control decay heat removal reactivity control and containment The daily risk assessments accounting for schedule changes and unplanned activities were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate
bull Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations As soon as practical following the shutdown the inspectors performed walkdown inspections of the primary containment
bull Electrical Power - The inspectors reviewed the status and configuration of safetyshyrelated buses throughout RFO 28 The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers the auxiliary transformer and the emergency diesel generators
bull Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (Le shutdown cooling) status on a daily basis Monitoring included daily reviews of residual heat removal system alignment reviews of spent fuel pool cooling system alignment and reviews of RCS time-to-boil calculations and results
bull Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan
bull Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling eVolutions including procedure place keeping communications with refueling floor personnel monitoring of source range nuclear instrumentation and monitoring of individual control rod positions
bull Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage The inspectors
Enclosure
14
performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
15
conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
1
4
REPORT DETAILS
Summary of Plant Status
Vermont Yankee (VY) Nuclear Power Station began the inspection period operating at 100 percent power On April 24 2010 VY performed a planned power reduction to support the refueling and maintenance outage On May 26 2010 VY began power ascension after completion of the refueling outage however the unit automatically shut down at 70 percent power due to a recent modification design issue After correcting the modification issue VY began power ascension on May 29 2010 VY reached 100 percent power on June 1 2010 and remained at or near 100 percent power for the duration of the inspection period
1 REACTOR SAFETY
Cornerstones Initiating Events Mitigating Systems Barrier Integrity
1R01 Adverse Weather Protection (7111101-1 sample)
Grid Stability - Summer Readiness of Offsite and Alternate AC Power Systems
a Inspection Scoge
The inspectors performed a review of Entergys offsite and alternate AC power system readiness for adverse weather The inspectors reviewed Entergys plant features and procedures for operation and continued availability of their AC power systems to determine if they were appropriate The inspection focused on Entergys procedures for communication protocols with the transmission system operator (TSO) to determine if appropriate information would be exchanged when issues arise that could impact the offsite power system The inspectors also reviewed Entergys procedures to determine if they addressed necessary actions to be taken if notified by the TSO that they needed to transfer safety-related loads to the onsite power supply compensatory actions to be taken if it were not possible to predict grid conditions and required communications between Entergy and the TSO The inspectors interviewed personnel and performed a walkdown of the switchyard A list of documents reviewed is provided in the Attachment
b Findings
No findings were identified
Enclosure
1
5
1 R04 Equipment Alignment (7111104 - 4 samples)
Partial Equipment Alignment
a Inspection ScoQe
The inspectors performed four partial system walk downs to verify correct system alignment and to identify any discrepancies that could impact system operability Observed plant conditions were compared to the standby alignment of equipment specified in applicable piping and instrumentation drawings and operating procedures (OPs) The inspectors verified valve positions and the general condition of selected components Finally the inspectors evaluated material condition housekeeping and component labeling The documents reviewed are listed in the Attachment The following systems were inspected
bull A train residual heal removal service water (RHRSW) system during B train RHRSW system testing
bull A train residual heat removal (RHR) during B train RHR testing bull S train emergency diesel generator (EDG) system during A train EDG system
maintenance and bull Advanced off-gas system (AOG) after maintenance
b Findings
No findings were identified
1 R05 Fire Protection (7111105 - 7 samples)
Quarterly Inspection (7111105Q - 6 samples)
a Inspection ScoQe
The inspectors performed inspections of six fire areas based on a review of the Vermont Yankee Safe Shutdown Capability Analysis the Fire Hazards Analysis and the Individual Plant Examination for External Events (IPEEE) The inspectors reviewed Entergys fire protection program to determine the specified fire protection design features fire area boundaries and combustible loading requirements for the selected areas The inspectors verified consistent with applicable administrative procedures that combustibles and ignition sources were adequately controlled passive fire barriers manual fire-fighting equipment and detection and suppression equipment were appropriately maintained and compensatory measures for out-ot-service degraded or inoperable fire protection equipment were implemented in accordance with Entergys fire protection program The inspectors evaluated the fire protection program for conformance with the requirements of License Condition 3F The documents reviewed are listed in the Attachment The following fire areas were inspected
Enclosure
6
bull Fire area FA-8 elevation 252 A EDG bull Fire area FA-9 elevation 252 B EDG bull Fire zone FZ-7 elevation 228 condenser bay basement bull Fire zone FZ- elevation 248 condenser bay and ground floor bull Reactor building RB-4 elevation 252 reactor building south and bull Reactor building RB-4 elevation 213 high pressure coolant injection (HPCI)
b Findings
No findings were identified
2 Annual Inspection (7111105A - 1 sample)
The inspectors evaluated Entergys fire brigade performance by observing an announced fire brigade drill on April 2 2010 The inspectors verified that the number of individuals assigned to the fire brigade response met the minimum specified number each member donned the protective clothing tumout gear and self-contained breathing apparatus the fire brigade leader exhibited command of the fire brigade and had copies of the pre-fire plans the fire brigade arrived at the fire scene in a timely manner the licensees drill scenario was followed and acceptance criteria for the drill objectives were met and the licensee performed a post-drill critique to discuss any failures and weaknesses associated with the fire drill performance
b Findings
No findings were identified
1RO Heat Sink Performance (7111107 - 2 samples)
Annual Inspection
a Inspection Scope
The inspectors reviewed the results of the thermal performance tests of emergency diesel generator heat exchangers for DG-1-1A and DG-1-1B including the scavenging air cooler lubricating oil cooler and jacket water cooler for each diesel The inspectors discussed the test results with the system engineer and reviewed the completed surveillance data to determine whether test results met acceptance criteria which considered differences between test and design basis accident conditions The inspectors also reviewed Entergys corrective action program (CAP) to ensure significant heat exchanger performance problems were appropriately identified and documented and that corrective actions assigned if any were appropriate A list of documents reviewed is provided in the Attachment to this report
b Findings
No findings were identified
Enclosure
7
1 R08 Inservice Inspection (lSI) (7111108 -1 sample)
a Inspection Scope
The purpose of this inspection was to assess the effectiveness of the licensees lSI program for monitoring degradation of reactor pressure vessel internals reactor coolant system boundary risk significant piping system boundaries and the containment boundary The inspector assessed the inservice inspection activities using requirements and acceptance criteria for component examination specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI and applicable NRC Regulatory Requirements
The inspector selected a sample of nondestructive examination (NDE) activities to perform a documentation review of those NDE activities for compliance with the requirements of the ASME Boiler and Pressure Vessel Code Section XI The sample selection was based on the inspection procedure objectives sample availability and risk priority of those components and systems where degradation could result in a significant increase in risk of core damage The inspector verified by documentation review that test procedures and examiner qualifications had been reviewed and approved for use by the licensee The inspector reviewed a sample of these procedures and qualifications to determine they were current and in accordance with the ASME Code requirements In addition the inspector performed this review to determine that examiners had been trained and qualified for use of the performance demonstration initiative (PDI) manual ultrasonic test procedures The inspector selected a sample of Indication Notification Reports (INR) and Condition Reports (CRs) to evaluate the licensees effectiveness in the identification and resolution of relevant indications discovered during the observed lSI activities The inspectors documentation review of non-destructive testing included the following
bull Ultrasonic test (UT) manual PDI-UT of weld overlay applied to core spray nozzles N5A-SE and N5B-SE (Examination data was reviewed for comparative evaluation with the UT examinations performed in 1993 1998 and 2004)
bull Magnetic particle test (MT) of sweep weld RH17-S-349A to the RHR piping drawing G191172 lSI Isometric ISI-5920-9212
bull Visual examination (VT-3) of component supports on torus suppression chamber (NB-H1951-TSS10 drawings 5920-914461359131 and 9133) and
bull Liquid Penetrant test (PT) of nozzle to safe end dissimilar butt weld N10-SE drawing ISI-RPV-103 location elevation 269 ft azimuth 350 degrees
The inspector reviewed the visual inspection results of various in-vessel components including jet pump structural members leveling devices miscellaneous fasteners and tack welds made to secure components in place These observations were made to determine the examiner skill and to assess the test equipment performance examination technique and the quality of the inspection environment (water clarity) The inspector performed a review of in-vessel component non-conforming conditions identified in CRs 2010-020112010-02016 and INR-VYR 28-0528-0628-0728-08 28-09 28-10 and 28-11 Additional CRs listed in the Attachment to this report were
Enclosure
8
reviewed by the inspector to evaluate the characterization and disposition of relevant indications identified during the in-vessel visual inspection (IWI) of structural components within the vessel
The inspector selected three ASME Section XI repairreplacement plans-for review where welding on a safety related pressure boundary was performed The review was performed to evaluate qualification and control of the welding process specified in the work order Also to determine that the weld procedures and welders assigned to perform this special process are qualified in accordance with the requirements of ASME Section XI and that specified weld examinations are done in accordance with the ASME code requirements The three ASME Section XI repairreplacement work orders reviewed were
bull W0184964-06 was developed for welding of fitting to service water (SW) piping to facilitate installation of valve V70-164C This welding was of stainless steel base materials welded in line 34SW-18A by groove welding using weld procedure specification (WPS) SS-88-8 Rev 21 Welds 48 and 49 added to the service water system as shown on Weld Map 184964-10 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3
bull W0178169-01 was developed to replace fourteen inch 0 service water pump discharge valve V70-2D Welding was of carbon steel to carbon steel using WPS CS-11-A Rev 3 by groove welding of pipe to valve and pipe to pipe (3 welds) as shown on weld map 178169-1 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3 and
bull W0184964-06 was developed to replace pipe to socket weld 47 in service water system line 34 SW-18A using WPS BM-81-A Rev 2 stainless to carbon steel as shown on weld map 184964-10RO Applicable Code for acceptance was ASME Section XI lSI Class 3
Additionally the inspector performed a visual evaluation of the primary containment liner and additional structural members attached to the liner to assess the condition of the protective coating The evaluation included accessible locations on elevations 252 thru 266 The inspector performed this visual evaluation to determine the extent of any peeling blistering coating loss or other damage as a result of corrosion foreign material impact or lack of maintenance Condition Report CR-VTY-2010-02337 was initiated to describe the results of this visual examination
b Findings
No findings were identified
Enclosure
9
1R11 Licensed Operator Requalification Program (71111110 - 1 sample)
Ouarterly Inspection
a Insgection Scoge
The inspectors observed a simulator-based licensed operator requalification (LOR) exam on June 10 2010 The inspectors assessed the performance of risk significant operator actions including the use of emergency operating procedures The inspectors evaluated crew performance in the areas of clarity and formality of communications ability to take timely actions prioritization interpretation and verification of alarms procedure usage control board manipulations and command and control The inspectors also compared the simulator configuration with the actual control board configuration Finally the inspectors verified that evaluators were identifying and documenting crew performance problems The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R12 Maintenance Effectiveness (71111120 - 3 samples)
a Inspection Scope
The inspectors reviewed performance-based problems involving selected in-scope structures systems and components (SSCs) to assess the effectiveness of the maintenance program The reviews focused on the following aspects when applicable
bull Proper maintenance rule scoping in accordance with 10 CFR 5065 bull Characterization of reliability issues bull Changing system and component unavailability bull 10 CFR 5065 (a)1) and (a)(2) classifications bull Identifying and addressing common cause failures bull Trending of system flow and temperature values bull Appropriateness of performance criteria for SSCs classified (a)(2) and bull Adequacy of goals and corrective actions for SSCs classified (a)(1)
The inspectors reviewed the applicable system health reports maintenance backlogs and Maintenance Rule basis documents The documents reviewed are listed in the Attachment The following structures systems and components were inspected
bull Residual Heat Removal (RHR) relief valves bull Core Spray CS and bull A recirculation pump motor generator set scoop tube positioner
Enclosure
10
b Findings
No findings were identified
1R13 Maintenance Risk Assessments and Emergent Work Control (7111113 -7 samples)
a Inspection Scope
The inspectors evaluated seven maintenance risk assessments for planned and emergent maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work The inspectors reviewed maintenance risk evaluations maintenance plans work schedules and control room logs to determine if concurrent or emergent maintenance or surveillance activities significantly increased the plant risk The inspectors reviewed risk assessments to determine if they were performed as required by 10 CFR 5065a)(4) and implemented in accordance with Entergys administrative procedures (AP) 0125 Plant Equipment and AP 0172 Work Schedule Risk Management - Online When emergent work was performed the inspectors observed activities to determine if plant risk was promptly reassessed and managed The documents reviewed are listed in the Attachment The following maintenance activities were inspected
bull On April 28 2010 increased risk due to removing the A station battery from service for planned maintenance
bull The week of May 32010 increased (yellow) risk due to refueling outage activities bull The week of May 10 2010 increased risk due to electrical bus outages to support
planned maintenance bull The week of May 17 2010 increased risk due to vessel drain down activities
installation of the reactor vessel head installation of the drywell vessel head and integrated leak rate testing to support outage activities
bull On June 8 2010 increased (yellow) risk due to primary containment being declared inoperable
bull On June 10 2010 high risk evolution associated with the CS system and bull On June 24 2010 high risk evolution associated with the A recirculation pump
motor~generator set scoop tube repair activities
b Findings
No findings were identified
1R15 Operability Evaluations (7111115 - 5 samples)
a Inspection Scope
The inspectors reviewed five operability evaluations associated with degraded or nonshyconforming conditions to assess the acceptability of the evaluations the use and control of applicable compensatory measures and compliance with Technical Specifications The inspectors reviewed and compared the technical adequacy of the evaluations with
Enclosure
1
11
the Technical Specifications Updated Final Safety Analysis Report associated design basis documents and Entergys procedure EN-OP-104 Operability Determinations The documents reviewed are listed in the Attachment The inspectors reviewed evaluations of the following degraded or non-conforming conditions
bull CR 2010-01686 pitting found on the RHRSW pump P-8-1C discharge piping bull CR 2010-01821 drywell dome gasket damage bull CR 2010-01944 SW strainer pitting below minimum wall thickness bull CR 2010-02285 S emergency diesel generator cylinder 10 temperature differs
from other cylinders by more than 300 degrees Fahrenheit and bull CR 2010-03202 GNF-2 (nuclear) fuel defect in the spacer springs at certain fuel pin
locations
b Findings
No findings were identified
1R18 Plant Modifications (7111118 - 3 samples)
Temporary Plant Modifications
a Inspection Scope (2 samples)
The inspectors reviewed two temporary modifications to ensure they did not adversely affect the availability reliability or functional capability of any risk-significant SSCs and assessed the adequacy of the 10 CFR 5059 evaluations The inspectors reviewed the engineering change package walked down the area interviewed various personnel and compared the installation and control of the modification to the procedural requirements The inspectors also verified that the installation was consistent with the modification documentation that the drawings and procedures were updated as applicable and that the post-installation testing was adequate The documents reviewed are listed in the Attachment The following two temporary modifications were reviewed
bull Engineering change (EC) 16583 temporary modification to provide power to 480VAC bus-710ads during a bus-7 outage and
bull EC 22659 temporary modification for the leak repair on the AOG two (2) inch pipe 2 CNPE-172A
b Findings
No findings were identified
Enclosure
2
12
Permanent Plant Modifications
a Inspection Scol2e (1 sample)
The inspectors reviewed EC16322 Replacement of Standby Fuel Pool Cooling Service Water Piping to ensure it did not adversely affect the availability reliability or functional capability of any risk-significant SSCs The inspectors reviewed the engineering change package and completed post-maintenance testing (PMT) package and observed the system in operation following the installation of the modification The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R19 Post-Maintenance Testing (7111119 - 10 samples)
a Inspection Scope
The inspectors reviewed ten post-maintenance test (PMT) activities on risk-significant systems The inspectors reviewed these activities to determine whether test acceptance criteria were clear and consistent with design basis documents When testing was directly observed the inspectors determined whether installed test equipment was appropriate and controlled and whether the test was performed in accordance with 10 CFR Part 50 Appendix B Criterion XI ~Test Control and applicable station procedures Upon completion the inspectors performed a walkdown to verify that equipment was returned to the proper alignment necessary to perform its safety function and evaluated whether conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the PMTs performed for the following maintenance activities
bull On April 9 2010 B normal fuel pool cooling pump seal replacement bull On April 21 2010 hydraulic control unit HCU-2235 valve (111 ) replacement bull On April 22 2010 A reactor water clean up pump seal replacement bull On May 32010 startup transformer (T-3-1B) refuel outage maintenance activities bull On May 2 2010 c service water pump discharge valve replacement
bull On May 16 2010 A EDG service water piping replacement bull On May 18 2010 post maintenance examination during RPV operational pressure
test following RPV relief valve replacement bull On June 8 2010 B RHR safety relief valve (SR-10-86B) replacement bull On June 10 2010 B core spray discharge piping safety relief valve (SR-14-20B)
replacement and bull On June 222010 B EDG fuel rack and governor maintenance
b Findings
No findings were identified
Enclosure
13
1 R20 Refueling and Other Outage Activities (7111120 -1 sample)
a Inspection Scope
The inspectors evaluated VY refueling outage (RFO) 28 activities to verify that Entergy considered risk when developing outage schedules adhered to administrative risk reduction methodologies for plant configuration control and adhered to their operating license TS requirements and approved procedures A list of documents reviewed is provided in the Attachment The following activities were inspected
bull Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 28 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions electrical power availability inventory control decay heat removal reactivity control and containment The daily risk assessments accounting for schedule changes and unplanned activities were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate
bull Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations As soon as practical following the shutdown the inspectors performed walkdown inspections of the primary containment
bull Electrical Power - The inspectors reviewed the status and configuration of safetyshyrelated buses throughout RFO 28 The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers the auxiliary transformer and the emergency diesel generators
bull Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (Le shutdown cooling) status on a daily basis Monitoring included daily reviews of residual heat removal system alignment reviews of spent fuel pool cooling system alignment and reviews of RCS time-to-boil calculations and results
bull Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan
bull Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling eVolutions including procedure place keeping communications with refueling floor personnel monitoring of source range nuclear instrumentation and monitoring of individual control rod positions
bull Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage The inspectors
Enclosure
14
performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
15
conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
1
5
1 R04 Equipment Alignment (7111104 - 4 samples)
Partial Equipment Alignment
a Inspection ScoQe
The inspectors performed four partial system walk downs to verify correct system alignment and to identify any discrepancies that could impact system operability Observed plant conditions were compared to the standby alignment of equipment specified in applicable piping and instrumentation drawings and operating procedures (OPs) The inspectors verified valve positions and the general condition of selected components Finally the inspectors evaluated material condition housekeeping and component labeling The documents reviewed are listed in the Attachment The following systems were inspected
bull A train residual heal removal service water (RHRSW) system during B train RHRSW system testing
bull A train residual heat removal (RHR) during B train RHR testing bull S train emergency diesel generator (EDG) system during A train EDG system
maintenance and bull Advanced off-gas system (AOG) after maintenance
b Findings
No findings were identified
1 R05 Fire Protection (7111105 - 7 samples)
Quarterly Inspection (7111105Q - 6 samples)
a Inspection ScoQe
The inspectors performed inspections of six fire areas based on a review of the Vermont Yankee Safe Shutdown Capability Analysis the Fire Hazards Analysis and the Individual Plant Examination for External Events (IPEEE) The inspectors reviewed Entergys fire protection program to determine the specified fire protection design features fire area boundaries and combustible loading requirements for the selected areas The inspectors verified consistent with applicable administrative procedures that combustibles and ignition sources were adequately controlled passive fire barriers manual fire-fighting equipment and detection and suppression equipment were appropriately maintained and compensatory measures for out-ot-service degraded or inoperable fire protection equipment were implemented in accordance with Entergys fire protection program The inspectors evaluated the fire protection program for conformance with the requirements of License Condition 3F The documents reviewed are listed in the Attachment The following fire areas were inspected
Enclosure
6
bull Fire area FA-8 elevation 252 A EDG bull Fire area FA-9 elevation 252 B EDG bull Fire zone FZ-7 elevation 228 condenser bay basement bull Fire zone FZ- elevation 248 condenser bay and ground floor bull Reactor building RB-4 elevation 252 reactor building south and bull Reactor building RB-4 elevation 213 high pressure coolant injection (HPCI)
b Findings
No findings were identified
2 Annual Inspection (7111105A - 1 sample)
The inspectors evaluated Entergys fire brigade performance by observing an announced fire brigade drill on April 2 2010 The inspectors verified that the number of individuals assigned to the fire brigade response met the minimum specified number each member donned the protective clothing tumout gear and self-contained breathing apparatus the fire brigade leader exhibited command of the fire brigade and had copies of the pre-fire plans the fire brigade arrived at the fire scene in a timely manner the licensees drill scenario was followed and acceptance criteria for the drill objectives were met and the licensee performed a post-drill critique to discuss any failures and weaknesses associated with the fire drill performance
b Findings
No findings were identified
1RO Heat Sink Performance (7111107 - 2 samples)
Annual Inspection
a Inspection Scope
The inspectors reviewed the results of the thermal performance tests of emergency diesel generator heat exchangers for DG-1-1A and DG-1-1B including the scavenging air cooler lubricating oil cooler and jacket water cooler for each diesel The inspectors discussed the test results with the system engineer and reviewed the completed surveillance data to determine whether test results met acceptance criteria which considered differences between test and design basis accident conditions The inspectors also reviewed Entergys corrective action program (CAP) to ensure significant heat exchanger performance problems were appropriately identified and documented and that corrective actions assigned if any were appropriate A list of documents reviewed is provided in the Attachment to this report
b Findings
No findings were identified
Enclosure
7
1 R08 Inservice Inspection (lSI) (7111108 -1 sample)
a Inspection Scope
The purpose of this inspection was to assess the effectiveness of the licensees lSI program for monitoring degradation of reactor pressure vessel internals reactor coolant system boundary risk significant piping system boundaries and the containment boundary The inspector assessed the inservice inspection activities using requirements and acceptance criteria for component examination specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI and applicable NRC Regulatory Requirements
The inspector selected a sample of nondestructive examination (NDE) activities to perform a documentation review of those NDE activities for compliance with the requirements of the ASME Boiler and Pressure Vessel Code Section XI The sample selection was based on the inspection procedure objectives sample availability and risk priority of those components and systems where degradation could result in a significant increase in risk of core damage The inspector verified by documentation review that test procedures and examiner qualifications had been reviewed and approved for use by the licensee The inspector reviewed a sample of these procedures and qualifications to determine they were current and in accordance with the ASME Code requirements In addition the inspector performed this review to determine that examiners had been trained and qualified for use of the performance demonstration initiative (PDI) manual ultrasonic test procedures The inspector selected a sample of Indication Notification Reports (INR) and Condition Reports (CRs) to evaluate the licensees effectiveness in the identification and resolution of relevant indications discovered during the observed lSI activities The inspectors documentation review of non-destructive testing included the following
bull Ultrasonic test (UT) manual PDI-UT of weld overlay applied to core spray nozzles N5A-SE and N5B-SE (Examination data was reviewed for comparative evaluation with the UT examinations performed in 1993 1998 and 2004)
bull Magnetic particle test (MT) of sweep weld RH17-S-349A to the RHR piping drawing G191172 lSI Isometric ISI-5920-9212
bull Visual examination (VT-3) of component supports on torus suppression chamber (NB-H1951-TSS10 drawings 5920-914461359131 and 9133) and
bull Liquid Penetrant test (PT) of nozzle to safe end dissimilar butt weld N10-SE drawing ISI-RPV-103 location elevation 269 ft azimuth 350 degrees
The inspector reviewed the visual inspection results of various in-vessel components including jet pump structural members leveling devices miscellaneous fasteners and tack welds made to secure components in place These observations were made to determine the examiner skill and to assess the test equipment performance examination technique and the quality of the inspection environment (water clarity) The inspector performed a review of in-vessel component non-conforming conditions identified in CRs 2010-020112010-02016 and INR-VYR 28-0528-0628-0728-08 28-09 28-10 and 28-11 Additional CRs listed in the Attachment to this report were
Enclosure
8
reviewed by the inspector to evaluate the characterization and disposition of relevant indications identified during the in-vessel visual inspection (IWI) of structural components within the vessel
The inspector selected three ASME Section XI repairreplacement plans-for review where welding on a safety related pressure boundary was performed The review was performed to evaluate qualification and control of the welding process specified in the work order Also to determine that the weld procedures and welders assigned to perform this special process are qualified in accordance with the requirements of ASME Section XI and that specified weld examinations are done in accordance with the ASME code requirements The three ASME Section XI repairreplacement work orders reviewed were
bull W0184964-06 was developed for welding of fitting to service water (SW) piping to facilitate installation of valve V70-164C This welding was of stainless steel base materials welded in line 34SW-18A by groove welding using weld procedure specification (WPS) SS-88-8 Rev 21 Welds 48 and 49 added to the service water system as shown on Weld Map 184964-10 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3
bull W0178169-01 was developed to replace fourteen inch 0 service water pump discharge valve V70-2D Welding was of carbon steel to carbon steel using WPS CS-11-A Rev 3 by groove welding of pipe to valve and pipe to pipe (3 welds) as shown on weld map 178169-1 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3 and
bull W0184964-06 was developed to replace pipe to socket weld 47 in service water system line 34 SW-18A using WPS BM-81-A Rev 2 stainless to carbon steel as shown on weld map 184964-10RO Applicable Code for acceptance was ASME Section XI lSI Class 3
Additionally the inspector performed a visual evaluation of the primary containment liner and additional structural members attached to the liner to assess the condition of the protective coating The evaluation included accessible locations on elevations 252 thru 266 The inspector performed this visual evaluation to determine the extent of any peeling blistering coating loss or other damage as a result of corrosion foreign material impact or lack of maintenance Condition Report CR-VTY-2010-02337 was initiated to describe the results of this visual examination
b Findings
No findings were identified
Enclosure
9
1R11 Licensed Operator Requalification Program (71111110 - 1 sample)
Ouarterly Inspection
a Insgection Scoge
The inspectors observed a simulator-based licensed operator requalification (LOR) exam on June 10 2010 The inspectors assessed the performance of risk significant operator actions including the use of emergency operating procedures The inspectors evaluated crew performance in the areas of clarity and formality of communications ability to take timely actions prioritization interpretation and verification of alarms procedure usage control board manipulations and command and control The inspectors also compared the simulator configuration with the actual control board configuration Finally the inspectors verified that evaluators were identifying and documenting crew performance problems The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R12 Maintenance Effectiveness (71111120 - 3 samples)
a Inspection Scope
The inspectors reviewed performance-based problems involving selected in-scope structures systems and components (SSCs) to assess the effectiveness of the maintenance program The reviews focused on the following aspects when applicable
bull Proper maintenance rule scoping in accordance with 10 CFR 5065 bull Characterization of reliability issues bull Changing system and component unavailability bull 10 CFR 5065 (a)1) and (a)(2) classifications bull Identifying and addressing common cause failures bull Trending of system flow and temperature values bull Appropriateness of performance criteria for SSCs classified (a)(2) and bull Adequacy of goals and corrective actions for SSCs classified (a)(1)
The inspectors reviewed the applicable system health reports maintenance backlogs and Maintenance Rule basis documents The documents reviewed are listed in the Attachment The following structures systems and components were inspected
bull Residual Heat Removal (RHR) relief valves bull Core Spray CS and bull A recirculation pump motor generator set scoop tube positioner
Enclosure
10
b Findings
No findings were identified
1R13 Maintenance Risk Assessments and Emergent Work Control (7111113 -7 samples)
a Inspection Scope
The inspectors evaluated seven maintenance risk assessments for planned and emergent maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work The inspectors reviewed maintenance risk evaluations maintenance plans work schedules and control room logs to determine if concurrent or emergent maintenance or surveillance activities significantly increased the plant risk The inspectors reviewed risk assessments to determine if they were performed as required by 10 CFR 5065a)(4) and implemented in accordance with Entergys administrative procedures (AP) 0125 Plant Equipment and AP 0172 Work Schedule Risk Management - Online When emergent work was performed the inspectors observed activities to determine if plant risk was promptly reassessed and managed The documents reviewed are listed in the Attachment The following maintenance activities were inspected
bull On April 28 2010 increased risk due to removing the A station battery from service for planned maintenance
bull The week of May 32010 increased (yellow) risk due to refueling outage activities bull The week of May 10 2010 increased risk due to electrical bus outages to support
planned maintenance bull The week of May 17 2010 increased risk due to vessel drain down activities
installation of the reactor vessel head installation of the drywell vessel head and integrated leak rate testing to support outage activities
bull On June 8 2010 increased (yellow) risk due to primary containment being declared inoperable
bull On June 10 2010 high risk evolution associated with the CS system and bull On June 24 2010 high risk evolution associated with the A recirculation pump
motor~generator set scoop tube repair activities
b Findings
No findings were identified
1R15 Operability Evaluations (7111115 - 5 samples)
a Inspection Scope
The inspectors reviewed five operability evaluations associated with degraded or nonshyconforming conditions to assess the acceptability of the evaluations the use and control of applicable compensatory measures and compliance with Technical Specifications The inspectors reviewed and compared the technical adequacy of the evaluations with
Enclosure
1
11
the Technical Specifications Updated Final Safety Analysis Report associated design basis documents and Entergys procedure EN-OP-104 Operability Determinations The documents reviewed are listed in the Attachment The inspectors reviewed evaluations of the following degraded or non-conforming conditions
bull CR 2010-01686 pitting found on the RHRSW pump P-8-1C discharge piping bull CR 2010-01821 drywell dome gasket damage bull CR 2010-01944 SW strainer pitting below minimum wall thickness bull CR 2010-02285 S emergency diesel generator cylinder 10 temperature differs
from other cylinders by more than 300 degrees Fahrenheit and bull CR 2010-03202 GNF-2 (nuclear) fuel defect in the spacer springs at certain fuel pin
locations
b Findings
No findings were identified
1R18 Plant Modifications (7111118 - 3 samples)
Temporary Plant Modifications
a Inspection Scope (2 samples)
The inspectors reviewed two temporary modifications to ensure they did not adversely affect the availability reliability or functional capability of any risk-significant SSCs and assessed the adequacy of the 10 CFR 5059 evaluations The inspectors reviewed the engineering change package walked down the area interviewed various personnel and compared the installation and control of the modification to the procedural requirements The inspectors also verified that the installation was consistent with the modification documentation that the drawings and procedures were updated as applicable and that the post-installation testing was adequate The documents reviewed are listed in the Attachment The following two temporary modifications were reviewed
bull Engineering change (EC) 16583 temporary modification to provide power to 480VAC bus-710ads during a bus-7 outage and
bull EC 22659 temporary modification for the leak repair on the AOG two (2) inch pipe 2 CNPE-172A
b Findings
No findings were identified
Enclosure
2
12
Permanent Plant Modifications
a Inspection Scol2e (1 sample)
The inspectors reviewed EC16322 Replacement of Standby Fuel Pool Cooling Service Water Piping to ensure it did not adversely affect the availability reliability or functional capability of any risk-significant SSCs The inspectors reviewed the engineering change package and completed post-maintenance testing (PMT) package and observed the system in operation following the installation of the modification The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R19 Post-Maintenance Testing (7111119 - 10 samples)
a Inspection Scope
The inspectors reviewed ten post-maintenance test (PMT) activities on risk-significant systems The inspectors reviewed these activities to determine whether test acceptance criteria were clear and consistent with design basis documents When testing was directly observed the inspectors determined whether installed test equipment was appropriate and controlled and whether the test was performed in accordance with 10 CFR Part 50 Appendix B Criterion XI ~Test Control and applicable station procedures Upon completion the inspectors performed a walkdown to verify that equipment was returned to the proper alignment necessary to perform its safety function and evaluated whether conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the PMTs performed for the following maintenance activities
bull On April 9 2010 B normal fuel pool cooling pump seal replacement bull On April 21 2010 hydraulic control unit HCU-2235 valve (111 ) replacement bull On April 22 2010 A reactor water clean up pump seal replacement bull On May 32010 startup transformer (T-3-1B) refuel outage maintenance activities bull On May 2 2010 c service water pump discharge valve replacement
bull On May 16 2010 A EDG service water piping replacement bull On May 18 2010 post maintenance examination during RPV operational pressure
test following RPV relief valve replacement bull On June 8 2010 B RHR safety relief valve (SR-10-86B) replacement bull On June 10 2010 B core spray discharge piping safety relief valve (SR-14-20B)
replacement and bull On June 222010 B EDG fuel rack and governor maintenance
b Findings
No findings were identified
Enclosure
13
1 R20 Refueling and Other Outage Activities (7111120 -1 sample)
a Inspection Scope
The inspectors evaluated VY refueling outage (RFO) 28 activities to verify that Entergy considered risk when developing outage schedules adhered to administrative risk reduction methodologies for plant configuration control and adhered to their operating license TS requirements and approved procedures A list of documents reviewed is provided in the Attachment The following activities were inspected
bull Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 28 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions electrical power availability inventory control decay heat removal reactivity control and containment The daily risk assessments accounting for schedule changes and unplanned activities were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate
bull Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations As soon as practical following the shutdown the inspectors performed walkdown inspections of the primary containment
bull Electrical Power - The inspectors reviewed the status and configuration of safetyshyrelated buses throughout RFO 28 The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers the auxiliary transformer and the emergency diesel generators
bull Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (Le shutdown cooling) status on a daily basis Monitoring included daily reviews of residual heat removal system alignment reviews of spent fuel pool cooling system alignment and reviews of RCS time-to-boil calculations and results
bull Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan
bull Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling eVolutions including procedure place keeping communications with refueling floor personnel monitoring of source range nuclear instrumentation and monitoring of individual control rod positions
bull Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage The inspectors
Enclosure
14
performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
15
conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
6
bull Fire area FA-8 elevation 252 A EDG bull Fire area FA-9 elevation 252 B EDG bull Fire zone FZ-7 elevation 228 condenser bay basement bull Fire zone FZ- elevation 248 condenser bay and ground floor bull Reactor building RB-4 elevation 252 reactor building south and bull Reactor building RB-4 elevation 213 high pressure coolant injection (HPCI)
b Findings
No findings were identified
2 Annual Inspection (7111105A - 1 sample)
The inspectors evaluated Entergys fire brigade performance by observing an announced fire brigade drill on April 2 2010 The inspectors verified that the number of individuals assigned to the fire brigade response met the minimum specified number each member donned the protective clothing tumout gear and self-contained breathing apparatus the fire brigade leader exhibited command of the fire brigade and had copies of the pre-fire plans the fire brigade arrived at the fire scene in a timely manner the licensees drill scenario was followed and acceptance criteria for the drill objectives were met and the licensee performed a post-drill critique to discuss any failures and weaknesses associated with the fire drill performance
b Findings
No findings were identified
1RO Heat Sink Performance (7111107 - 2 samples)
Annual Inspection
a Inspection Scope
The inspectors reviewed the results of the thermal performance tests of emergency diesel generator heat exchangers for DG-1-1A and DG-1-1B including the scavenging air cooler lubricating oil cooler and jacket water cooler for each diesel The inspectors discussed the test results with the system engineer and reviewed the completed surveillance data to determine whether test results met acceptance criteria which considered differences between test and design basis accident conditions The inspectors also reviewed Entergys corrective action program (CAP) to ensure significant heat exchanger performance problems were appropriately identified and documented and that corrective actions assigned if any were appropriate A list of documents reviewed is provided in the Attachment to this report
b Findings
No findings were identified
Enclosure
7
1 R08 Inservice Inspection (lSI) (7111108 -1 sample)
a Inspection Scope
The purpose of this inspection was to assess the effectiveness of the licensees lSI program for monitoring degradation of reactor pressure vessel internals reactor coolant system boundary risk significant piping system boundaries and the containment boundary The inspector assessed the inservice inspection activities using requirements and acceptance criteria for component examination specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI and applicable NRC Regulatory Requirements
The inspector selected a sample of nondestructive examination (NDE) activities to perform a documentation review of those NDE activities for compliance with the requirements of the ASME Boiler and Pressure Vessel Code Section XI The sample selection was based on the inspection procedure objectives sample availability and risk priority of those components and systems where degradation could result in a significant increase in risk of core damage The inspector verified by documentation review that test procedures and examiner qualifications had been reviewed and approved for use by the licensee The inspector reviewed a sample of these procedures and qualifications to determine they were current and in accordance with the ASME Code requirements In addition the inspector performed this review to determine that examiners had been trained and qualified for use of the performance demonstration initiative (PDI) manual ultrasonic test procedures The inspector selected a sample of Indication Notification Reports (INR) and Condition Reports (CRs) to evaluate the licensees effectiveness in the identification and resolution of relevant indications discovered during the observed lSI activities The inspectors documentation review of non-destructive testing included the following
bull Ultrasonic test (UT) manual PDI-UT of weld overlay applied to core spray nozzles N5A-SE and N5B-SE (Examination data was reviewed for comparative evaluation with the UT examinations performed in 1993 1998 and 2004)
bull Magnetic particle test (MT) of sweep weld RH17-S-349A to the RHR piping drawing G191172 lSI Isometric ISI-5920-9212
bull Visual examination (VT-3) of component supports on torus suppression chamber (NB-H1951-TSS10 drawings 5920-914461359131 and 9133) and
bull Liquid Penetrant test (PT) of nozzle to safe end dissimilar butt weld N10-SE drawing ISI-RPV-103 location elevation 269 ft azimuth 350 degrees
The inspector reviewed the visual inspection results of various in-vessel components including jet pump structural members leveling devices miscellaneous fasteners and tack welds made to secure components in place These observations were made to determine the examiner skill and to assess the test equipment performance examination technique and the quality of the inspection environment (water clarity) The inspector performed a review of in-vessel component non-conforming conditions identified in CRs 2010-020112010-02016 and INR-VYR 28-0528-0628-0728-08 28-09 28-10 and 28-11 Additional CRs listed in the Attachment to this report were
Enclosure
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reviewed by the inspector to evaluate the characterization and disposition of relevant indications identified during the in-vessel visual inspection (IWI) of structural components within the vessel
The inspector selected three ASME Section XI repairreplacement plans-for review where welding on a safety related pressure boundary was performed The review was performed to evaluate qualification and control of the welding process specified in the work order Also to determine that the weld procedures and welders assigned to perform this special process are qualified in accordance with the requirements of ASME Section XI and that specified weld examinations are done in accordance with the ASME code requirements The three ASME Section XI repairreplacement work orders reviewed were
bull W0184964-06 was developed for welding of fitting to service water (SW) piping to facilitate installation of valve V70-164C This welding was of stainless steel base materials welded in line 34SW-18A by groove welding using weld procedure specification (WPS) SS-88-8 Rev 21 Welds 48 and 49 added to the service water system as shown on Weld Map 184964-10 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3
bull W0178169-01 was developed to replace fourteen inch 0 service water pump discharge valve V70-2D Welding was of carbon steel to carbon steel using WPS CS-11-A Rev 3 by groove welding of pipe to valve and pipe to pipe (3 welds) as shown on weld map 178169-1 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3 and
bull W0184964-06 was developed to replace pipe to socket weld 47 in service water system line 34 SW-18A using WPS BM-81-A Rev 2 stainless to carbon steel as shown on weld map 184964-10RO Applicable Code for acceptance was ASME Section XI lSI Class 3
Additionally the inspector performed a visual evaluation of the primary containment liner and additional structural members attached to the liner to assess the condition of the protective coating The evaluation included accessible locations on elevations 252 thru 266 The inspector performed this visual evaluation to determine the extent of any peeling blistering coating loss or other damage as a result of corrosion foreign material impact or lack of maintenance Condition Report CR-VTY-2010-02337 was initiated to describe the results of this visual examination
b Findings
No findings were identified
Enclosure
9
1R11 Licensed Operator Requalification Program (71111110 - 1 sample)
Ouarterly Inspection
a Insgection Scoge
The inspectors observed a simulator-based licensed operator requalification (LOR) exam on June 10 2010 The inspectors assessed the performance of risk significant operator actions including the use of emergency operating procedures The inspectors evaluated crew performance in the areas of clarity and formality of communications ability to take timely actions prioritization interpretation and verification of alarms procedure usage control board manipulations and command and control The inspectors also compared the simulator configuration with the actual control board configuration Finally the inspectors verified that evaluators were identifying and documenting crew performance problems The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R12 Maintenance Effectiveness (71111120 - 3 samples)
a Inspection Scope
The inspectors reviewed performance-based problems involving selected in-scope structures systems and components (SSCs) to assess the effectiveness of the maintenance program The reviews focused on the following aspects when applicable
bull Proper maintenance rule scoping in accordance with 10 CFR 5065 bull Characterization of reliability issues bull Changing system and component unavailability bull 10 CFR 5065 (a)1) and (a)(2) classifications bull Identifying and addressing common cause failures bull Trending of system flow and temperature values bull Appropriateness of performance criteria for SSCs classified (a)(2) and bull Adequacy of goals and corrective actions for SSCs classified (a)(1)
The inspectors reviewed the applicable system health reports maintenance backlogs and Maintenance Rule basis documents The documents reviewed are listed in the Attachment The following structures systems and components were inspected
bull Residual Heat Removal (RHR) relief valves bull Core Spray CS and bull A recirculation pump motor generator set scoop tube positioner
Enclosure
10
b Findings
No findings were identified
1R13 Maintenance Risk Assessments and Emergent Work Control (7111113 -7 samples)
a Inspection Scope
The inspectors evaluated seven maintenance risk assessments for planned and emergent maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work The inspectors reviewed maintenance risk evaluations maintenance plans work schedules and control room logs to determine if concurrent or emergent maintenance or surveillance activities significantly increased the plant risk The inspectors reviewed risk assessments to determine if they were performed as required by 10 CFR 5065a)(4) and implemented in accordance with Entergys administrative procedures (AP) 0125 Plant Equipment and AP 0172 Work Schedule Risk Management - Online When emergent work was performed the inspectors observed activities to determine if plant risk was promptly reassessed and managed The documents reviewed are listed in the Attachment The following maintenance activities were inspected
bull On April 28 2010 increased risk due to removing the A station battery from service for planned maintenance
bull The week of May 32010 increased (yellow) risk due to refueling outage activities bull The week of May 10 2010 increased risk due to electrical bus outages to support
planned maintenance bull The week of May 17 2010 increased risk due to vessel drain down activities
installation of the reactor vessel head installation of the drywell vessel head and integrated leak rate testing to support outage activities
bull On June 8 2010 increased (yellow) risk due to primary containment being declared inoperable
bull On June 10 2010 high risk evolution associated with the CS system and bull On June 24 2010 high risk evolution associated with the A recirculation pump
motor~generator set scoop tube repair activities
b Findings
No findings were identified
1R15 Operability Evaluations (7111115 - 5 samples)
a Inspection Scope
The inspectors reviewed five operability evaluations associated with degraded or nonshyconforming conditions to assess the acceptability of the evaluations the use and control of applicable compensatory measures and compliance with Technical Specifications The inspectors reviewed and compared the technical adequacy of the evaluations with
Enclosure
1
11
the Technical Specifications Updated Final Safety Analysis Report associated design basis documents and Entergys procedure EN-OP-104 Operability Determinations The documents reviewed are listed in the Attachment The inspectors reviewed evaluations of the following degraded or non-conforming conditions
bull CR 2010-01686 pitting found on the RHRSW pump P-8-1C discharge piping bull CR 2010-01821 drywell dome gasket damage bull CR 2010-01944 SW strainer pitting below minimum wall thickness bull CR 2010-02285 S emergency diesel generator cylinder 10 temperature differs
from other cylinders by more than 300 degrees Fahrenheit and bull CR 2010-03202 GNF-2 (nuclear) fuel defect in the spacer springs at certain fuel pin
locations
b Findings
No findings were identified
1R18 Plant Modifications (7111118 - 3 samples)
Temporary Plant Modifications
a Inspection Scope (2 samples)
The inspectors reviewed two temporary modifications to ensure they did not adversely affect the availability reliability or functional capability of any risk-significant SSCs and assessed the adequacy of the 10 CFR 5059 evaluations The inspectors reviewed the engineering change package walked down the area interviewed various personnel and compared the installation and control of the modification to the procedural requirements The inspectors also verified that the installation was consistent with the modification documentation that the drawings and procedures were updated as applicable and that the post-installation testing was adequate The documents reviewed are listed in the Attachment The following two temporary modifications were reviewed
bull Engineering change (EC) 16583 temporary modification to provide power to 480VAC bus-710ads during a bus-7 outage and
bull EC 22659 temporary modification for the leak repair on the AOG two (2) inch pipe 2 CNPE-172A
b Findings
No findings were identified
Enclosure
2
12
Permanent Plant Modifications
a Inspection Scol2e (1 sample)
The inspectors reviewed EC16322 Replacement of Standby Fuel Pool Cooling Service Water Piping to ensure it did not adversely affect the availability reliability or functional capability of any risk-significant SSCs The inspectors reviewed the engineering change package and completed post-maintenance testing (PMT) package and observed the system in operation following the installation of the modification The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R19 Post-Maintenance Testing (7111119 - 10 samples)
a Inspection Scope
The inspectors reviewed ten post-maintenance test (PMT) activities on risk-significant systems The inspectors reviewed these activities to determine whether test acceptance criteria were clear and consistent with design basis documents When testing was directly observed the inspectors determined whether installed test equipment was appropriate and controlled and whether the test was performed in accordance with 10 CFR Part 50 Appendix B Criterion XI ~Test Control and applicable station procedures Upon completion the inspectors performed a walkdown to verify that equipment was returned to the proper alignment necessary to perform its safety function and evaluated whether conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the PMTs performed for the following maintenance activities
bull On April 9 2010 B normal fuel pool cooling pump seal replacement bull On April 21 2010 hydraulic control unit HCU-2235 valve (111 ) replacement bull On April 22 2010 A reactor water clean up pump seal replacement bull On May 32010 startup transformer (T-3-1B) refuel outage maintenance activities bull On May 2 2010 c service water pump discharge valve replacement
bull On May 16 2010 A EDG service water piping replacement bull On May 18 2010 post maintenance examination during RPV operational pressure
test following RPV relief valve replacement bull On June 8 2010 B RHR safety relief valve (SR-10-86B) replacement bull On June 10 2010 B core spray discharge piping safety relief valve (SR-14-20B)
replacement and bull On June 222010 B EDG fuel rack and governor maintenance
b Findings
No findings were identified
Enclosure
13
1 R20 Refueling and Other Outage Activities (7111120 -1 sample)
a Inspection Scope
The inspectors evaluated VY refueling outage (RFO) 28 activities to verify that Entergy considered risk when developing outage schedules adhered to administrative risk reduction methodologies for plant configuration control and adhered to their operating license TS requirements and approved procedures A list of documents reviewed is provided in the Attachment The following activities were inspected
bull Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 28 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions electrical power availability inventory control decay heat removal reactivity control and containment The daily risk assessments accounting for schedule changes and unplanned activities were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate
bull Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations As soon as practical following the shutdown the inspectors performed walkdown inspections of the primary containment
bull Electrical Power - The inspectors reviewed the status and configuration of safetyshyrelated buses throughout RFO 28 The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers the auxiliary transformer and the emergency diesel generators
bull Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (Le shutdown cooling) status on a daily basis Monitoring included daily reviews of residual heat removal system alignment reviews of spent fuel pool cooling system alignment and reviews of RCS time-to-boil calculations and results
bull Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan
bull Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling eVolutions including procedure place keeping communications with refueling floor personnel monitoring of source range nuclear instrumentation and monitoring of individual control rod positions
bull Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage The inspectors
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performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
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conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
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finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
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guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
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The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
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This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
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equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
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bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
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PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
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Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
7
1 R08 Inservice Inspection (lSI) (7111108 -1 sample)
a Inspection Scope
The purpose of this inspection was to assess the effectiveness of the licensees lSI program for monitoring degradation of reactor pressure vessel internals reactor coolant system boundary risk significant piping system boundaries and the containment boundary The inspector assessed the inservice inspection activities using requirements and acceptance criteria for component examination specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI and applicable NRC Regulatory Requirements
The inspector selected a sample of nondestructive examination (NDE) activities to perform a documentation review of those NDE activities for compliance with the requirements of the ASME Boiler and Pressure Vessel Code Section XI The sample selection was based on the inspection procedure objectives sample availability and risk priority of those components and systems where degradation could result in a significant increase in risk of core damage The inspector verified by documentation review that test procedures and examiner qualifications had been reviewed and approved for use by the licensee The inspector reviewed a sample of these procedures and qualifications to determine they were current and in accordance with the ASME Code requirements In addition the inspector performed this review to determine that examiners had been trained and qualified for use of the performance demonstration initiative (PDI) manual ultrasonic test procedures The inspector selected a sample of Indication Notification Reports (INR) and Condition Reports (CRs) to evaluate the licensees effectiveness in the identification and resolution of relevant indications discovered during the observed lSI activities The inspectors documentation review of non-destructive testing included the following
bull Ultrasonic test (UT) manual PDI-UT of weld overlay applied to core spray nozzles N5A-SE and N5B-SE (Examination data was reviewed for comparative evaluation with the UT examinations performed in 1993 1998 and 2004)
bull Magnetic particle test (MT) of sweep weld RH17-S-349A to the RHR piping drawing G191172 lSI Isometric ISI-5920-9212
bull Visual examination (VT-3) of component supports on torus suppression chamber (NB-H1951-TSS10 drawings 5920-914461359131 and 9133) and
bull Liquid Penetrant test (PT) of nozzle to safe end dissimilar butt weld N10-SE drawing ISI-RPV-103 location elevation 269 ft azimuth 350 degrees
The inspector reviewed the visual inspection results of various in-vessel components including jet pump structural members leveling devices miscellaneous fasteners and tack welds made to secure components in place These observations were made to determine the examiner skill and to assess the test equipment performance examination technique and the quality of the inspection environment (water clarity) The inspector performed a review of in-vessel component non-conforming conditions identified in CRs 2010-020112010-02016 and INR-VYR 28-0528-0628-0728-08 28-09 28-10 and 28-11 Additional CRs listed in the Attachment to this report were
Enclosure
8
reviewed by the inspector to evaluate the characterization and disposition of relevant indications identified during the in-vessel visual inspection (IWI) of structural components within the vessel
The inspector selected three ASME Section XI repairreplacement plans-for review where welding on a safety related pressure boundary was performed The review was performed to evaluate qualification and control of the welding process specified in the work order Also to determine that the weld procedures and welders assigned to perform this special process are qualified in accordance with the requirements of ASME Section XI and that specified weld examinations are done in accordance with the ASME code requirements The three ASME Section XI repairreplacement work orders reviewed were
bull W0184964-06 was developed for welding of fitting to service water (SW) piping to facilitate installation of valve V70-164C This welding was of stainless steel base materials welded in line 34SW-18A by groove welding using weld procedure specification (WPS) SS-88-8 Rev 21 Welds 48 and 49 added to the service water system as shown on Weld Map 184964-10 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3
bull W0178169-01 was developed to replace fourteen inch 0 service water pump discharge valve V70-2D Welding was of carbon steel to carbon steel using WPS CS-11-A Rev 3 by groove welding of pipe to valve and pipe to pipe (3 welds) as shown on weld map 178169-1 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3 and
bull W0184964-06 was developed to replace pipe to socket weld 47 in service water system line 34 SW-18A using WPS BM-81-A Rev 2 stainless to carbon steel as shown on weld map 184964-10RO Applicable Code for acceptance was ASME Section XI lSI Class 3
Additionally the inspector performed a visual evaluation of the primary containment liner and additional structural members attached to the liner to assess the condition of the protective coating The evaluation included accessible locations on elevations 252 thru 266 The inspector performed this visual evaluation to determine the extent of any peeling blistering coating loss or other damage as a result of corrosion foreign material impact or lack of maintenance Condition Report CR-VTY-2010-02337 was initiated to describe the results of this visual examination
b Findings
No findings were identified
Enclosure
9
1R11 Licensed Operator Requalification Program (71111110 - 1 sample)
Ouarterly Inspection
a Insgection Scoge
The inspectors observed a simulator-based licensed operator requalification (LOR) exam on June 10 2010 The inspectors assessed the performance of risk significant operator actions including the use of emergency operating procedures The inspectors evaluated crew performance in the areas of clarity and formality of communications ability to take timely actions prioritization interpretation and verification of alarms procedure usage control board manipulations and command and control The inspectors also compared the simulator configuration with the actual control board configuration Finally the inspectors verified that evaluators were identifying and documenting crew performance problems The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R12 Maintenance Effectiveness (71111120 - 3 samples)
a Inspection Scope
The inspectors reviewed performance-based problems involving selected in-scope structures systems and components (SSCs) to assess the effectiveness of the maintenance program The reviews focused on the following aspects when applicable
bull Proper maintenance rule scoping in accordance with 10 CFR 5065 bull Characterization of reliability issues bull Changing system and component unavailability bull 10 CFR 5065 (a)1) and (a)(2) classifications bull Identifying and addressing common cause failures bull Trending of system flow and temperature values bull Appropriateness of performance criteria for SSCs classified (a)(2) and bull Adequacy of goals and corrective actions for SSCs classified (a)(1)
The inspectors reviewed the applicable system health reports maintenance backlogs and Maintenance Rule basis documents The documents reviewed are listed in the Attachment The following structures systems and components were inspected
bull Residual Heat Removal (RHR) relief valves bull Core Spray CS and bull A recirculation pump motor generator set scoop tube positioner
Enclosure
10
b Findings
No findings were identified
1R13 Maintenance Risk Assessments and Emergent Work Control (7111113 -7 samples)
a Inspection Scope
The inspectors evaluated seven maintenance risk assessments for planned and emergent maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work The inspectors reviewed maintenance risk evaluations maintenance plans work schedules and control room logs to determine if concurrent or emergent maintenance or surveillance activities significantly increased the plant risk The inspectors reviewed risk assessments to determine if they were performed as required by 10 CFR 5065a)(4) and implemented in accordance with Entergys administrative procedures (AP) 0125 Plant Equipment and AP 0172 Work Schedule Risk Management - Online When emergent work was performed the inspectors observed activities to determine if plant risk was promptly reassessed and managed The documents reviewed are listed in the Attachment The following maintenance activities were inspected
bull On April 28 2010 increased risk due to removing the A station battery from service for planned maintenance
bull The week of May 32010 increased (yellow) risk due to refueling outage activities bull The week of May 10 2010 increased risk due to electrical bus outages to support
planned maintenance bull The week of May 17 2010 increased risk due to vessel drain down activities
installation of the reactor vessel head installation of the drywell vessel head and integrated leak rate testing to support outage activities
bull On June 8 2010 increased (yellow) risk due to primary containment being declared inoperable
bull On June 10 2010 high risk evolution associated with the CS system and bull On June 24 2010 high risk evolution associated with the A recirculation pump
motor~generator set scoop tube repair activities
b Findings
No findings were identified
1R15 Operability Evaluations (7111115 - 5 samples)
a Inspection Scope
The inspectors reviewed five operability evaluations associated with degraded or nonshyconforming conditions to assess the acceptability of the evaluations the use and control of applicable compensatory measures and compliance with Technical Specifications The inspectors reviewed and compared the technical adequacy of the evaluations with
Enclosure
1
11
the Technical Specifications Updated Final Safety Analysis Report associated design basis documents and Entergys procedure EN-OP-104 Operability Determinations The documents reviewed are listed in the Attachment The inspectors reviewed evaluations of the following degraded or non-conforming conditions
bull CR 2010-01686 pitting found on the RHRSW pump P-8-1C discharge piping bull CR 2010-01821 drywell dome gasket damage bull CR 2010-01944 SW strainer pitting below minimum wall thickness bull CR 2010-02285 S emergency diesel generator cylinder 10 temperature differs
from other cylinders by more than 300 degrees Fahrenheit and bull CR 2010-03202 GNF-2 (nuclear) fuel defect in the spacer springs at certain fuel pin
locations
b Findings
No findings were identified
1R18 Plant Modifications (7111118 - 3 samples)
Temporary Plant Modifications
a Inspection Scope (2 samples)
The inspectors reviewed two temporary modifications to ensure they did not adversely affect the availability reliability or functional capability of any risk-significant SSCs and assessed the adequacy of the 10 CFR 5059 evaluations The inspectors reviewed the engineering change package walked down the area interviewed various personnel and compared the installation and control of the modification to the procedural requirements The inspectors also verified that the installation was consistent with the modification documentation that the drawings and procedures were updated as applicable and that the post-installation testing was adequate The documents reviewed are listed in the Attachment The following two temporary modifications were reviewed
bull Engineering change (EC) 16583 temporary modification to provide power to 480VAC bus-710ads during a bus-7 outage and
bull EC 22659 temporary modification for the leak repair on the AOG two (2) inch pipe 2 CNPE-172A
b Findings
No findings were identified
Enclosure
2
12
Permanent Plant Modifications
a Inspection Scol2e (1 sample)
The inspectors reviewed EC16322 Replacement of Standby Fuel Pool Cooling Service Water Piping to ensure it did not adversely affect the availability reliability or functional capability of any risk-significant SSCs The inspectors reviewed the engineering change package and completed post-maintenance testing (PMT) package and observed the system in operation following the installation of the modification The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R19 Post-Maintenance Testing (7111119 - 10 samples)
a Inspection Scope
The inspectors reviewed ten post-maintenance test (PMT) activities on risk-significant systems The inspectors reviewed these activities to determine whether test acceptance criteria were clear and consistent with design basis documents When testing was directly observed the inspectors determined whether installed test equipment was appropriate and controlled and whether the test was performed in accordance with 10 CFR Part 50 Appendix B Criterion XI ~Test Control and applicable station procedures Upon completion the inspectors performed a walkdown to verify that equipment was returned to the proper alignment necessary to perform its safety function and evaluated whether conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the PMTs performed for the following maintenance activities
bull On April 9 2010 B normal fuel pool cooling pump seal replacement bull On April 21 2010 hydraulic control unit HCU-2235 valve (111 ) replacement bull On April 22 2010 A reactor water clean up pump seal replacement bull On May 32010 startup transformer (T-3-1B) refuel outage maintenance activities bull On May 2 2010 c service water pump discharge valve replacement
bull On May 16 2010 A EDG service water piping replacement bull On May 18 2010 post maintenance examination during RPV operational pressure
test following RPV relief valve replacement bull On June 8 2010 B RHR safety relief valve (SR-10-86B) replacement bull On June 10 2010 B core spray discharge piping safety relief valve (SR-14-20B)
replacement and bull On June 222010 B EDG fuel rack and governor maintenance
b Findings
No findings were identified
Enclosure
13
1 R20 Refueling and Other Outage Activities (7111120 -1 sample)
a Inspection Scope
The inspectors evaluated VY refueling outage (RFO) 28 activities to verify that Entergy considered risk when developing outage schedules adhered to administrative risk reduction methodologies for plant configuration control and adhered to their operating license TS requirements and approved procedures A list of documents reviewed is provided in the Attachment The following activities were inspected
bull Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 28 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions electrical power availability inventory control decay heat removal reactivity control and containment The daily risk assessments accounting for schedule changes and unplanned activities were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate
bull Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations As soon as practical following the shutdown the inspectors performed walkdown inspections of the primary containment
bull Electrical Power - The inspectors reviewed the status and configuration of safetyshyrelated buses throughout RFO 28 The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers the auxiliary transformer and the emergency diesel generators
bull Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (Le shutdown cooling) status on a daily basis Monitoring included daily reviews of residual heat removal system alignment reviews of spent fuel pool cooling system alignment and reviews of RCS time-to-boil calculations and results
bull Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan
bull Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling eVolutions including procedure place keeping communications with refueling floor personnel monitoring of source range nuclear instrumentation and monitoring of individual control rod positions
bull Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage The inspectors
Enclosure
14
performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
15
conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
8
reviewed by the inspector to evaluate the characterization and disposition of relevant indications identified during the in-vessel visual inspection (IWI) of structural components within the vessel
The inspector selected three ASME Section XI repairreplacement plans-for review where welding on a safety related pressure boundary was performed The review was performed to evaluate qualification and control of the welding process specified in the work order Also to determine that the weld procedures and welders assigned to perform this special process are qualified in accordance with the requirements of ASME Section XI and that specified weld examinations are done in accordance with the ASME code requirements The three ASME Section XI repairreplacement work orders reviewed were
bull W0184964-06 was developed for welding of fitting to service water (SW) piping to facilitate installation of valve V70-164C This welding was of stainless steel base materials welded in line 34SW-18A by groove welding using weld procedure specification (WPS) SS-88-8 Rev 21 Welds 48 and 49 added to the service water system as shown on Weld Map 184964-10 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3
bull W0178169-01 was developed to replace fourteen inch 0 service water pump discharge valve V70-2D Welding was of carbon steel to carbon steel using WPS CS-11-A Rev 3 by groove welding of pipe to valve and pipe to pipe (3 welds) as shown on weld map 178169-1 Rev O Applicable Code for acceptance was ASME Section XI lSI Class 3 and
bull W0184964-06 was developed to replace pipe to socket weld 47 in service water system line 34 SW-18A using WPS BM-81-A Rev 2 stainless to carbon steel as shown on weld map 184964-10RO Applicable Code for acceptance was ASME Section XI lSI Class 3
Additionally the inspector performed a visual evaluation of the primary containment liner and additional structural members attached to the liner to assess the condition of the protective coating The evaluation included accessible locations on elevations 252 thru 266 The inspector performed this visual evaluation to determine the extent of any peeling blistering coating loss or other damage as a result of corrosion foreign material impact or lack of maintenance Condition Report CR-VTY-2010-02337 was initiated to describe the results of this visual examination
b Findings
No findings were identified
Enclosure
9
1R11 Licensed Operator Requalification Program (71111110 - 1 sample)
Ouarterly Inspection
a Insgection Scoge
The inspectors observed a simulator-based licensed operator requalification (LOR) exam on June 10 2010 The inspectors assessed the performance of risk significant operator actions including the use of emergency operating procedures The inspectors evaluated crew performance in the areas of clarity and formality of communications ability to take timely actions prioritization interpretation and verification of alarms procedure usage control board manipulations and command and control The inspectors also compared the simulator configuration with the actual control board configuration Finally the inspectors verified that evaluators were identifying and documenting crew performance problems The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R12 Maintenance Effectiveness (71111120 - 3 samples)
a Inspection Scope
The inspectors reviewed performance-based problems involving selected in-scope structures systems and components (SSCs) to assess the effectiveness of the maintenance program The reviews focused on the following aspects when applicable
bull Proper maintenance rule scoping in accordance with 10 CFR 5065 bull Characterization of reliability issues bull Changing system and component unavailability bull 10 CFR 5065 (a)1) and (a)(2) classifications bull Identifying and addressing common cause failures bull Trending of system flow and temperature values bull Appropriateness of performance criteria for SSCs classified (a)(2) and bull Adequacy of goals and corrective actions for SSCs classified (a)(1)
The inspectors reviewed the applicable system health reports maintenance backlogs and Maintenance Rule basis documents The documents reviewed are listed in the Attachment The following structures systems and components were inspected
bull Residual Heat Removal (RHR) relief valves bull Core Spray CS and bull A recirculation pump motor generator set scoop tube positioner
Enclosure
10
b Findings
No findings were identified
1R13 Maintenance Risk Assessments and Emergent Work Control (7111113 -7 samples)
a Inspection Scope
The inspectors evaluated seven maintenance risk assessments for planned and emergent maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work The inspectors reviewed maintenance risk evaluations maintenance plans work schedules and control room logs to determine if concurrent or emergent maintenance or surveillance activities significantly increased the plant risk The inspectors reviewed risk assessments to determine if they were performed as required by 10 CFR 5065a)(4) and implemented in accordance with Entergys administrative procedures (AP) 0125 Plant Equipment and AP 0172 Work Schedule Risk Management - Online When emergent work was performed the inspectors observed activities to determine if plant risk was promptly reassessed and managed The documents reviewed are listed in the Attachment The following maintenance activities were inspected
bull On April 28 2010 increased risk due to removing the A station battery from service for planned maintenance
bull The week of May 32010 increased (yellow) risk due to refueling outage activities bull The week of May 10 2010 increased risk due to electrical bus outages to support
planned maintenance bull The week of May 17 2010 increased risk due to vessel drain down activities
installation of the reactor vessel head installation of the drywell vessel head and integrated leak rate testing to support outage activities
bull On June 8 2010 increased (yellow) risk due to primary containment being declared inoperable
bull On June 10 2010 high risk evolution associated with the CS system and bull On June 24 2010 high risk evolution associated with the A recirculation pump
motor~generator set scoop tube repair activities
b Findings
No findings were identified
1R15 Operability Evaluations (7111115 - 5 samples)
a Inspection Scope
The inspectors reviewed five operability evaluations associated with degraded or nonshyconforming conditions to assess the acceptability of the evaluations the use and control of applicable compensatory measures and compliance with Technical Specifications The inspectors reviewed and compared the technical adequacy of the evaluations with
Enclosure
1
11
the Technical Specifications Updated Final Safety Analysis Report associated design basis documents and Entergys procedure EN-OP-104 Operability Determinations The documents reviewed are listed in the Attachment The inspectors reviewed evaluations of the following degraded or non-conforming conditions
bull CR 2010-01686 pitting found on the RHRSW pump P-8-1C discharge piping bull CR 2010-01821 drywell dome gasket damage bull CR 2010-01944 SW strainer pitting below minimum wall thickness bull CR 2010-02285 S emergency diesel generator cylinder 10 temperature differs
from other cylinders by more than 300 degrees Fahrenheit and bull CR 2010-03202 GNF-2 (nuclear) fuel defect in the spacer springs at certain fuel pin
locations
b Findings
No findings were identified
1R18 Plant Modifications (7111118 - 3 samples)
Temporary Plant Modifications
a Inspection Scope (2 samples)
The inspectors reviewed two temporary modifications to ensure they did not adversely affect the availability reliability or functional capability of any risk-significant SSCs and assessed the adequacy of the 10 CFR 5059 evaluations The inspectors reviewed the engineering change package walked down the area interviewed various personnel and compared the installation and control of the modification to the procedural requirements The inspectors also verified that the installation was consistent with the modification documentation that the drawings and procedures were updated as applicable and that the post-installation testing was adequate The documents reviewed are listed in the Attachment The following two temporary modifications were reviewed
bull Engineering change (EC) 16583 temporary modification to provide power to 480VAC bus-710ads during a bus-7 outage and
bull EC 22659 temporary modification for the leak repair on the AOG two (2) inch pipe 2 CNPE-172A
b Findings
No findings were identified
Enclosure
2
12
Permanent Plant Modifications
a Inspection Scol2e (1 sample)
The inspectors reviewed EC16322 Replacement of Standby Fuel Pool Cooling Service Water Piping to ensure it did not adversely affect the availability reliability or functional capability of any risk-significant SSCs The inspectors reviewed the engineering change package and completed post-maintenance testing (PMT) package and observed the system in operation following the installation of the modification The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R19 Post-Maintenance Testing (7111119 - 10 samples)
a Inspection Scope
The inspectors reviewed ten post-maintenance test (PMT) activities on risk-significant systems The inspectors reviewed these activities to determine whether test acceptance criteria were clear and consistent with design basis documents When testing was directly observed the inspectors determined whether installed test equipment was appropriate and controlled and whether the test was performed in accordance with 10 CFR Part 50 Appendix B Criterion XI ~Test Control and applicable station procedures Upon completion the inspectors performed a walkdown to verify that equipment was returned to the proper alignment necessary to perform its safety function and evaluated whether conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the PMTs performed for the following maintenance activities
bull On April 9 2010 B normal fuel pool cooling pump seal replacement bull On April 21 2010 hydraulic control unit HCU-2235 valve (111 ) replacement bull On April 22 2010 A reactor water clean up pump seal replacement bull On May 32010 startup transformer (T-3-1B) refuel outage maintenance activities bull On May 2 2010 c service water pump discharge valve replacement
bull On May 16 2010 A EDG service water piping replacement bull On May 18 2010 post maintenance examination during RPV operational pressure
test following RPV relief valve replacement bull On June 8 2010 B RHR safety relief valve (SR-10-86B) replacement bull On June 10 2010 B core spray discharge piping safety relief valve (SR-14-20B)
replacement and bull On June 222010 B EDG fuel rack and governor maintenance
b Findings
No findings were identified
Enclosure
13
1 R20 Refueling and Other Outage Activities (7111120 -1 sample)
a Inspection Scope
The inspectors evaluated VY refueling outage (RFO) 28 activities to verify that Entergy considered risk when developing outage schedules adhered to administrative risk reduction methodologies for plant configuration control and adhered to their operating license TS requirements and approved procedures A list of documents reviewed is provided in the Attachment The following activities were inspected
bull Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 28 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions electrical power availability inventory control decay heat removal reactivity control and containment The daily risk assessments accounting for schedule changes and unplanned activities were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate
bull Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations As soon as practical following the shutdown the inspectors performed walkdown inspections of the primary containment
bull Electrical Power - The inspectors reviewed the status and configuration of safetyshyrelated buses throughout RFO 28 The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers the auxiliary transformer and the emergency diesel generators
bull Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (Le shutdown cooling) status on a daily basis Monitoring included daily reviews of residual heat removal system alignment reviews of spent fuel pool cooling system alignment and reviews of RCS time-to-boil calculations and results
bull Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan
bull Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling eVolutions including procedure place keeping communications with refueling floor personnel monitoring of source range nuclear instrumentation and monitoring of individual control rod positions
bull Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage The inspectors
Enclosure
14
performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
15
conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
9
1R11 Licensed Operator Requalification Program (71111110 - 1 sample)
Ouarterly Inspection
a Insgection Scoge
The inspectors observed a simulator-based licensed operator requalification (LOR) exam on June 10 2010 The inspectors assessed the performance of risk significant operator actions including the use of emergency operating procedures The inspectors evaluated crew performance in the areas of clarity and formality of communications ability to take timely actions prioritization interpretation and verification of alarms procedure usage control board manipulations and command and control The inspectors also compared the simulator configuration with the actual control board configuration Finally the inspectors verified that evaluators were identifying and documenting crew performance problems The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R12 Maintenance Effectiveness (71111120 - 3 samples)
a Inspection Scope
The inspectors reviewed performance-based problems involving selected in-scope structures systems and components (SSCs) to assess the effectiveness of the maintenance program The reviews focused on the following aspects when applicable
bull Proper maintenance rule scoping in accordance with 10 CFR 5065 bull Characterization of reliability issues bull Changing system and component unavailability bull 10 CFR 5065 (a)1) and (a)(2) classifications bull Identifying and addressing common cause failures bull Trending of system flow and temperature values bull Appropriateness of performance criteria for SSCs classified (a)(2) and bull Adequacy of goals and corrective actions for SSCs classified (a)(1)
The inspectors reviewed the applicable system health reports maintenance backlogs and Maintenance Rule basis documents The documents reviewed are listed in the Attachment The following structures systems and components were inspected
bull Residual Heat Removal (RHR) relief valves bull Core Spray CS and bull A recirculation pump motor generator set scoop tube positioner
Enclosure
10
b Findings
No findings were identified
1R13 Maintenance Risk Assessments and Emergent Work Control (7111113 -7 samples)
a Inspection Scope
The inspectors evaluated seven maintenance risk assessments for planned and emergent maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work The inspectors reviewed maintenance risk evaluations maintenance plans work schedules and control room logs to determine if concurrent or emergent maintenance or surveillance activities significantly increased the plant risk The inspectors reviewed risk assessments to determine if they were performed as required by 10 CFR 5065a)(4) and implemented in accordance with Entergys administrative procedures (AP) 0125 Plant Equipment and AP 0172 Work Schedule Risk Management - Online When emergent work was performed the inspectors observed activities to determine if plant risk was promptly reassessed and managed The documents reviewed are listed in the Attachment The following maintenance activities were inspected
bull On April 28 2010 increased risk due to removing the A station battery from service for planned maintenance
bull The week of May 32010 increased (yellow) risk due to refueling outage activities bull The week of May 10 2010 increased risk due to electrical bus outages to support
planned maintenance bull The week of May 17 2010 increased risk due to vessel drain down activities
installation of the reactor vessel head installation of the drywell vessel head and integrated leak rate testing to support outage activities
bull On June 8 2010 increased (yellow) risk due to primary containment being declared inoperable
bull On June 10 2010 high risk evolution associated with the CS system and bull On June 24 2010 high risk evolution associated with the A recirculation pump
motor~generator set scoop tube repair activities
b Findings
No findings were identified
1R15 Operability Evaluations (7111115 - 5 samples)
a Inspection Scope
The inspectors reviewed five operability evaluations associated with degraded or nonshyconforming conditions to assess the acceptability of the evaluations the use and control of applicable compensatory measures and compliance with Technical Specifications The inspectors reviewed and compared the technical adequacy of the evaluations with
Enclosure
1
11
the Technical Specifications Updated Final Safety Analysis Report associated design basis documents and Entergys procedure EN-OP-104 Operability Determinations The documents reviewed are listed in the Attachment The inspectors reviewed evaluations of the following degraded or non-conforming conditions
bull CR 2010-01686 pitting found on the RHRSW pump P-8-1C discharge piping bull CR 2010-01821 drywell dome gasket damage bull CR 2010-01944 SW strainer pitting below minimum wall thickness bull CR 2010-02285 S emergency diesel generator cylinder 10 temperature differs
from other cylinders by more than 300 degrees Fahrenheit and bull CR 2010-03202 GNF-2 (nuclear) fuel defect in the spacer springs at certain fuel pin
locations
b Findings
No findings were identified
1R18 Plant Modifications (7111118 - 3 samples)
Temporary Plant Modifications
a Inspection Scope (2 samples)
The inspectors reviewed two temporary modifications to ensure they did not adversely affect the availability reliability or functional capability of any risk-significant SSCs and assessed the adequacy of the 10 CFR 5059 evaluations The inspectors reviewed the engineering change package walked down the area interviewed various personnel and compared the installation and control of the modification to the procedural requirements The inspectors also verified that the installation was consistent with the modification documentation that the drawings and procedures were updated as applicable and that the post-installation testing was adequate The documents reviewed are listed in the Attachment The following two temporary modifications were reviewed
bull Engineering change (EC) 16583 temporary modification to provide power to 480VAC bus-710ads during a bus-7 outage and
bull EC 22659 temporary modification for the leak repair on the AOG two (2) inch pipe 2 CNPE-172A
b Findings
No findings were identified
Enclosure
2
12
Permanent Plant Modifications
a Inspection Scol2e (1 sample)
The inspectors reviewed EC16322 Replacement of Standby Fuel Pool Cooling Service Water Piping to ensure it did not adversely affect the availability reliability or functional capability of any risk-significant SSCs The inspectors reviewed the engineering change package and completed post-maintenance testing (PMT) package and observed the system in operation following the installation of the modification The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R19 Post-Maintenance Testing (7111119 - 10 samples)
a Inspection Scope
The inspectors reviewed ten post-maintenance test (PMT) activities on risk-significant systems The inspectors reviewed these activities to determine whether test acceptance criteria were clear and consistent with design basis documents When testing was directly observed the inspectors determined whether installed test equipment was appropriate and controlled and whether the test was performed in accordance with 10 CFR Part 50 Appendix B Criterion XI ~Test Control and applicable station procedures Upon completion the inspectors performed a walkdown to verify that equipment was returned to the proper alignment necessary to perform its safety function and evaluated whether conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the PMTs performed for the following maintenance activities
bull On April 9 2010 B normal fuel pool cooling pump seal replacement bull On April 21 2010 hydraulic control unit HCU-2235 valve (111 ) replacement bull On April 22 2010 A reactor water clean up pump seal replacement bull On May 32010 startup transformer (T-3-1B) refuel outage maintenance activities bull On May 2 2010 c service water pump discharge valve replacement
bull On May 16 2010 A EDG service water piping replacement bull On May 18 2010 post maintenance examination during RPV operational pressure
test following RPV relief valve replacement bull On June 8 2010 B RHR safety relief valve (SR-10-86B) replacement bull On June 10 2010 B core spray discharge piping safety relief valve (SR-14-20B)
replacement and bull On June 222010 B EDG fuel rack and governor maintenance
b Findings
No findings were identified
Enclosure
13
1 R20 Refueling and Other Outage Activities (7111120 -1 sample)
a Inspection Scope
The inspectors evaluated VY refueling outage (RFO) 28 activities to verify that Entergy considered risk when developing outage schedules adhered to administrative risk reduction methodologies for plant configuration control and adhered to their operating license TS requirements and approved procedures A list of documents reviewed is provided in the Attachment The following activities were inspected
bull Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 28 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions electrical power availability inventory control decay heat removal reactivity control and containment The daily risk assessments accounting for schedule changes and unplanned activities were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate
bull Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations As soon as practical following the shutdown the inspectors performed walkdown inspections of the primary containment
bull Electrical Power - The inspectors reviewed the status and configuration of safetyshyrelated buses throughout RFO 28 The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers the auxiliary transformer and the emergency diesel generators
bull Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (Le shutdown cooling) status on a daily basis Monitoring included daily reviews of residual heat removal system alignment reviews of spent fuel pool cooling system alignment and reviews of RCS time-to-boil calculations and results
bull Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan
bull Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling eVolutions including procedure place keeping communications with refueling floor personnel monitoring of source range nuclear instrumentation and monitoring of individual control rod positions
bull Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage The inspectors
Enclosure
14
performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
15
conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
10
b Findings
No findings were identified
1R13 Maintenance Risk Assessments and Emergent Work Control (7111113 -7 samples)
a Inspection Scope
The inspectors evaluated seven maintenance risk assessments for planned and emergent maintenance activities to verify that the appropriate risk assessments were performed prior to removing equipment for work The inspectors reviewed maintenance risk evaluations maintenance plans work schedules and control room logs to determine if concurrent or emergent maintenance or surveillance activities significantly increased the plant risk The inspectors reviewed risk assessments to determine if they were performed as required by 10 CFR 5065a)(4) and implemented in accordance with Entergys administrative procedures (AP) 0125 Plant Equipment and AP 0172 Work Schedule Risk Management - Online When emergent work was performed the inspectors observed activities to determine if plant risk was promptly reassessed and managed The documents reviewed are listed in the Attachment The following maintenance activities were inspected
bull On April 28 2010 increased risk due to removing the A station battery from service for planned maintenance
bull The week of May 32010 increased (yellow) risk due to refueling outage activities bull The week of May 10 2010 increased risk due to electrical bus outages to support
planned maintenance bull The week of May 17 2010 increased risk due to vessel drain down activities
installation of the reactor vessel head installation of the drywell vessel head and integrated leak rate testing to support outage activities
bull On June 8 2010 increased (yellow) risk due to primary containment being declared inoperable
bull On June 10 2010 high risk evolution associated with the CS system and bull On June 24 2010 high risk evolution associated with the A recirculation pump
motor~generator set scoop tube repair activities
b Findings
No findings were identified
1R15 Operability Evaluations (7111115 - 5 samples)
a Inspection Scope
The inspectors reviewed five operability evaluations associated with degraded or nonshyconforming conditions to assess the acceptability of the evaluations the use and control of applicable compensatory measures and compliance with Technical Specifications The inspectors reviewed and compared the technical adequacy of the evaluations with
Enclosure
1
11
the Technical Specifications Updated Final Safety Analysis Report associated design basis documents and Entergys procedure EN-OP-104 Operability Determinations The documents reviewed are listed in the Attachment The inspectors reviewed evaluations of the following degraded or non-conforming conditions
bull CR 2010-01686 pitting found on the RHRSW pump P-8-1C discharge piping bull CR 2010-01821 drywell dome gasket damage bull CR 2010-01944 SW strainer pitting below minimum wall thickness bull CR 2010-02285 S emergency diesel generator cylinder 10 temperature differs
from other cylinders by more than 300 degrees Fahrenheit and bull CR 2010-03202 GNF-2 (nuclear) fuel defect in the spacer springs at certain fuel pin
locations
b Findings
No findings were identified
1R18 Plant Modifications (7111118 - 3 samples)
Temporary Plant Modifications
a Inspection Scope (2 samples)
The inspectors reviewed two temporary modifications to ensure they did not adversely affect the availability reliability or functional capability of any risk-significant SSCs and assessed the adequacy of the 10 CFR 5059 evaluations The inspectors reviewed the engineering change package walked down the area interviewed various personnel and compared the installation and control of the modification to the procedural requirements The inspectors also verified that the installation was consistent with the modification documentation that the drawings and procedures were updated as applicable and that the post-installation testing was adequate The documents reviewed are listed in the Attachment The following two temporary modifications were reviewed
bull Engineering change (EC) 16583 temporary modification to provide power to 480VAC bus-710ads during a bus-7 outage and
bull EC 22659 temporary modification for the leak repair on the AOG two (2) inch pipe 2 CNPE-172A
b Findings
No findings were identified
Enclosure
2
12
Permanent Plant Modifications
a Inspection Scol2e (1 sample)
The inspectors reviewed EC16322 Replacement of Standby Fuel Pool Cooling Service Water Piping to ensure it did not adversely affect the availability reliability or functional capability of any risk-significant SSCs The inspectors reviewed the engineering change package and completed post-maintenance testing (PMT) package and observed the system in operation following the installation of the modification The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R19 Post-Maintenance Testing (7111119 - 10 samples)
a Inspection Scope
The inspectors reviewed ten post-maintenance test (PMT) activities on risk-significant systems The inspectors reviewed these activities to determine whether test acceptance criteria were clear and consistent with design basis documents When testing was directly observed the inspectors determined whether installed test equipment was appropriate and controlled and whether the test was performed in accordance with 10 CFR Part 50 Appendix B Criterion XI ~Test Control and applicable station procedures Upon completion the inspectors performed a walkdown to verify that equipment was returned to the proper alignment necessary to perform its safety function and evaluated whether conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the PMTs performed for the following maintenance activities
bull On April 9 2010 B normal fuel pool cooling pump seal replacement bull On April 21 2010 hydraulic control unit HCU-2235 valve (111 ) replacement bull On April 22 2010 A reactor water clean up pump seal replacement bull On May 32010 startup transformer (T-3-1B) refuel outage maintenance activities bull On May 2 2010 c service water pump discharge valve replacement
bull On May 16 2010 A EDG service water piping replacement bull On May 18 2010 post maintenance examination during RPV operational pressure
test following RPV relief valve replacement bull On June 8 2010 B RHR safety relief valve (SR-10-86B) replacement bull On June 10 2010 B core spray discharge piping safety relief valve (SR-14-20B)
replacement and bull On June 222010 B EDG fuel rack and governor maintenance
b Findings
No findings were identified
Enclosure
13
1 R20 Refueling and Other Outage Activities (7111120 -1 sample)
a Inspection Scope
The inspectors evaluated VY refueling outage (RFO) 28 activities to verify that Entergy considered risk when developing outage schedules adhered to administrative risk reduction methodologies for plant configuration control and adhered to their operating license TS requirements and approved procedures A list of documents reviewed is provided in the Attachment The following activities were inspected
bull Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 28 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions electrical power availability inventory control decay heat removal reactivity control and containment The daily risk assessments accounting for schedule changes and unplanned activities were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate
bull Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations As soon as practical following the shutdown the inspectors performed walkdown inspections of the primary containment
bull Electrical Power - The inspectors reviewed the status and configuration of safetyshyrelated buses throughout RFO 28 The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers the auxiliary transformer and the emergency diesel generators
bull Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (Le shutdown cooling) status on a daily basis Monitoring included daily reviews of residual heat removal system alignment reviews of spent fuel pool cooling system alignment and reviews of RCS time-to-boil calculations and results
bull Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan
bull Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling eVolutions including procedure place keeping communications with refueling floor personnel monitoring of source range nuclear instrumentation and monitoring of individual control rod positions
bull Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage The inspectors
Enclosure
14
performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
15
conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
1
11
the Technical Specifications Updated Final Safety Analysis Report associated design basis documents and Entergys procedure EN-OP-104 Operability Determinations The documents reviewed are listed in the Attachment The inspectors reviewed evaluations of the following degraded or non-conforming conditions
bull CR 2010-01686 pitting found on the RHRSW pump P-8-1C discharge piping bull CR 2010-01821 drywell dome gasket damage bull CR 2010-01944 SW strainer pitting below minimum wall thickness bull CR 2010-02285 S emergency diesel generator cylinder 10 temperature differs
from other cylinders by more than 300 degrees Fahrenheit and bull CR 2010-03202 GNF-2 (nuclear) fuel defect in the spacer springs at certain fuel pin
locations
b Findings
No findings were identified
1R18 Plant Modifications (7111118 - 3 samples)
Temporary Plant Modifications
a Inspection Scope (2 samples)
The inspectors reviewed two temporary modifications to ensure they did not adversely affect the availability reliability or functional capability of any risk-significant SSCs and assessed the adequacy of the 10 CFR 5059 evaluations The inspectors reviewed the engineering change package walked down the area interviewed various personnel and compared the installation and control of the modification to the procedural requirements The inspectors also verified that the installation was consistent with the modification documentation that the drawings and procedures were updated as applicable and that the post-installation testing was adequate The documents reviewed are listed in the Attachment The following two temporary modifications were reviewed
bull Engineering change (EC) 16583 temporary modification to provide power to 480VAC bus-710ads during a bus-7 outage and
bull EC 22659 temporary modification for the leak repair on the AOG two (2) inch pipe 2 CNPE-172A
b Findings
No findings were identified
Enclosure
2
12
Permanent Plant Modifications
a Inspection Scol2e (1 sample)
The inspectors reviewed EC16322 Replacement of Standby Fuel Pool Cooling Service Water Piping to ensure it did not adversely affect the availability reliability or functional capability of any risk-significant SSCs The inspectors reviewed the engineering change package and completed post-maintenance testing (PMT) package and observed the system in operation following the installation of the modification The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R19 Post-Maintenance Testing (7111119 - 10 samples)
a Inspection Scope
The inspectors reviewed ten post-maintenance test (PMT) activities on risk-significant systems The inspectors reviewed these activities to determine whether test acceptance criteria were clear and consistent with design basis documents When testing was directly observed the inspectors determined whether installed test equipment was appropriate and controlled and whether the test was performed in accordance with 10 CFR Part 50 Appendix B Criterion XI ~Test Control and applicable station procedures Upon completion the inspectors performed a walkdown to verify that equipment was returned to the proper alignment necessary to perform its safety function and evaluated whether conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the PMTs performed for the following maintenance activities
bull On April 9 2010 B normal fuel pool cooling pump seal replacement bull On April 21 2010 hydraulic control unit HCU-2235 valve (111 ) replacement bull On April 22 2010 A reactor water clean up pump seal replacement bull On May 32010 startup transformer (T-3-1B) refuel outage maintenance activities bull On May 2 2010 c service water pump discharge valve replacement
bull On May 16 2010 A EDG service water piping replacement bull On May 18 2010 post maintenance examination during RPV operational pressure
test following RPV relief valve replacement bull On June 8 2010 B RHR safety relief valve (SR-10-86B) replacement bull On June 10 2010 B core spray discharge piping safety relief valve (SR-14-20B)
replacement and bull On June 222010 B EDG fuel rack and governor maintenance
b Findings
No findings were identified
Enclosure
13
1 R20 Refueling and Other Outage Activities (7111120 -1 sample)
a Inspection Scope
The inspectors evaluated VY refueling outage (RFO) 28 activities to verify that Entergy considered risk when developing outage schedules adhered to administrative risk reduction methodologies for plant configuration control and adhered to their operating license TS requirements and approved procedures A list of documents reviewed is provided in the Attachment The following activities were inspected
bull Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 28 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions electrical power availability inventory control decay heat removal reactivity control and containment The daily risk assessments accounting for schedule changes and unplanned activities were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate
bull Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations As soon as practical following the shutdown the inspectors performed walkdown inspections of the primary containment
bull Electrical Power - The inspectors reviewed the status and configuration of safetyshyrelated buses throughout RFO 28 The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers the auxiliary transformer and the emergency diesel generators
bull Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (Le shutdown cooling) status on a daily basis Monitoring included daily reviews of residual heat removal system alignment reviews of spent fuel pool cooling system alignment and reviews of RCS time-to-boil calculations and results
bull Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan
bull Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling eVolutions including procedure place keeping communications with refueling floor personnel monitoring of source range nuclear instrumentation and monitoring of individual control rod positions
bull Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage The inspectors
Enclosure
14
performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
15
conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
2
12
Permanent Plant Modifications
a Inspection Scol2e (1 sample)
The inspectors reviewed EC16322 Replacement of Standby Fuel Pool Cooling Service Water Piping to ensure it did not adversely affect the availability reliability or functional capability of any risk-significant SSCs The inspectors reviewed the engineering change package and completed post-maintenance testing (PMT) package and observed the system in operation following the installation of the modification The documents reviewed are listed in the Attachment
b Findings
No findings were identified
1 R19 Post-Maintenance Testing (7111119 - 10 samples)
a Inspection Scope
The inspectors reviewed ten post-maintenance test (PMT) activities on risk-significant systems The inspectors reviewed these activities to determine whether test acceptance criteria were clear and consistent with design basis documents When testing was directly observed the inspectors determined whether installed test equipment was appropriate and controlled and whether the test was performed in accordance with 10 CFR Part 50 Appendix B Criterion XI ~Test Control and applicable station procedures Upon completion the inspectors performed a walkdown to verify that equipment was returned to the proper alignment necessary to perform its safety function and evaluated whether conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the PMTs performed for the following maintenance activities
bull On April 9 2010 B normal fuel pool cooling pump seal replacement bull On April 21 2010 hydraulic control unit HCU-2235 valve (111 ) replacement bull On April 22 2010 A reactor water clean up pump seal replacement bull On May 32010 startup transformer (T-3-1B) refuel outage maintenance activities bull On May 2 2010 c service water pump discharge valve replacement
bull On May 16 2010 A EDG service water piping replacement bull On May 18 2010 post maintenance examination during RPV operational pressure
test following RPV relief valve replacement bull On June 8 2010 B RHR safety relief valve (SR-10-86B) replacement bull On June 10 2010 B core spray discharge piping safety relief valve (SR-14-20B)
replacement and bull On June 222010 B EDG fuel rack and governor maintenance
b Findings
No findings were identified
Enclosure
13
1 R20 Refueling and Other Outage Activities (7111120 -1 sample)
a Inspection Scope
The inspectors evaluated VY refueling outage (RFO) 28 activities to verify that Entergy considered risk when developing outage schedules adhered to administrative risk reduction methodologies for plant configuration control and adhered to their operating license TS requirements and approved procedures A list of documents reviewed is provided in the Attachment The following activities were inspected
bull Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 28 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions electrical power availability inventory control decay heat removal reactivity control and containment The daily risk assessments accounting for schedule changes and unplanned activities were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate
bull Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations As soon as practical following the shutdown the inspectors performed walkdown inspections of the primary containment
bull Electrical Power - The inspectors reviewed the status and configuration of safetyshyrelated buses throughout RFO 28 The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers the auxiliary transformer and the emergency diesel generators
bull Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (Le shutdown cooling) status on a daily basis Monitoring included daily reviews of residual heat removal system alignment reviews of spent fuel pool cooling system alignment and reviews of RCS time-to-boil calculations and results
bull Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan
bull Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling eVolutions including procedure place keeping communications with refueling floor personnel monitoring of source range nuclear instrumentation and monitoring of individual control rod positions
bull Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage The inspectors
Enclosure
14
performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
15
conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
13
1 R20 Refueling and Other Outage Activities (7111120 -1 sample)
a Inspection Scope
The inspectors evaluated VY refueling outage (RFO) 28 activities to verify that Entergy considered risk when developing outage schedules adhered to administrative risk reduction methodologies for plant configuration control and adhered to their operating license TS requirements and approved procedures A list of documents reviewed is provided in the Attachment The following activities were inspected
bull Review of the Outage Plan and Daily Shutdown Risk Assessments - The inspectors reviewed the RFO 28 shutdown risk assessment to verify that Entergy addressed the outages impact on defense-in-depth for the five shutdown critical safety functions electrical power availability inventory control decay heat removal reactivity control and containment The daily risk assessments accounting for schedule changes and unplanned activities were also periodically reviewed to determine whether adequate defense-in-depth was maintained for each safety function when redundancy was limited and that planned contingencies were appropriate
bull Monitoring of Shutdown Activities - The inspectors observed the shutdown of the reactor plant including reactor plant cooldown and transition to shutdown cooling operations As soon as practical following the shutdown the inspectors performed walkdown inspections of the primary containment
bull Electrical Power - The inspectors reviewed the status and configuration of safetyshyrelated buses throughout RFO 28 The inspectors performed frequent walkdowns of affected portions of the electrical plant including startup transformers the auxiliary transformer and the emergency diesel generators
bull Decay Heat Removal System Monitoring - The inspectors monitored decay heat removal (Le shutdown cooling) status on a daily basis Monitoring included daily reviews of residual heat removal system alignment reviews of spent fuel pool cooling system alignment and reviews of RCS time-to-boil calculations and results
bull Inventory Control - The inspectors performed daily RCS inventory control reviews including reviews of available injection systems and flow paths to ensure consistency with the outage risk plan
bull Reactivity Control - The inspectors observed reactivity management actions taken by control room operators during refueling eVolutions including procedure place keeping communications with refueling floor personnel monitoring of source range nuclear instrumentation and monitoring of individual control rod positions
bull Containment Closure - The inspectors verified proper primary and secondary containment configuration was maintained throughout the outage The inspectors
Enclosure
14
performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
15
conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
14
performed a primary containment as-found inspection and a closeout walkdown prior to final containment closure Finally the inspectors performed a walkdown of primary and secondary containment to verify that they had been appropriately reestablished prior to and during startup
bull Refueling Activities - The inspectors observed portions of refueling operations including fuel handling and accounting in the reactor vessel and spent fuel pool The inspectors also performed an independent core reload verification of 100 percent of the core
bull Heatup and Startup Activities - The inspectors observed portions of the heatup and startup of the reactor plant following the completion of RFO 28
bull Identification and Resolution of Problems - The inspectors also verified that Entergy identified problems related to refueling activities and entered them into their CAP
b Findings
Introduction A self-revealing NCV of very low safety significance (Green) of TS 64 Procedures was identified when operators inadvertently drained water from the reactor pressure vessel (RPV) during integrated emergency core cooling system (ECCS) testing Specifically Entergy failed to establish the initial plant conditions necessary to perform integrated ECCS testing without causing an inadvertent drain down of the vessel through the main steam lines the RCIC turbine and into the torus
Description On May 17 2010 while VY was shutdown for a refueling outage VY experienced an inadvertent loss of reactor coolant inventory when operators initiated integrated ECCS testing The vessel head was installed and the vessel was flooded up to the RPV flange
At the start of the integrated EGCS test the RCIG and HPCI systems were aligned normally When the test was initiated the RCIC and HPCI steam supply isolation valves opened as expected This provided a path for water to flow from the RPV through the main steam lines and into the torus
The event began at 412 am with the reactor water level at 28507 inches HPGI immediately isolated on a high steam flow signal caused by the flow of water down the HPCI steam line The event was terminated when operators closed the RGIG inboard steam isolation valve 55-minutes later at 507 am with reactor water level at 26103 inches RPV water level lowered approximately 24 inches The licensee restored the RPV inventory
This is the first time VY conducted integrated EGCS testing with the reactor pressure vessel head installed In the past this testing was done with the head removed and main steam line plugs installed to prevent water flow through the path described above However past operating experience has shown that in this configuration the test caused sufficient turbulence inside the reactor vessel to create high airborne contamination levels on the refueling floor Therefore VY developed a procedUre to
Enclosure
15
conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
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guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
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The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
15
conduct integrated ECCS testing with the RPV head installed
Analysis The inspectors determined that the failure to establish appropriate plant conditions prior to ECCS testing in accordance with TS 64 was a performance deficiency that was reasonably within Entergys ability to foresee and correct and should have been prevented Traditional Enforcement did not apply as the issue did not have actual or potential safety consequence had no willful aspects nor did it impact the NRCs ability to perform its regulatory function
A review of IMC 0612 Appendix E Minor Examples revealed that there were no examples similar to this finding The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safetY functions during shutdown as well as power operations Specifically the implementation of the inadequate procedure guidance resulted in an unexpected loss of RPV water inventory of approximately 2100 gallons The inspectors performed an initial screening of the finding in accordance with IMC 060904 Phase 1 - Initial Screening and Characterization of Findings The inspectors concluded that the finding was a Primary n
System Loss of Coolant Accident initiator contributor that affected the safety of the reactor during the refueling outage The inspectors then evaluated the significance of the finding using Inspection Manual Chapter 0609 Appendix G Shutdown Operations shySignificance Determination Process The inspector determined this issue was of very low safety significance using Appendix G Attachment 1 Phase 1 Operational Checklist for Both PWRs and BWRs and specifically Checklist 8 BWR Cold Shutdown or Refueling Operation Time to Boilgt 2 Hours RCS Level lt 23 Above Top of Flange This determination was based on the fact that the reactor vessel water level would not decrease below the level of the main steam Hnes The inadvertent draining of the water level to the level of the main steam lines would not significantly impact the shutdown safety functions of decay heat removal and maintaining water level in the reactor core
The inspectors determined that this finding had a cross-cutting aspect in the HIJman Performance cross-cutting area Resources component because the test procedure was inadequate Specifically the procedure did not provide adequate directions for establishing plant conditions during a test that had the capability of draining ReS inventory [H2(c)]
Enforcement Vermont Yankee Technical Specification 64 states in part that written procedures shall be maintained covering activities such as refueling operations and surveillance and testing requirements Contrary to the above on May 172010 Entergy performed integrated ECCS testing using a procedure that was not maintained adequately in that it did not contain appropriate initial plant conditions prior to testing Specifically the procedure did not verify that a RPV drain down path to the torus through the main steam lines and the RCIC and HPCI turbines did not exist Entergy restored the RPV inventory initiated a CR to perform a root cause evaluation of the issue and assigned a corrective action to revise the procedure in order to preclude recurrence in future outages This resulted in an RPV coolant loss to the torus equivalent to approximately 24 inches of reactor vessel water level Because this
Enclosure
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
16
finding was of very low safety significance and has been entered into the CAP (CR 2010-02757) this violation is being treated as a NCV consistent with Section VIA1 of the NRC Enforcement Policy (NCV 0500027112010003-01 Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure)
1 R22 Surveillance Testing (7111122 - 10 samples)
a Inspection Scope
The inspectors observed ten surveillance tests andor reviewed test data of selected risk-significant SSCs to determine whether the testing adequately demonstrated equipment operational readiness and the ability to perform the intended safety functions The inspectors reviewed selected prerequisites and precautions to determine if they were met evaluated whether the tests were performed in accordance with the written procedure determined whether the test data was complete and met procedural requirements and assessed whether SSCs were properly returned to service following testing The inspectors also verified that conditions adverse to quality were entered into the CAP for resolution The documents reviewed are listed in the Attachment The inspectors reviewed the following surveillance tests
bull On April 20 2010 0 RHRSW pump operability and full flow test (1ST) bull On April 20 2010 0 RHR pump operability test (1ST) bull On April 25 2010 Reactor coolant temperature during cool down per Technical
Specification 46A2 bull On April 28 2010 A main station battery performance test bull On May 132010 MSIV 80C local leak rate test (CIV) bull On May 17 2010 ECCS integrated automatic initiation test bull On May 20 2010 RPV operational system leakage test bull On May 23 2010 HPCI pump and valve operability test post refueling outage bull On May 23 2010 RCIC pump and valve operability test post refueling outage and bull On June 28 2010 reactor coolant system leak detection surveillance (RCS LO)
b Findings
No findings were identified
1EP6 Drill Evaluation (7111406 -1 sample)
a Inspection Scope
The inspectors observed an emergency preparedness (EP) drill on June 23 2010 and reviewed the player and lead controller critiques Entergys EP staff preselected the drill notifications and protective action recommendations to be included in the EP drill performance indicator (PI) The inspectors discussed the performance expectations and results with Entergys EP staff to confirm correct implementation of the PI program The inspectors focused on the ability of licensed operators to perform event claSSifications and to make proper notifications in accordance with Entergys procedures and industry
Enclosure
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
17
guidance The inspectors evaluated the drill for conformance with the requirements of 10 CFR Part 50 Appendix E Emergency Planning and Preparedness for Production and Utilization Facilities The inspectors compared Entergys self-identified issues with observations from the inspectors review to ensure that performance issues were properly identified and documented The documents reviewed are listed in the Attachment
b Findings
No findings were identified
2 RADIATION SAFETY
Cornerstone OccupationalPublic Radiation Safety (PS)
2RS01 Radiological Hazard Assessment and Exposure Controls (7112401)
a Inspection Scope
Radiological Hazard Assessment
The inspector determined if there had been changes to plant operations since the last inspection that may result in a significantly new radiological hazard for onsite workers or members of the public The inspector verified the licensee had assessed the potential impact of these changes with respect to the Spring refueling outage radiological conditions and had implemented periodic monitoring as appropriate to detect and quantify the associated radiological hazards
The inspector reviewed radiological surveys of principal refueling outage radiological work areas The inspector reviewed surveys to verify they were appropriate for the given radiological hazards that were accessed by workers
The inspector conducted walk-downs of the facility to evaluate material conditions and potential radiological conditions (radiological control area protected area controlled area contaminated tool storage and contaminated machine shops)
The inspector selected radiologically risk-significant work activities associated with Refueling Outage RFO 28 that involved exposure to radiation including
bull Reactor in-service inspection bull Reactor reassembly bull Scaffold installation activities bull Temporary shielding installation activities and bull Radiation protection job coverage of various work activities
Enclosure
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
18
The inspector reviewed pre-work surveys to verify if Entergy appropriately identified and quantified the radiological hazard and established adequate protective measures The inspector evaluated the radiological survey program to determine if hazards were properly identifiedincluding the following
bull Identification of hot particles bull The presence of alpha emitters bull The potential for airborne radioactive materials including the potential presence of
transuranics andor other hard-to-detect radioactive materials bull The hazards associated with work activities that could suddenly and severely
increase radiological conditions and bull Severe radiation field dose gradients that can result in non~uniform exposures of the
body
The inspector selected air sample survey records to verify that samples were collected and counted in accordance with licensee procedures The inspector observed work in potential airborne areas to verify that air samples were representative of the breathing air zone The inspector verified that the licensee has a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne
Contamination and Radioactive Material Control
At the Vermont Yankee Radiological Controlled Area (RCA) control point the inspector observed workers surveying and releasing potentially contaminated materials for unrestricted use The inspector verified that the counting instrumentation was located in a low background area and that the instruments sensitivity was appropriate for the type of contamination being measured
Instructions to Workers
The inspector selected containers holding nonexempt licensed radioactive materials resulting from the Spring 2010 refueling outage activities that may cause unplanned or inadvertent exposure of workers to verify that they were labeled and controlled
The inspector reviewed radiation work permits (RWPs) associated with the work activities listed above that were used to access high radiation areas and identified what work control instructions or control barriers had been specified The inspector verified that allowable stay times or permissible dose for radiologically Significant work under each radiation work permit was identified The inspector verified that electronic personal dosimeter (EPD) alarm set points were in conformance with survey indications and plant policy
The inspector selected two occurrences where a workers EPD noticeably malfunctioned or alarmed The inspector verified that workers responded to the off-normal condition The inspector verified that the issue was included in the CAP and dose evaluations were conducted
Enclosure
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
19
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report I
I b Findings I
i
No findings were identified
2RS02 Occugational ALARA Planning and Controls (7112402) I a Inspection Scope
The inspector reviewed pertinent information regarding plant collective exposure history current exposure trends and ongoing or planned activities in order to assess current performance and exposure challenges The inspector determined the plants 3-year rolling average collective exposure
The inspector determined the site-specific trends in collective exposures and source term measurements The source term has been stable for the last several years with refueling outage dose rates as expected for most outage work activities
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identified
2RS04 Occupational Dose Assessment (7112404)
a Inspection Scope
Special Bioassat
The inspector reviewed the adequacy of the licensees program for dose assessments based on airborneDerived Air Concentration (DAC) monitoring The inspector verified that flow rates andor collection times for fixed head air samplers or lapel breathing zone air samplers were adequate to ensure that appropriate lower limits of detection (LLDs are obtained The inspector reviewed the adequacy of procedural guidance used to assess dose when the licensee applies protection factors The inspector reviewed dose assessments performed using airborneDAC monitoring The inspector verified that the licensees DAC calculations were representative of the actual airborne radionuclide mixture including hard-to-detect nuclides
The inspector reviewed the adequacy of the licensees internal dose assessments for any actual internal exposure greater than 10 millirem committed effective dose
Enclosure
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
20
equivalent The inspector determined that the affected personnel were properly monitored with calibrated equipment and the data was analyzed and internal exposures properly assessed in accordance with licensee procedures
This inspection effort represented partial completion of one sample Further inspection is planned to fully complete this sample and the results will be documented in a future report
b Findings
No findings were identined
2RS05 Radiation Monitoring Instruments (7112405 - 1 Sample)
a Inspection Scope
During the period June 7-10 2010 the inspector conducted the following activities to verify that the Vermont Yankee was ensuring the accuracy and operability of radiation monitoring instrumentation Implementation of these controls was reviewed against the criteria contained in 10 CFR 20 relevant Technical Specifications and Vermont Yankees procedures
Inspection Planning
bull The inspector reviewed the UFSAR to identify radiation instruments aSSOCiated with monitoring area radiological conditions including airborne radioactivity process streams effluents materialarticles and workers
bull The inspector obtained a listing of all survey instrumentation including air samplers small article monitors (SAMs) personnel contamination monitors (PCMs) and other monitors used to detect contamination The inspectors reviewed the list to determine if an adequate number and type of instruments are available to support operations
bull The inspector obtained and reviewed copies of evaluation reports of the radiation monitoring program since the last inspection
bull The inspector obtained and reviewed copies of procedures used for instrument source checks and calibrations
bull The inspector reviewed area radiation monitor set point values and basis and bull The inspector reviewed the effluent monitor set pOint basis and the calculation
methods provided in the offsite dose calculation manual (ODCM)
Walkdowns and Observations
bull The inspector toured the Turbine Reactor and Advanced Offgas buildings and observed the condition of the Reactor Building South Ventilation monitor the Service Water Effluent monitor and the Advanced Off Gas Hold Up and Stack monitors and the Radioactive Liquid Waste Discharge monitor These monitor configurations aligned with Vermont Yankees ODCM descriptions
Enclosure
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
21
bull The inspector checked the calibration due dates and source check stickers for portable survey instruments ready for issue or in the field The type of instruments checked included RO-20M RM25 Telepoles RM20 AMP-100 and REM-500
bull The inspector observed a technician perform instrument source checks The inspectors verified that the instrument source checks included exposures at each high-range scale The source check observations included RO-20M RM20 Telepoles AMP-100 and a Small Article Monitors (SAM)-11
bull The inspector verified Area Radiation Monitors (ARM) and Continuous Air Monitors (CAM) were appropriately positioned relative to the radiation source(s) they were intended to monitor The inspectors compared the monitor response with actual area conditions for severa ARMs and
bull The inspector observed the daily source checks for Aptec AMP3e 204019 Thermo PM-7 536 and 537 and SAM-11 516 and 407 The inspector verified the source checks were in accordance with the manufacturers recommendations and Vermont Yankees procedures
Calibration and Testing Program - Process and Effluent Monitors
bull The inspector verified for fOLir effluent monitor instruments that channel calibration and functional tests were performed consistent with radiological effluent technical specifications The inspector also verified that the source calibrations use National Institute of Standards and Technology (NIST) traceable sources or secondary measuring that has been calibrated to NIST standard The inspectors verified that the sources used represent the plant nuclide mix
bull The inspector verified that effluent monitor alarm set pOints are established as provided in the ODCM and station procedures and
bull There were no changes to effluent monitor set-pOints during this inspection period
Laboratocy Instrumentation
bull The inspector verified that the daily performance checks and calibration data indicate the frequency of calibration is adequate and there is no degradation of instrument performance
Whole Body Counter
bull The inspector reviewed the methods and sources used to perform the Whole Body Counter (WBC) checks prior to daily use and observed a performance check The inspector verified the checks are appropriate and align with the plants isotopic mix and
bull The inspector reviewed the WBC calibration reports completed since the last inspection The inspector verified the calibration sources and phantoms used were appropriate and representative of the plant source term
Enclosure
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
22
PostmiddotAccident Monitoring Instrumentation
bull The inspector reviewed the May 162010 calibration records for the Drywell highshyrange monitors R16-181A and R16-18B and three Containment Monitors RM-18shy154A RM-18-154B and RM-18-154C
bull The inspector verified that an electronic calibration for the Drywell high-range monitors was performed and included each decade above 10 remhour The inspector also verified that a source calibration was performed and included an exposure for at least one decade below 10 remhour
bull The inspector verified the acceptance criteria were reasonable bull The inspector reviewed the calibration records and availability for the Main Stack
Ventilation and Reactor Building Ventilation high range monitors bull The inspector reviewed Vermont Yankees capability to collect high-range postshy
accident iodine effluent samples and bull There were no opportunities to observe electronic or source calibrations of the high
range monitors during this inspection These calibrations are only performed during outages
PMs PCMs and SAMs
bull The inspector observed the use of an Eberline PM-7 PM-12 Aptec AMP3e and SAM-11 and verified that the alarm set points were reasonable to ensure that licensed material is not released from the site and
bull The inspector reviewed calibration records and procedures for these devices and verified that calibration methodology was consistent with manufacturers recommendations
Portable Survey Instruments ARMs Electronic Dosimetry and Air SamplersCAMs
bull The inspector reviewed calibration records for a PIG-6B aTelepole an R020AA a Mark 2 ElectroniC Personal Dosimeter an AMS-4 an RP-4520 and a REM-500 The inspector reviewed the detector measurement geometry and calibration methods for ARMs and portable radiation survey instruments The inspector observed a calibration of a PIG-6B and a source check of a Telepole and
bull The inspector reviewed the corrective actions taken for two R020s and one Telepole found to be out of the acceptance criteria during the observed daily source check 110 corrective action reports were identified for personal monitoring devices
Instrument Calibrator
bull The inspector reviewed the current output tables for Vermont Yankees portable survey and ARM instrument calibrator unit The inspector verified that Vermont Yankee periodically measures the calibrator output over the range of the instruments and
bull The inspector verified the calibrator is periodically calibrated using NIST traceable sources
Enclosure
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
23
Calibration and Check Sources
bull The inspector reviewed Vermont Yankees 10 CFR 61 source term to verify that the calibration sources used are representative of the types and energies of radiation encountered in the plant
Problem Identification and Resolution
bull The inspector reviewed condition reports related to radiation monitoring instrumentation and selected three specific CRs to review with Vermont Yankee staff The inspector verified that appropriate corrective actions have been taken The inspector verified that problems are being identified at the appropriate threshold and are properly addressed for resolUtion
This inspection effort represented completion of one sample
b Findings
No findings were identified
4 OTHER ACTIVITIES lOA]
40A1 Performance Indicator (PI) Verification (71151 - 2 samples)
Initiating Events Cornerstone
a Inspection ScoRe
The inspectors reviewed Entergys submittals and performance indicator (PI) data for the cornerstones listed below for the period from January 2009 to December 2009 The inspectors reviewed selected operator logs plant process computer data licensee event reports and CRs The PI definitions and guidance contained in Nuclear Energy Institute (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 during this period The Pis reviewed were
bull Reactor coolant system activity (BI01) and bull Reactor coolant system total leakage (BI02)
b Findings
No findings were identified
Enclosure
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
1
24
40A2 Identification and Resolution of Problems (71152 - 1 sample)
Reviews of Items Entered into the Corrective Action Program
a Inspection Scope
The inspectors performed a daily screening of each item entered into Entergys CAP This review was accomplished by reviewing printouts of each CR attending daily screening meetings andor accessing Entergys database The purpose of this review was to identify conditions such as repetitive equipment failures or human performance issues that might warrant additional follow up
Additionally the inspectors reviewed a sample of non-conforming conditions identified during lSI examinations this outage to evaluate the effectiveness of the licensee in identification and resolution of problems The inspectors selected INR VYR28-3 RO and R2 for evaluation of flaw identification characterization and placement into the licensee corrective action program using CR-VTY-2010-02016 The remote in-vessel visual inspection (lWI) of the reactor steam dryer welds revealed crack-like indications at the DC-V4C Steam Dryer Drain Channel weld This flaw was previously identified during visual examination in refuel outage RFO-27 The indication was characterized as linear located in the heat affected zone on the drain pipe DC-H-27 side of the weld The vertical component of this indication does not connect to the previously identified indication on drain channel H-27 The inspector reviewed the materials of construction weld metal flaw location weld metal profile and condition of the adjacent base material The inspector verified that the flaws identified were characterized appropriately and entered into the licensees corrective action process
b Findings
No findings were identified
2 Semi-Annual Trend Review (1 sample)
a Inspection ScoQe
The inspectors performed a review of Entergys CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue The inspectors review considered the six~month period of November 2009 to April 2010 although some examples expanded beyond those dates when the scope of the trend warranted The inspectors compared their results with the results contained in Entergys quarterly trend reports operator logs and CRs The corrective actions assigned to address select individual issues were reviewed for adequacy
b Findings and Observations
No findings or observations of significance were identified
Enclosure
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
1
25
40A3 Event Followup (71153 - 3 samples)
Reactor Scram
a Inspection Scope
At 329 pm on May 25 2010 the Vermont Yankee nuclear power plant experienced a main generator trip and lockout due to a high differential current on a 345KV Tie Line This resulted in a main turbine trip and reactor scram The plant did not experience any complications during the scram and all automatic functions responded appropriately Prior to the main generator trip the licensee was raising reactor power from 70 percent to 745 percent at 1 percent every 3 minutes This is the highest power level reached after tying in the new VELCO switchyard to 345KV system Entergy determined that the main generator trip was initiated by a high differential current caused by differences in the winding ratios between the current sensors in the VY switchyard and the new VELCO switchyard As the generator power was raised the current sensors deviated sufficiently to cause the main generator to trip Entergy generated a modification change to make Entergys current sensors compatible with VELCOs current sensors
b Findings and Observations
No findings or observations of significance were identified
2 Loss of Communications
a Inspection Scope
At 200 am on May 272010 Vermont Yankee lost telephone communications The loss of telephone communications was due to the high winds experienced during a thunderstorm Lost external communication capability inCluded commercial telephone and the Emergency Notification System A microwave link with the local transmission system operator and some cell phone service remained available At the time of the loss of communications the plant was shutdown following a scram caused by unrelated issues An emergency (Notice of Unusual Event) was not declared because sufficient internal and external communication capability remained available Communication capabilities were restored at approximately 200 pm
b Findings and Observations
No findings or observations of Significance were identified
3 Notice of Unusual Event
a Inspection Scope
On June 23 2010 Vermont Yankee declared a Notice of Unusual Event (UE) at 225 pm The declaration was made by Entergy in accordance with the plant specific emergency action guidelines after ground motion was felt by personnel on-site and the
Enclosure
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
26
occurrence of an earthquake was confirmed by the National Earthquake Information Center According to US Geological Survey an earthquake of magnitude 50 occurred with a seismic epicenter located 33 miles north of Gatineau Quebec Canada near Ottawa and approximately 300 miles from the Vermont Yankee site Vermont Yankee continued to operate normally at 100-percent power and there was no evidence of damage based on plant inspection of station equipment and structures The NRC Resident Inspectors were on-site and independently verified by conducting inspection activities that there was no evidence of damage to plant equipment The NRC confirmed that VY operators notified the states of NH VT and MA regarding the UE emergency declaration The UE was terminated by Entergy at 525 pm on June 23 2010 based on a thorough investigation that verified no damage to station eqUipment and structures had occurred as a result of the seismic activity
b Findings and Observations
No findings or observations of significance were identified
40A5 Other Activities
TI 2515179 Verification of Licensee Resl20nses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10 Code of Federal Regulations Part 202207 (1 0 CFR 202207)
a Inspection Scope
During the period June 7 2010 through June 10 2010 the inspector conducted the following activities to confirm the inventories of materials possessed by Vermont Yankee were appropriately reported and documented in the National Source Tracking System (NSTS) in accordance with 10 CFR 202207
Inspection Planning
bull The inspector retrieved a copy of Vermont Yankees NSTS inventory The inventory indicated that Vermont Yankee didnt possess any sources that required NSTS tracking
Inventory Verification
bull The inspector reviewed the sites source inventory and verified aU sources were below the level requiring NSTS tracking
bull The inspector discussed the requirements with Vermont Yankee staff members including the Radiological Protection Support Supervisor and determined that they were aware of the requirements and had correctly determined that they didnt apply to Vermont Yankee at this time However Vermont Yankee understood the need to comply with the NSTS requirements if applicable sources were obtained in the future
Enclosure
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
27
b Findings
No findings were identified
40A6 Meetings including Exit
Exit Meeting Summary
On May 13 2010 the inspector presented the radiation safety baseline inspection results to Mr Christopher Wamser General Manager of Plant Operations and other members of his staff The inspector confirmed that no proprietary information was provided or examined during the inspection
On June 10 2010 the inspector presented the radiation safety and TI 179 inspection results to Mr David Tkatch Radiation Protection Manager The inspector verified that proprietary information was not provided to the inspector for the inspection
On June 21 2010 Donald Jackson NRC Regional Branch Chief for Vermont Yankee presented and discussed the End-of-Cycle performance assessment of the Vermont Yankee Nuclear Power Plant with Mr Michael Colomb Site Vice President The licensee acknowledged the assessment and planned regulatory oversight This discussion was completed prior to a public performance assessment open-house and meeting on June 222010 (ADAMS Accession ML 100621409)
On July 26 2010 the resident inspectors presented the 2nd quarter inspection results to Mr Michael Colomb Site Vice President and other members of the Vermont Yankee staff The inspectors confirmed that no proprietary information was provided or examined during the inspection
ATTACHMENT SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Vermont Yankee Personnel M Colomb Site Vice President C Wamser General Manager of Plant Operations G Lozier Acting Director of Nuclear Safety J Devincentis Acting Licensing Manager N Rademacher Director of Engineering M Philippon Operations Manager J Rogers Design Engineering P Rose OperationsFIN Team G Von der Esch Asst Operations Manager R Current Sr Electrical IampC System Engineer L Doucette System Engineering R Meister Licensing P Corbett Manager Quality Assurance P Couture Licensing Specialist L Derting Supervisor Radwaste J Geyster Supervisor Radiation Protection M Gosekamp Manager Maintenance J Hardy Superintendant Chemistry R Wanczyk Acting Manager CAampA M Morgan Superintendent Training S Skibniowski Environmental Specialist P Stover Supervisor Radiation Protection D Tkatch Manager Radiation Protection R Wanczyk Enexus Site Representative K Stupak LOR Program Lead H Sreite Senior engineer J Mully Engineer S Jonasch Engineer R Current Engineer
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
A-2
LIST OF ITEMS OPENED CLOSED AND DISCUSSED
Opened and Closed
050002712010003-01 NCV Inadvertent Loss of RCS Inventory During ECCS Testing Due to Inadequate Procedure
Closed None
Discussed None
LIST OF DOCUMENTS REVIEWED
In addition to the documents identified in the body of this report the inspectors reviewed the following documents and records
Vermont Yankee Nuclear Power Station Updated Final Safety Analysis Report Vermont Yankee Nuclear Power Station Technical Specifications Vermont Yankee Nuclear Power Station Narrative Logs Night Orders and Standing Orders
1lt Denotes creation as a result of NRC inspection
Section 1 R01 Adverse Weather Protection
Condition Reports 2010-03036 2010-03042
Procedures AP 0172 Work Schedule Risk Management - Online Rev 21 ON 3179 Grid Instability Rev 3 OP 2140 345 KV Electrical System Rev 51 OP 2141 115 KV Switchyard Rev 30 OT3122 Loss of Normal Power Rev 41 ENN-PL-158 Transmission Grid Interface and Compliance with NERC Standards Rev 1
Miscellaneous Documents BVY 06-032 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 2 2006
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
A-3 BVY 06-038 Vermont Yankee Nuclear Power Station Licensee No DPR-28 Response to
Generic Letter 2006-02 Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power dated April 14 2006
Section 1R04 Equipment Alignment
Procedures OP 2150 Advanced Off Gas System Rev 67 OP 2124 Residual Heat Removal System Rev 114 OP 2126 Diesel Generators Rev 56
Drawings G-191172 Flow Diagram Residual Heat Removal System Rev 66 33600-A-207 Engineering Flow Diagram Train A and B Recombiner Area Off Gas
Modification Rev 25
Section 1 R05 Fire Protection
Procedures OP 2186 Fire Suppression Systems Rev 56 OP 3020 Fire Emergency Response Procedure Rev 54 OP 4002 Integrity Surveillance of Fire Detectors and Fire Suppression Systems Rev 14 PP 7011 Vermont Yankee Fire Protection and Appendix R Program Rev 9 EN-TQ-125 Fire Brigade Drills Rev 0
Miscellaneous Documents PFP-RB-6 Reactor Building South Elevation 252-6 dated 5272007 PFP-RB-11 Torus North Elevation 213-9 dated 512003 PFP-RB-12 HPCI Pump Room Elevation 213-9 dated 5112003 PFPmiddotTB-5 Diesel Rooms Elevation 252-6 dated 512003 PFP-TB-6 Condenser Bay ampGround Floor EleVation 248-6 dated 5272007 PFP-TB-6A Turbine Building Walkway ampGround Floor Elevation 252-6 dated 5272007 PFP-TB-7 Condenser Bay Basement Elevation 228-6 dated 512003 Fire Hazards Analysis Rev 10 Fire Brigade Drill Scenario dated 422010
Section 1R07 Heat Sink Performance
Procedures OP 4126 Diesel Generator Surveillances Rev 84 OP 4126 Diesel Generator Surveillances Rev 84
Miscellaneous OP 412602 dated March 15 2010 OP 412602 dated May 52010 OP 412602 dated May 162010 OP 412602 dated May 192010
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
A-4 OP 412602 dated May 212010 Diesel Generator Test HX Tracking Report dated June 7 2010
Section 1R08 Inservice inspection
Procedures PDI-UT-1 Generic procedure for UT examination of ferritic pipe welds Rev B NE S069 IWI nondestructive examination procedure Rev 1 ENN-NDE-10 Visual examination (VT-3) for mechanical and structural condition ASME XI
Rev 2 ENN-NDE-929 Manual Ultrasonic examination of weld overlay on nozzles N5A and N5B
Rev 0 ENN-NDE-931 MT for ASME Section XI Rev 1 ENN-NDE-941 Liquid Penetrant Examination for ASME Section XI Rev 1 ENN-NDE-904 Manual Ultrasonic Examination of Ferritic Piping Welds (ASME XI) Rev 2 WPS BM-S1-B Weld Procedure Specification for manual gas tungsten arc (GTAW) of carbon
steel to stainless steel ASME III Rev 2 WPS BM-81-A Weld Procedure Specification for GTAW and shielded metal arc welding
(SMAW) of carbon steel to stainless steel Rev 2 WPS CS-11-A Weld Procedure Specification for manual GTAW and SMAW of carbon steel
Rev 3
Condition Reports 2010-01638 2010-01942 2010-02016 2010middot02011
Work Orders WO 00204945-01 WO 00205437-01 WO 00206415 WO 00204901-035 WO 00206012-01 WO 00205569-01 WO 00184964-06 WO 00178169-01
Drawings ISI-RPV-105 Main Steam piping lSI isometric line 1S MS-7B elbOW to elbow Rev 3 ISI-RPV-103 Nozzle to safe end butt weld at RPV Rev 3 ISI-RPV-105 R3 Main Steam piping lSI isometric line 18 MS-7B elbow to elbow Rev 3
Miscellaneous Miscellaneous UT PDI qualifications for personnel Rev B PQR 599 Procedure Qualification Record supporting WPS CS 11-A Rev 3 PQR 607Procedure Qualification Record supporting WPS BM-81-A Rev 2
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
A-5
PQR 606 Procedure Qualification Record supporting WPS BM 8i-A Rev 0 PQR 607 Procedure Qualification Record supporting WPS BM-81-A Rev 2 UT 28-904-016 Ultrasonic Manual Examination of weld MS7B-B6 Main Steam (MS) PT 28-941-001 Liquid Penetrant Test of weld of N10-SE nozzle to safe end reactor vessel PT 28-940002 Liquid Penetrant Test of weld HD39 in feedwater system MT 28-9-931-001 Magnetic Particle test of sweep weld RH17-S-349A VT-3 28-1003-012 Visual examination of torus support IIB-H1951-TSS10 54-151-363-05 Remote Underwater In Vessel Visual Inspection of Reactor Vessel Internals INR-IWI-VYR28-1 0-01 Steam Dryer Attachment Bracket indications INR-VYR28-01 INR-VYR28-02 INR-VYR28-03 INR VYR28-04 INR-VYR28-05 INR-VYR28-06 INR-VYR28-07 INR-VYR28-08 INR-VYR28-09 INR-VYR28-10 INR-VYR28-11
Section 1 R11 Licensed Operator Requalification Program
Miscellaneous lOR-28-101-4 Simulator Exercise Guide Rev 2
Section 1R12 Maintenance Effectiveness
Condition Reports 2009-02217 2010-03146 2010middot03159 2010-03192 2010-03194 2010middot03209 2010-03267 2010middot03268
Work Orders WO 00240019 WO 52250119
Miscellaneous Documents VY Maintenance Rule - State of the System Report Nuclear Boiler Report Period Ending
6302010 VY Maintenance Rule - State of the System Report Recire Flow Control Report Period Ending
6302010 System Health Report - Core Spray Second Quarter 2010 System Health Report - Residual Heat Removal First Quarter 2010
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
A-6
Section 1 Ri3 Maintenance Risk Assessments and Emergent Work Control
Procedures EN-WM-101 On Line Work Management Process Rev 4 EN-WM-104 On Line Risk Assessment Rev 0 AP 0172 Work Schedule Risk Management - On Une Rev 19 AP 0173 Work Schedule Risk Management - Outage Rev 24
Miscellaneous Documents Vermont Yankee RFO-28 Compensatory Measures and Contingency Plans for Station Battery
Maintenance Outage Outage Schedule Risk Assessment and Management Worksheet 042610 to 043010 Outage Schedule Risk Assessment and Management Worksheet 050310 to 050710 Outage Schedule Risk Assessment and Management Worksheet 051010 to 051410 Outage Schedule Risk Assessment and Management Worksheet 051710 to 052110
Section iRiS Operability Evaluations
Condition Reports 2010-01849 2010-01944
Procedures EN-OP-104 Operability Determinations Rev 3 ENN-NDE-905 Ultrasonic Thickness Examination Rev 1
Work Orders WO 051317
Section iRiS Plant Modifications
Condition Reports 2009-00238 2009-00500
Work Order WO 00219750-33 W000202414
Procedures EN-DC-115 Nuclear Change Format and content Rev 7 EN-Ll-100 Process Applicability Determination Rev 8 EN-ME-S-001-MULTI Engineering Leak Repair Evaluation Rev 3 OP 2179 Standby Fuel Pool Cooling Rev 13 OP 2184 Normal Fuel Pool Cooling System Rev 56 OP 4179 Standby Fuel Pool Cooling Surveillance Rev 20
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
A-7 Drawings VYC-3080 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 7 Service Water Inlet to Heat Exchanger on Tube Side Rev 0 VYI-SW-Part 9 Service Water Inlet to Heat Exchanger on Tube Side Rev 0
Miscellaneous Documents Engineering Change 16328 Engineering Change 16583 Vermont Yankee Service Water Systems Design Basis Documents Rev 29
Section 1R19 Post-Maintenance Testing
Condition Reports 2010-01975 2010-03351
Work Orders WO 00128140 WO 00175473 WO 00175475 WO 00175478 WO 00175480 WO 00175482 WO 00175484 WO 00178169 WO 00178170 WO 00184964 WO 00200894 WO 00216473 WO 00226982 WO 00224494 WO 00239979 WO 00240019 WO 00241468 WO 02697718 WO 52203938 WO 52217262 WO 52213384 WO 52213387 WO 52213389 WO 52213388 WO 52213387 WO 52213385 WO 52203938
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
A-8
Procedures OP 4101 KRPVO Operational Leakage Test Rev 50 OP 4126 Diesel Generator Surveillance Rev 84
Miscellaneous Documents Doble Testing Results for T -3-1 B dated 4292010 Tagout ICS-Valve-SR-14-20B Trouble shooting Plan for B EDG oscillations during surveillance dated June 22 2010
Section 1 R20 Refueling and Other Outage Activities
Condition Report 2010-02145 2010-02836
Procedures AP 0077 ~Barrier Control Process Rev 20 ARS 21003 CRP 9-5 Alarm Response Sheets Rev 9 OP 1100 Refuel Platform Operation Rev 38
OP 1101 Management of Refueling Activities and Fuel Movement Rev 48 OP 4100 ECCS integrated Automatic Initiation Test Rev 48
Miscellaneous Documents EC20757 Vermont Yankee Outage Work Schedule dated April 18 2010
Section 1R22 Surveillance Testing
Condition Report 2010-01977
Work Orders WO 52187881
Procedures OP 4100 ECCS Integrated Automatic Initiation Test Rev 48 OP 4101 RPV Operational System Leakage Test Rev 51 OP 4120 High Pressure Coolant Injection System Surveillance Rev 78 OP 4121 Reactor core Isolation Cooling System Surveillance Rev 81 EGST-4029 Primary Containment Integrated Leak Rate Testing Rev 1 EMST-BATT-421 0-22 Detailed Periodic Battery Visual Inspection Rev 0 EMST-BATT-4215-02 Main Station Battery Service Test Rev 0 OP 4124 Residual Heat Removal System Surveillance Rev 115 OP 4030 Leak Rate Test Rev 75 ARS 21002 CRP 9-4 Alarm Response Sheets Rev 9
Attachment
i
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
A-9
OP 4152 Equipment and Floor Drain Sump and Totalizer Surveillance Rev 43 OP 2152 Drywell Equipment and Floor Drains Rev 26
Miscellaneous Documents Excel Spreadsheet with required temperature points and valves (Filename VY Cooldown
4_25_10xls) BCT-2000 Battery Load Test Report dated 4282010 VY Memo regarding failure of MS-80C and MS-86D dated April 28 2010 VYLIC 09-02 Applicability of NRC Regulatory Information Summary 2009-02 Use of
Containment Atmosphere Gaseous Radioactivity Monitors as Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors to Vermont Yankee dated March 2 2009
Design Basis Document for Primary Containment Isolation System Rev 14 VYC-3055 Fill Rate and Pump-out Timer Setting for the Drywell Equipment and Floor Drain
Sumps Rev 0
Section 1 EP6 Emergency Preparedness Drill
Procedures EN-EP-308 Emergency Planning Critiques Rev 0 AP 0153 Operations Department Communications and Log Maintenance Rev 33 AP 0156 Notification of Significant Events Rev 65 AP 3125 Emergency Plan Classification and Action Level Scheme Rev 22 DP 0093 Emergency Planning Data Management Rev 14 OP 3540 Control Room Actions during an Emergency Rev 23 NE199-02 Regulatory Assessment Performance Indicator Guideline Rev 6
Section 2RS05 Radiation Monitoring Instrumentation
Procedures OP 4326 Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional
Calibration Rev 24 OP 4616 Liquid Process Radiation Monitors Rev 11 OP 4618 Source Calibration of AOG Process Radiation Monitoring System Rev 17 OP 4619 Plant Stack Monitors Rev 13 OP 4617 Calculation of Chemistry ContrOlled Set points Rev 22DP 4578 Calibration and
Use of REM-500 Neutron Survey Meters Rev 5 DP 4558 Calibration of Ion Chamber Survey Meters Rev 16 DP 4596 Operation and Calibration of the Merlin Gerin Telepole Rev 0 DP 4595 Operation and Calibration of the Merlin Gerin Amp 1001200 Rev 0 DP 4549 Calibration and Use of RM-14 and RM-20 Rev 20 DP 4591 Operation and Calibration of Aptec AMP-3e Rev 4 EN-RP-306 Calibration and Operation of Eberline PM-7 Rev 2 EN~RP-308 Operation and calibration of Gamma SCintillation Tool Monitors Rev 4 RP 4520 Source Calibration of Area Monitoring System Rev 27 OP 4506 Operation and Source Calibration of Reactor Building Ventilation Exhaust Air and
Containment Air Monitors Rev 16 Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
A-10
DP 4534 Calibration of Portable Air Samplers Rev 18 EN-RP-303 Source Checking of Radiation Protection Instrumentation Rev 2 EN-RP-113 Air Sampling Rev 7
Condition Reports 2008-04409 2009-01413 2010-01145
Audits and Self-Assessments QA-0206-2009-VY-1 Combined Chemistry Effluent and Environmental Monitoring August 10-27 2009
Calibration Records Instrument Type Serial Calibration Date
Portable Radiation Survey Instruments REM-500 1183 06012010 R020M 204 10132009 RM-25 132 12162009 Telepole 7063 02102010 AMP 100 7183 01292010 RM-20 6158 12162009
PCMPMfSAM APM-3e 204019 09022009 PM-7 536 04092010 SAM-11 516 09032009
Area Radiation MonitorsContamination Monitors ARM-8 09082009 CAM-17-500A 09012009
Air Sampler Flow Gauge Hi-Q High Vol 21128 04232010 Hi-Q Low Vol 14443 03092010
Section 40A1 Performance Indicator (PI) Verification
Miscellaneous Documents Reactor Coolant System Activity and Reactor Coolant System Leakage Reports from January
of 2009 to March 2010 Control room logs from January 2009 to March 2010
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
A-11
Section 40A2 Problem IdentificatiQ and Resolution
Procedures Condition Reports from November 2009 to May 2010
ADAMS ALARA AOG AP ARM ASME CAM CAP CFR CR CS DAC DRP DRS EC ECCS EDG EPD HCU HPCI IMC INR IPEEE lSI 1ST IWI LOR MT NCV NDE NEI NIST NRC NSTS ODCM OP PARS
LIST OF ACRONYMS
Agencywide Documents Access and Management System As Low As Reasonably Achievable Advanced Off Gas System Administrative Procedure Area Radiation Monitors American Society of Mechanical Engineers Continuous Air Monitors Corrective Action Program Code of Federal Regulations Condition Report Core Spray Derived Airborne Concentration Division of Reactor Projects Division of Reactor Safety Engineering Change Emergency Core Cooling System Emergency Diesel Generator Electronic Personal Dosimeter Hydraulic Control Unit High Pressure Coolant Injection Inspection Manual Chapter Indication Notification Report Individual Plant Examination for External Events Inservice Inspection In-Service Testing In-Vessel Visual Inspection Licensed Operator Requalification Magnetic Particle Test Non-cited Violation Non-Destructive Examination Nuclear Energy Institute National Institute of Standards and Technology Nuclear Regulatory Commission National Source Tracking System Offsite Dose Calculation Manual Operating Procedure Publicly Available Records System
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment
A-12
PCM POI PI PMT PRV PT RCIC RCS RFO RHR RHRSW RPV SAM SOP SSCs SW TS TSO UFSAR UE UT VT VY WBC WO WPS
Personnel Contamination Monitors Performance Demonstration Initiative Performance Indicator Post Maintenance Testing Reactor Pressure Vessel Liquid Penetrant Test Reactor Core Isolation Cooling Reactor Coolant System Refuel Outage Residual Heat Removal Residual Heal Removal Service Water Reactor Pressure Vessel Small Article Monitors Significance Determination Process Structures Systems and Components Service Water Technical Specification Transmission System Operator Updated Final Safety Analysis Report Unusual Event Ultrasonic Test Visual Test Vermont Yankee Whole Body Counter Work Order Weld Procedure Specification
Attachment