IR 05000458/2005003

From kanterella
Jump to navigation Jump to search
IR 05000458-05-003; on 04/01/2005 - 06/30/2005; River Bend Station; Fire Protection
ML052220409
Person / Time
Site: River Bend Entergy icon.png
Issue date: 08/10/2005
From: Webb Patricia Walker
NRC/RGN-IV/DRP/RPB-C
To: Hinnenkamp P
Entergy Operations
References
IR-05-003
Download: ML052220409 (37)
v • d • e


Text

ust 10, 2005

SUBJECT:

RIVER BEND STATION - NRC INTEGRATED INSPECTION REPORT 05000458/2005003)

Dear Mr. Hinnenkamp:

On June 30, 2005, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your River Bend Station. The enclosed integrated inspection report documents the inspection findings, which were discussed on June 23, 2005, with you and other members of your staff.

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

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

This report documents one NRC-identified finding of very low safety significance (Green). This finding was determined to involve violations of NRC requirements. However, because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating this finding as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy. If you contest this noncited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011; the Director, Office of Enforcement, U.S.

Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the River Bend Station facility.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Entergy Operations, Inc. -2-Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

/RA/

Wayne C. Walker, Chief Project Branch C Division of Reactor Projects Docket: 50-458 License: NPF-47

Enclosure:

NRC Inspection Report 05000458/2005003 w/Attachment: Supplemental Information

REGION IV==

Docket: 50-458 License: NPF-47 Report: 05000458/2005003 Licensee: Entergy Operations, Inc.

Facility: River Bend Station Location: 5485 U.S. Highway 61 St. Francisville, Louisiana Dates: April 1 through June 30, 2005 Inspectors: P. J. Alter, Senior Resident Inspector, Project Branch C M. O. Miller, Resident Inspector, Project Branch C R. E. Lantz, Sr. Emergency Preparedness Inspector, Operations Branch (Section 1EP4)

B. D. Baca, Health Physicist, Plant Support Branch (Section 2OS1)

L.. Ricketson, P.E., Senior Health Physicist, Plant Support Branch (Section 4OA5)

Approved By: W. C. Walker, Chief Project Branch C Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000458/2005003; 04/01/2005 - 06/30/2005; River Bend Station; Fire Protection

The report covered a 3-month period of routine baseline inspections by resident inspectors and announced baseline inspections by regional emergency planning and radiation protection inspectors. One Green noncited violation (NCV) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, Significance Determination Process. 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 3, dated July 2000.

NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green noncited violation of Attachment 4 to Facility Operating License NPF-47 for failure to inspect portable fire extinguishers within the required frequency. The inspectors identified a total of 24 portable fire extinguishers that had not received an inspection during the month of April 2005. The inspectors found 26 condition reports in the licensees corrective action program documenting missed inspections of portable fire extinguishers during the period from January 2000 through April 2005. Two of these condition reports were based on NRC-identified missed inspections of portable fire extinguishers in January and September of 2004.

The inspectors determined that this NRC-identified finding was more than minor because it was associated with the mitigating systems cornerstone attribute to protect against external factors, like fire, and because the finding affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process. The inspectors determined that the degradation rating was low because the fire extinguishers were expected to display nearly the same level of effectiveness and reliability as they would have had the fire extinguishers been inspected during the month of April 2005. Because this finding was assigned a low degradation rating, it was screened as having very low risk significance (Green). This finding also had crosscutting aspects associated with problem identification and resolution since the inspectors found 28 condition reports in the licensee's corrective action program documenting missed inspections of portable fire extinguishers during the period from January 2000 through April 2005. Because this Green finding was documented in the licensees corrective action program as CR-RBS-2005-01726, this violation is being treated as a noncited violation, consistent with Section VI. A of the NRC Enforcement Policy (Section 1R05).

Licensee-Identified Violations

Two violation of very low safety significance, which were identified by the licensee, have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and corrective actions are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status: The plant was operated at 100 percent power from April 1-14, 2004.

On April 15, 2005, power was reduced to 85 percent power to insert Control Rod 29-24 to suppress local power in the vicinity of an expected fuel leak. The reactor was returned to 100 percent on April 16, 2005. On May 21, 2005, power was reduced to 64 percent to perform a control rod pattern exchange. Return to full power was delayed in order to make repairs to a reactor feed pumps seals. The reactor was returned to 100 percent on May 26, 2005. On June 22, 2005, the reactor plant was shut down to make repairs to the main generator cooling water system. The reactor was restarted on June 30, 2005, and power ascension was in progress at the end of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness

1R01 Adverse Weather Protection

a. Inspection Scope

Hurricane Arlene Preparation During the week of June 6, 2005, the inspectors reviewed the licensees implementation of plant procedures to protect mitigating systems from the hurricane approaching the Louisiana coast from the Gulf of Mexico (one inspection sample). Specifically, the inspectors:

(1) verified that risk-significant structures, systems, and components (SSC)will remain functional when challenged by hurricanes;
(2) verified that plant features for operation of the ultimate heat sink during hurricane season are appropriate; and (3)evaluated implementation of the hurricane preparation procedures and compensatory measures for affected SSC before the onset of a hurricane. The inspectors reviewed the following procedures as part of this inspection:
  • Corporate Emergency Procedure ENS-EP-302, Severe Weather Response, Revision 3
  • Abnormal Operating Procedure AOP-0029, Severe Weather Operation, Revision 15

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

a. Inspection Scope

.1 The inspectors performed four partial system walkdowns (four inspection samples)

during this inspection period. On April 26, 2005, the inspectors walked down the Division I emergency diesel generator while the Division II emergency diesel generator was inoperable for planned maintenance. On April 30, 2005, the inspectors walked down Division I Switchgear ENS-SWG1B during a Division II maintenance outage. On May 4, 2005, the inspectors walked down the reactor core isolation cooling system during a Division II maintenance outage. On May 5, 2005, the inspectors walked down Division I standby service water system while Division II standby service water system was out of service for planned maintenance. In each case, the inspectors verified the correct valve and power alignments by comparing positions of valves, switches, and electrical power breakers to the system operating procedures (SOP) listed below:

  • SOP-0046, 4.16 KV System, Revision 26
  • SOP-0053, Standby Diesel Generators and Auxiliaries, Revision 40

.2 During the week of June 6, 2005, the inspectors conducted a complete system

walkdown (one inspection sample) of the risk-significant instrument air supply system, interviewed the system engineer, and reviewed the maintenance rule database. The inspectors verified

(1) proper valve and control switch alignments,
(2) power supply lineup, and
(3) that alarms and indications in the main control room were as specified in the following documents:
  • SOP-0022, Instrument Air System, Revision 39A
  • Updated Safety Analysis Report (USAR) Section 9.3.1.1.2, Instrument Air System
  • Instrument air maintenance rule report The inspectors also verified electrical power requirements, labeling, and associated support systems' status. Operating air compressors were examined to ensure that any noticeable vibration was not excessive and that air compressors were properly ventilated. The walkdown also included evaluation of system piping and supports to ensure piping and supports did not show evidence of mechanical degradation and component foundations were not degraded.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

a. Inspection Scope

.1 The inspectors walked down accessible portions of the seven areas (seven inspection

samples) described below to assess:

(1) the licensees control of transient combustible material and ignition sources;
(2) fire detection and suppression capabilities;
(3) manual firefighting equipment and capability;
(4) the condition of passive fire protection features, such as, electrical raceway fire barrier systems, fire doors, and fire barrier penetrations; and
(5) any related compensatory measures. The areas inspected were:
  • Control Building, Elevation 70 foot, heating, ventilation, and air conditioning Room 1A for Division I safety-related equipment, Fire Area C-4, on April 30, 2005
  • Control Building, Elevation 70 foot, heating, ventilation, and air conditioning Room 1B for Division II safety-related equipment, Fire Area C-4, on April 30, 2005
  • Control Building, Elevation 70 foot, Cable Area C for Division I safety-related cable runs, Fire Area C-5, on April 30, 2005
  • Reactor Building, Elevation 78 foot, Low Pressure Core Spray Pump Room, Fire Area AB-6/Z-1, on May 5, 2005
  • Auxiliary Building, Elevation 95 foot, Residual Heat Removal Train A Room, Fire Area AB-5, on June 8, 2005 The inspectors reviewed the following documents during the fire protection inspections:
  • Pre-Fire Plan/Strategy Book
  • USAR Section 9A.2, Fire Hazards Analysis

b. Findings

Failure to Inspect Portable Fire Extinguishers Within the Required Frequency

Introduction.

The inspectors identified a noncited violation of very low safety significance (Green) for the licensees failure to inspect portable fire extinguishers within the required frequency.

Description.

The inspectors identified a total of 24 portable fire extinguishers that had not received an inspection during the month of April 2005. These portable fire extinguishers were located in the auxiliary, control, and diesel generator buildings, in areas of safety-related SSC. The licensee initiated Condition Report (CR)

CR-RBS-2005-01726 on May 4, 2005.

The inspectors found that CR-RBS-2004-0051 and CR-RBS-2004-2645 had been initiated in January and September of 2004, respectively, in response to NRC-identified missed inspections of portable fire extinguishers. The inspectors found 26 additional CRs written by station personnel that documented missed inspections of portable fire extinguishers during the period from January 2000 through April 2005. These CRs documented missed inspections of portable fire extinguishers located in the containment, fuel building, normal switchgear building, and other areas of the station.

The inspectors noted USAR Section 9.5.1.4, Fire Protection System Testing Program, specified the frequency of inspection of portable fire extinguishers as once every 31 days.

Analysis.

Using Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix B, the inspectors identified a licensee performance deficiency when they failed to inspect portable fire extinguishers critical to safety within the required frequency. The inspectors also determined that there were multiple examples of this performance deficiency. The inspectors found that this performance deficiency was reasonably within the licensees ability to foresee and correct and could have been prevented.

The inspectors determined that this NRC-identified finding was more than minor because it was associated with the mitigating systems cornerstone attribute to protect against external factors, like fire, and because the finding affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

The inspectors analyzed the finding using IMC 0609, Appendix F, Fire Protection Significance Determination Process. The inspectors determined that the degradation rating associated with the failure to perform monthly inspections of fire extinguishers was low because the fire extinguishers were expected to display nearly the same level of effectiveness and reliability as they would have, had the fire extinguishers been inspected during the month of April 2005. Since the finding was assigned a low degradation rating, it was screened as having very low risk significance (Green). This finding also had crosscutting aspects associated with problem identification and resolution since the inspectors found 28 condition reports in the licensee's corrective action program documenting missed inspections of portable fire extinguishers during the period from January 2000 through April 2005.

Enforcement.

Facility Operating License NPF-47, Attachment 4, "Fire Protection Program Requirements," License Condition 1, states, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the USAR. The River Bend Station fire protection test program specifies the frequency of inspection of portable fire extinguishers as every 31 days. Contrary to the above, 24 portable fire extinguishers in the auxiliary, control, and diesel generator buildings, in areas of safety-related SSC, were not inspected within 31 days of the previous inspection. Station personnel subsequently completed the inspections of the portable fire extinguishers in these areas. None of the portable fire extinguishers required maintenance or replacement.

Failure to perform monthly inspections of fire extinguishers as specified by the fire protection system test plan is a violation of License Condition 1 of Attachment 4 to Facility Operating License NPF-47. Because this violation was of very low safety significance (Green) and was documented in the licensees corrective action program as CR-RBS-2005-01726 and -02269, this violation was treated as a noncited violation (NCV) consistent with Section VI.A of the Enforcement Policy (NCV 05000458/2005003-01).

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors conducted an annual external flooding assessment (one inspection sample) to verify that the licensees flooding mitigation plans and equipment were consistent with design requirements and risk analysis assumptions. The inspectors interviewed station environmental personnel and conducted walkdowns of the onsite drainage systems on June 6, 2005. Specifically, the inspectors examined:

(1) culverts for blockage,
(2) the west creek fabriform channel for silt buildup and excessive vegetation growth,
(3) the east creek for excessive vegetation growth, and
(4) drainage ditches for excessive vegetation growth. The inspectors reviewed the following documents during the inspection as the bases for acceptability of the plant configuration.
  • River Bend Station individual plant examination of external events
  • USAR Section 3.4.1, Flood Protection
  • USAR Section 2.4.2.3, Effects of Local Intense Precipitation

b. Findings

No findings of significance were identified.

1R07 Heat Sink Performance

a. Inspection Scope

The inspectors reviewed the expected performance of residual heat removal system Heat Exchangers E12-EB001A and C that transfer heat directly to the standby service water system (one inspection sample). The inspectors verified that:

(1) differences between testing conditions and design conditions were appropriately considered,
(2) heat exchanger tests/inspection results were appropriately categorized against preestablished engineered acceptance criteria and were acceptable,
(3) the number of tubes plugged didnt affect the heat exchangers operability,
(4) frequency of tests/inspections was sufficient to detect degradation due to fouling prior to reduction of heat removal capabilities below design basis values,
(5) tests did consider test instrument inaccuracies and differences, and
(6) the licensee had developed acceptance criteria for its biofouling controls. The inspectors evaluated their observations against the requirements of the following documents:
  • USAR Table 6.2-9, Energy Balance for Recirculation Line Break, Revision 14
  • File 0221.432-000-019B, RHR Heat Exchanger Calculated Performance, dated January 10, 1990
  • File 0221.435-000-006B, RHR System Design Specification, Revision 2
  • Plant Engineering Procedure PEP-0239, Performance Monitoring Program for Residual Heat Removal Heat Exchangers E12-EB001A and E12-EB001C, conducted on March 15, 2005

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification

a. Inspection Scope

The inspectors observed three operator requalification simulator training evaluations (three inspection samples). On April 29, 2005, the inspectors observed simulator training evaluation of an operating crew as part of the operator requalification training program to assess licensed operator performance and the training evaluators critique.

On May 20, 2005, the inspectors observed simulator training evaluation of an operations staff training crew as part of the operator requalification training program to assess licensed operator performance and the training evaluators critique. On June 10, 2005, the inspectors observed simulator training evaluation of an operating crew as part of the operator requalification training program to assess licensed operator performance and the training evaluators critique. Emphasis was placed on observing weekly evaluation exercises or annual examination of high risk, licensed operator actions, operator activities associated with the emergency plan, and lessons learned from industry and plant experiences. In addition, the inspectors compared simulator control panel configurations with the actual control room panels for consistency. The simulator training evaluation scenarios observed were:

  • RSMS-OPS-509, SRV Tailpipe Steam Leak Inside the Drywell, Revision 3
  • RSMS-OPS-513, Single Rod Scram, Recirculation Line Break, LOCA, Revision 2
  • RSMS-OPS-509, SRV Tailpipe Steam Leak Inside The Drywell, Revision 3

f. Findings

No findings of significance were identified.

1R12 Maintenance Implementation

a. Inspection Scope

The inspectors reviewed two instrument air system performance problems (two inspection samples) to assess the effectiveness of the licensees maintenance efforts for SSC within the scope of the maintenance rule program. The inspectors verified licensees maintenance effectiveness by:

(1) verifying the licensees handling of SSC performance or condition problems,
(2) verifying the licensees handling of degraded SSC functional performance or condition,
(3) evaluating the role of work practices and common cause problems, and
(4) evaluating the licensees handling of the SSC issues being reviewed under the requirements of the maintenance rule (10 CFR 50.65);10 CFR Part 50, Appendix B; and the Technical Specifications.
  • CR-RBS-2004-04369, Instrument Air Compressor IAS-C2A fails to maintain system pressure, reviewed on June 7, 2004
  • CR-RBS-2004-04442, repeat failure of Instrument Air Compressor IAS-C2A to maintain system pressure, reviewed on June 9, 2005 The following documents were reviewed as part of this inspection:
  • NUMARC 93-01, Revision 2, Nuclear Energy Institute Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants
  • Maintenance rule function list
  • Maintenance rule performance criteria list

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation

a. Inspection Scope

The inspectors reviewed five maintenance activities (five inspection samples) to verify the performance of assessments of plant risk related to planned and emergent maintenance work activities. The inspectors verified:

(1) the adequacy of the risk assessments and the accuracy and completeness of the information considered, (2)management of the resultant risk and implementation of work controls and risk management actions, and
(3) effective control of emergent work, including prompt reassessment of resultant plant risk.

.1 Risk Assessment and Management of Risk

On a routine basis, the inspectors verified performance of risk assessments, in accordance with Administrative Procedure ADM-096, Risk Management Program Implementation and On-Line Maintenance Risk Assessment, Revision 4, for planned maintenance activities and emergent work involving SSC within the scope of the maintenance rule. Specific work activities evaluated included planned and emergent work for the weeks of:

  • May 30, 2005, Nondivisional work week, diesel-driven Instrument Air Compressor IAS-C4 corrective maintenance

.2 Emergent Work Control

During emergent work, the inspectors verified that the licensee took actions to minimize the probability of initiating events, maintained the functional capability of mitigating systems, and maintained barrier integrity. The inspectors also reviewed the emergent work activities to ensure the plant was not placed in an unacceptable configuration. The three emergent work activities evaluated were:

  • Condensate filtration system processor replacement on April 6, 2005
  • Division I control building air conditioning and control room fresh air outage on April 11, 2005
  • Preferred station service Transformer RTX-XSR1F repairs on April 20-21, 2005

b. Findings

No findings of significance were identified.

1R14 Personnel Performance During Nonroutine Plant Evolutions

a. Inspection Scope

Swap Division II Switchgear Power Source from Offsite Power to Division II Emergency Diesel The inspectors observed operations personnel performance when the Division II switchgear power supply was swapped from an offsite source to the Division II emergency diesel generator on April 20, 2005 (one inspection sample). The inspectors observed the operational safety review committee meeting and their approval of the evolution. During the inspection, the inspectors reviewed the briefing papers for this infrequently performed task and evolution and attended the prejob briefing given in the control room. The inspectors also reviewed the following documents used by the operators during the evolution:

C RBS Tagout, 311-RTX-XSR1F, dated April 19, 2005 C STP-000-0102, Power Distribution Alignment Check, Revision 4 C SOP-0045, 13.8 KV System, Revision 15 C SOP-0053, Standby Diesel Generator and Auxiliaries, Revision 40 C SOP-0055, Main and Station Transformers, Revision 12

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed four operability determinations (four inspection samples)selected on the basis of risk insights. The selected samples are addressed in the CRs listed below. The inspectors assessed:

(1) the accuracy of the evaluations;
(2) the use and control of compensatory measures, if needed; and
(3) compliance with Technical Specifications, the Technical Requirements Manual, the USAR, and other associated design-basis documents. The inspectors review included a verification that the operability determinations were made as specified by Procedure RBNP-078, Operability Determinations, Revision 7. The operability evaluations reviewed were associated with:
  • CR-RBS-2005-01298, fire protection Pump FPW-P1A battery replacement, reviewed on April 19, 2005
  • CR-RBS-2005-01434, Division I hydrogen ignitor supply Breaker EHS-MCC2A BKR 3A tripped during performance of STP-254-1401, reviewed on May 17, 2005

f. Findings

No findings of significance were identified.

1R16 Operator Workarounds

a. Inspection Scope

An operator workaround is defined as a degraded or nonconforming condition that complicates the operation of plant equipment and is compensated for by operator action. During the week of June 16, 2005, the inspectors reviewed the cumulative effect of the existing operator workarounds (one inspection sample) and contingency plans that existed prior to Planned Outage 05-02. The inspectors concentrated on the effect the workarounds have on:

(1) the reliability, availability, and potential for misoperation of any mitigating system;
(2) whether they could increase the frequency of an initiating event; and
(3) their effect on the operation of multiple mitigating systems. In addition, the inspectors reviewed the cumulative effects the operator workarounds have on the ability of the operators to respond in a correct and timely manner to plant transients and accidents. The procedures and other documents reviewed by the inspectors during this inspection are listed in the attachment to this report.

b. Findings

No findings of significance were identified.

1R17 Permanent Plant Modifications

a. Inspection Scope

The inspectors selected a total of two samples for this inspection.

The inspectors selected a permanent plant modification that was installed on the emergency response information system (ERIS) computer. The modification gave the ERIS computer the capability to calculate core thermal power using a heat balance.

This capability provided a backup indication of core thermal power should the plant process computer malfunction.

The inspectors selected another permanent plant modification for this sample that was installed in the turbine control system. During two previous turbine control valve tests, a false overspeed signal was developed in the speed control unit and that overspeed signal was sent to the turbine valve control unit. This resulted in a turbine trip and reactor scram both times. This modification installed a toggle switch between the speed control unit and the turbine valve control unit in the turbine control system. This switch was to be used only during main turbine control valve testing to isolate false speed error signals, preventing unnecessary turbine trips and reactor scrams.

The inspectors verified that the modification preparation, staging, and implementation did not impair emergency or abnormal procedure actions, key safety functions, or operator response to the loss of key safety functions. The inspectors verified that postmodification testing maintained the plant in a safe configuration during testing. The licensees operability declaration was confirmed by verifying that unintended system interactions did not occur, verifying SSC and software performance characteristics met the design basis, validating the appropriateness of modification design assumptions, and demonstrating that the modification test acceptance criteria were met. The inspectors verified that affected operations procedures and training were identified and necessary changes were made. The inspectors also verified that the plant simulator updates were scheduled for implementation. The documents reviewed by the inspectors during this inspection are listed in the attachment.

b. Findings

No findings of significance were identified.

1R19 Postmaintenance Testing

a. Inspection Scope

The inspectors reviewed five work orders (WO) to ensure that testing activities were adequate to verify system operability and functional capability (five inspection samples).

The inspectors:

(1) identified the safety function(s) for each system by reviewing applicable licensing basis and/or design-basis documents;
(2) reviewed each maintenance activity to identify which maintenance function(s) may have been affected;
(3) reviewed each test procedure to verify that the procedure adequately tested the safety function(s) that may have been affected by the maintenance activity;
(4) ensured that the acceptance criteria in the procedure were consistent with information in the applicable licensing basis and/or design-basis documents; and
(5) identified that the procedure was properly reviewed and approved. The five WOs inspected are listed below:

C WO 63742, diesel fire water Pump FPW-P1A operational test performed on April 6, 2005 C WO 51006692, diesel fire water Pump FPW-P1A battery voltage and electrolyte checks performed on April 6, 2005 C WO 63742 01, diesel fire water Pump FPW-P1A battery specific gravity checks performed on April 6, 2005 C WO 64617 04, replace preferred station service Transformer RTX-XSR1F secondary side lightning arrester cable, performed on April 21, 2005 C WO 64463 05, replace Division I hydrogen ignitors Supply Breaker EHS-MCC2A-BKR3A, performed on April 25, 2005

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors verified, by witnessing and reviewing test data, that four risk-significant system and component surveillance tests (four inspection samples) met Technical Specification, USAR, and procedure requirements. The inspectors ensured that surveillance tests demonstrated that the systems were capable of performing their intended safety functions and provided operational readiness. The inspectors specifically:

(1) evaluated surveillance tests for preconditioning;
(2) evaluated clear acceptance criteria, range, accuracy, and current calibration of test equipment; and
(3) verified that equipment was properly restored at the completion of the testing. The inspectors observed and reviewed the following surveillance tests and surveillance test procedures (STP):

C STP-251-3205, "Diesel Fire Pump Operational Text," Revision 12, performed on April 4, 2005 C STP-209-6310, RCIC Quarterly Pump and Valve Operability Test, Revision 26, performed on May 10, 2005 C STP-511-4528, RMS - Reactor Coolant System Leakage Drywell Atmosphere Radioactivity Channel Functional Test RMS-RE112, Revision 9B, performed on May 23, 2005 C Technical Specification required Reactor Coolant System Identified and Total Leakage Calculations:

STP-000-001, "Daily Operator Logs, Revision 47 and SOP-0104, Floor and Equipment Drains System, Revision 26, performed during June 2005

b. Findings

No findings of significance were identified.

Cornerstone: Emergency Preparedness

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

The inspector reviewed the River Bend Station Emergency Plan, Revision 27. This revision corrected the descriptions of the roles of the Louisiana Department of Environmental Quality to be consistent with the Louisiana State Emergency Plan. The revision also added the corporate emergency preparedness training procedure to the list of emergency plan implementing procedures and made other editorial changes.

The revision was compared to the previous revisions, to the criteria of NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, and to the requirements of 10 CFR 50.47(b) to determine if the licensee adequately implemented the emergency plan change process described in 10 CFR 50.54(q).

The inspector completed one sample during the inspection.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors observed the two emergency preparedness simulator training exercises (two inspection samples) conducted on April 29 and May 20, 2005, to identify any weaknesses and deficiencies in classification and notification activities. The inspectors also evaluated the licensee's assessment of classification and notification during the training exercise in accordance with plant procedures and NRC guidelines. The following procedures and documents were reviewed during the assessment:

  • EIP-2-001, Classification of Emergencies, Revision 12
  • EIP-2-002, Classification Actions, Revision 24
  • EIP-2-006, Notifications, Revision 31
  • EIP-2-026, Evacuation, Personnel Accountability and Search and Rescue, Revision 16

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety [OS]

2OS1 Access Control to Radiologically Significant Areas

a. Inspection Scope

This area was inspected to assess the licensees performance in implementing physical and administrative controls for airborne radioactivity areas, radiation areas, high radiation areas, and worker adherence to these controls. The inspector used the requirements in 10 CFR Part 20, the Technical Specifications, and the licensees procedures required by Technical Specifications as criteria for determining compliance.

During the inspection, the inspector interviewed the radiation protection manager, radiation protection supervisors, and radiation workers. The inspector performed independent radiation dose rate measurements and reviewed the following items:

  • Controls (surveys, posting, and barricades) of radiation, high radiation, or airborne radioactivity areas of the reactor, fuel handling, and radwaste buildings
  • Radiation work permit, procedure and engineering controls, and air sampler locations
  • Conformity of electronic personal dosimeter alarm setpoints with survey indications and plant policy; workers knowledge of required actions when their electronic personnel dosimeter noticeably malfunctions or alarms.
  • Barrier integrity and performance of engineering controls in two potential airborne radioactivity areas
  • Physical and programmatic controls for highly activated or contaminated materials (nonfuel) stored within spent fuel and other storage pools.
  • Self-assessments and audits related to the access control program since the last inspection
  • Corrective action documents related to access controls
  • Licensee actions in cases of repetitive deficiencies or significant individual deficiencies
  • Radiation work permit briefings and worker instructions
  • Adequacy of radiological controls such as, required surveys, radiation protection job coverage, and contamination controls during job performance
  • Dosimetry placement in high radiation work areas with significant dose rate gradients
  • Controls for special areas that have the potential to become very high radiation areas during certain plant operations
  • Radiation worker and radiation protection technician performance with respect to radiation protection work requirements Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
  • Adequacy of the licensees internal dose assessment for any actual internal exposure greater than 50 millirem CEDE
  • Licensee event reports and special reports related to the access control program since the last inspection The inspector completed 21 of the required 21 samples.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator Verification

a. Inspection Scope

The inspector sampled licensee submittals for the performance indicators listed below for the period from 2004 Second Quarter through 2005 First Quarter. To verify the accuracy of the performance indicator data reported during that period, performance indicator definitions and guidance contained in Nuclear Energy Institute 99-02, "Regulatory Assessment Indicator Guideline," Revision 3, were used to verify the basis in reporting for each data element.

Occupational Radiation Safety Cornerstone

  • Occupational Exposure Control Effectiveness Peformance Indicator Licensee records reviewed included corrective action documentation that identified occurrences of locked high radiation areas (as defined in the licensees Technical Specifications), very high radiation areas (as defined in 10 CFR 20.1003), and unplanned personnel exposures (as defined in Nuclear Energy Institute 99-02).

Additional records reviewed included as low as is reasonably achievable (ALARA)records and whole body counts of selected individual exposures. The inspector interviewed licensee personnel that were accountable for collecting and evaluating the performance indicator data. In addition, the inspector toured plant areas to verify that high radiation, locked high radiation, and very high radiation areas were properly controlled.

Public Radiation Safety Cornerstone

  • Radiological Effluent Technical Specification/Offsite Dose Calculation Manual Radiological Effluent Occurrences Licensee records reviewed included corrective action documentation that identified occurrences for liquid or gaseous effluent releases that exceeded performance indicator thresholds and those reported to the NRC. The inspector interviewed licensee personnel that were accountable for collecting and evaluating the performance indicator data.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Failure to translate USAR requirements into procedures for the emergency diesel

generator ventilation system

a. Inspection Scope

On June 6, 2005, the inspectors selected one issue for followup inspection. That issue was a problem identified in CR-RBS-2004-02634 for the emergency diesel generator ventilation system. This sample was chosen for an in-depth review to verify that the licensee had taken appropriate corrective actions to resolve this problem.

USAR Section 9.4.5.2 required switching to the redundant diesel generator set upon failure of the operating ventilation supply or exhaust fans. The inspectors found that these operational requirements were not contained in the procedures used by operations to operate and monitor the diesel generators.

The inspectors evaluated CR-RBS-2004-02634 against the requirements of the licensees corrective action program as described in nuclear management manual Procedure LI-102, Corrective Action Process, Revision1 and 10 CFR Part 50, Appendix B, Criterion XVI.

b. Findings and Observations

There were no findings of significance identified. The inspectors found several minor instances of noncompliance with Procedure LI-102. For example, there was an approved corrective action extension that had incomplete documentation.

In addition, the licensee found several missed opportunities to identify this problem.

Self-assessment and review activities that had been conducted, prior to the date that the problem was identified, could have identified this problem, but those activities were unsuccessful.

The inspectors verified that the corrective actions taken were appropriate, and also timely, relative to the significance of the identified problem; therefore, no violations of regulatory requirements or findings were identified.

.2 Semiannual Trend Review

a. Inspection Scope

The inspectors performed a 6-month review of the licensees corrective action program and associated documents to identify trends that could indicate the existence of a more safety-significant problem. The inspector's review was focused on trends identified during daily inspector screening of CRs and concentrated on repetitive issues, licensee trending efforts, and human performance problems. The inspector's review covered the 6-month period from January through June of 2005.

The inspectors chose 171 CRs related to the work planning process to assess the licensees tracking and trending program for identifying repetitive issues and formulating plans to correct longstanding problems. The inspectors determined that failure to complete timely and effective preventive and corrective maintenance could directly effect the availability and performance of risk important safety-related systems.

b. Findings and Observations

There were no findings of significance identified. The inspectors did identify a number of repetitive performance deficiencies with regard to the work planning process as described in licencee Procedures EN-WM-101, On-Line Work Management Process, Revision 0, and EN-WM-105, [Work] Planning, Revision 0. Specifically, the inspectors found that:

(1) work package content was often incomplete, with errors in reference documents, identification of required replacement parts, incomplete and unclear work instructions, and incomplete component and operability impact statements;
(2) failure to properly stage required measurement and test equipment;
(3) unavailability of required measurement and testing equipment;
(4) failure to arrange for support activities from other departments such as, required scaffolding, engineering and radiation protection monitoring and required equipment alignment, and protective tagging for work activities.

The inspectors felt that the maintenance and planning departments had properly identified the repetitive nature of these deficiencies and had proposed programmatic and organizational changes to improve performance in these areas.

.3 Cross-Reference to Problem Identification and Resolution Findings Documented

Elsewhere Section 1RO5 describes a problem identification and resolution crosscutting issue regarding repetitive failures to inspect portable fire extinguishers at the specified frequency.

.4 Access Controls to Radiologically Significant Areas

a. Inspection Scope

Section 2OS1 evaluated the effectiveness of the licensee's problem identification and resolution processes regarding access controls to radiologically significant areas and radiation worker practices. The inspector reviewed corrective action documents for root cause/apparent cause analysis against the licensees problem identification and resolution process.

b. Findings and Observations

No findings of significance were identified.

4OA5 Other Activities

.1 Temporary Instruction 2515/163, "Operational Readiness of Offsite Power

a. Inspection Scope

The inspectors reviewed the licensee's operating procedures that the control room operators use to assure the operability of offsite power for the following attributes:

  • Required operator actions, when notified that the offsite power posttrip voltage would not be acceptable for the continued operation of safety-related loads without transferring to the onsite power supply;
  • Operator compensatory actions, when the transmission system operator is not able to predict the posttrip voltage at the plant;
  • Required notifications for an inoperable offsite power system when informed by the transmission system operator, when an actual degraded voltage condition is identified;
  • Steps required for operators to recover offsite power within the station blackout coping time.

The inspectors reviewed the licensee's procedures to ensure they have the following attributes necessary for compliance with the maintenance rule, 10 CFR 50.65(a)(4):

  • Direct the plant staff to perform grid reliability evaluations as part of the maintenance risk assessments before taking a risk-significant piece of equipment out of service for maintenance activities;
  • Direct the plant staff to ensure that the current status of the offsite power system is included in the risk management and compensatory actions to reduce risk when performing risk-significant maintenance activities or when loss of offsite power or station blackout mitigating equipment is taken out of service;
  • Direct the control room staff to address degrading grid conditions that may emerge during a maintenance activity;
  • Direct the plant staff to notify the transmission system operator of risk changes during plant maintenance activities.

The procedures and documents reviewed during the inspection are listed in the attachment.

b. Findings

No findings of significance were identified.

.2 Temporary Instruction 2515/161, "Transportation of Reactor Control Rod Drives in

Type A Packages"

a. Inspection Scope

This area was inspected to verify that the licensee's radioactive material transportation program complies with specific requirements of 10 CFR Parts 20, 71, and Department of Transportation regulations contained in 49 CFR Part 173. The inspector interviewed licensee personnel and determined that the licensee had undergone refueling/defueling activities between January 1, 2002, and present, but it had not shipped irradiated control rod drives in Department of Transportation Specification 7A Type A packages.

b. Findings and Observations

No findings of significance were identified.

4OA6 Meetings, Including Exit

Exit Meetings On May 12, 2005, the inspector discussed the inspection findings of the emergency preparedness inspection with Mr. J. Leavines, Manager, Emergency Planning. The inspector verified that no proprietary information was provided during the inspection.

On May 19, 2005, the inspector discussed the inspection findings with Mr. M. Boyle, Manager, Radiation Protection. The inspector verified that no proprietary information was provided during the inspection.

The inspectors presented the inspection results to Mr. Paul Hinnenkamp, Vice President Operations, and other members of licensee management at the conclusion of the inspection on June 23, 2005. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On June 24, 2005, the inspector presented the access controls inspection results to Mr. D. Vinci, General Plant Manager, and other members of his staff who acknowledged the findings. The inspector confirmed that proprietary information was not provided or examined during the inspection.

4OA7 Licensee-Identified Violations

The following findings of very low safety significance were identified by the licensee and were violations of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV.

  • Technical Specification 5.4.1.a requires that written procedures be established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A, Section 1.c, requires procedures for equipment control. Procedure EN-WM0-101, On-line Work Management Process, Revision 0, required that tagging requests be submitted 5 week prior to the start of work and EN-WM-105, [Work] Planning, Revision 0, required that each task within a work package have a component impact statement for operators to evaluate the operational impact of the entire work package. Contrary to the above, WO 50971459 Task 7, for electricians to deenergize Division I instrument air supply to control building air damper accumulator Valve IAS-SOV36A, did not have a component impact statement and no electrical tagging request for Valve IAS-SOV36A was submitted prior to the start of work. As a result, Division I control room fresh air was removed from service for 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> and no work was performed.

This event was entered into the licensees corrective action program as CR-RBS-2005-1400. Based on a review of IMC 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations, the inspectors determined that the finding was of very low safety significance (Green) because it represented only the loss of redundancy for the control room fresh air system and did not effect the functionality of the control room envelope.

  • Technical Specification 7.5.2 states, in part, that areas with radiation levels equal to or greater than 1000 millirem per hour shall be provided with locked or continuously guarded doors to prevent unauthorized entry. Contrary to this requirement, the reactor water cleanup demineralizer cubicle area was not locked or guarded when it became a locked high radiation area some time between April 16-18, 2005. Operations returned the reactor water cleanup system to service on April 16, 2005, and a radiation protection technician found increased dose rates when performing a prejob survey of the cubicle on April 18, 2005. The highest general area dose rate for the work area was 2800 millirem per hour. This finding was identified in the licensees corrective action program as CR-RBS-2005-1475 and CR-RBS-2005-1480. This finding is of very low safety significance because it did not involve:
(1) ALARA planning and controls,
(2) an overexposure,
(3) a substantial potential for overexposure, or
(4) an impaired ability to assess dose.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

L. Ballard, Manager, Quality Programs
M. Boyle, Manager, Radiation Protection
D. Burnett, Superintendent, Chemistry
C. Bush, Manager, Outage
J. Clark, Assistant Operations Manager - Training
T. Coleman, Manager, Planning and Scheduling/Outage
M. Davis, Supervisor, Radiation Control
C. Forpahl, Manager, Corrective Actions
T. Gates, Manager, Equipment Reliability
H. Goodman, Acting Director, Engineering
P. Hinnenkamp, Vice President - Operations
B. Houston, Manager, Plant Maintenance
K. Huffstatler, Technical Specialist, Licensing
G. Huston, Assistant Operations Manager - Shift
A. James, Superintendent, Plant Security
R. King, Director, Nuclear Safety Assurance
J. Leavines, Manager, Emergency Planning
D. Lorfing, Manager, Licensing
W. Mashburn, Manager, Programs and Components
D. Myers, Senior Health Physics/Chemistry Specialist, Radiation Protection
P. Russell, Manager, System Engineering
C. Stafford, Manager, Operations
W. Trudell, Manager, Training and Development
D. Vinci, General Manager - Plant Operations

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000458/2005003-01 NCV Failure to Inspect Portable Fire Extinguishers Within the Required Frequency

LIST OF DOCUMENTS REVIEWED

Retrieved from "https://kanterella.com/w/index.php?title=IR_05000458/2005003&oldid=2287058"