IR 05000458/2009003

IR 05000458-09-003; on 04/01/2009 - 06/30/2009; River Bend Station, Integrated Resident and Regional Report; Drill Evaluation

ML092180817
Person / Time
Site:	River Bend
Issue date:	08/06/2009
From:	Geoffrey Miller NRC/RGN-IV/DRP/RPB-C
To:	Mike Perito Entergy Operations
References
IR-09-003
Download: ML092180817 (33)

Text

August 6, 2009

Michael Perito Vice President, Operations Entergy Operations, Inc.

River Bend Station 5485 U.S. Highway 61N St. Francisville, LA 70775

Subject:

RIVER BEND STATION - NRC INTEGRATED INSPECTION REPORT 05000458/2009003

Dear Mr. Perito:

On June 30, 2009, 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 July 8, 2009, 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 a violation of NRC requirements. However, because of the very low safety significance and because it is entered into your corrective action program, the NRC is treating this finding as a noncited violation, consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the violation or the significance of the 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, D.C. 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 E. Lamar Blvd, Suite 400, Arlington, Texas, 76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the River Bend Station facility. In addition, if you disagree with the characterization of any 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 IV, and the NRC Resident Inspector at River Bend Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

In accordance with 10 CFR 2.390 of the NRC's Rules of Practice, a copy of this letter, and its enclosure, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (ADAMS).

UNITED STATES NUCLEAR REGULATORY COMMISSION R E GI ON I V 612 EAST LAMAR BLVD, SUITE 400 ARLINGTON, TEXAS 76011-4125

Entergy Operations, Inc.

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

Sincerely,

/RA/ DLProulx for Geoffrey B. Miller, Chief Project Branch C Division of Reactor Projects Docket: 50-458 License: NPF-47

Enclosure:

NRC Inspection Report 05000458/2009003 w/Attachment: Supplemental Information

REGION IV==

Docket:

05000458 License:

NPF-47 Report:

05000458/2009003 Licensee:

Entergy Operations, Inc.

Facility:

River Bend Station Location:

5485 U.S. Highway 61N St. Francisville, LA Dates:

April 1 through June 30, 2009 Inspectors:

G. Larkin, Senior Resident Inspector C. Norton, Resident Inspector P. Elkmann, Senior Emergency Preparedness Inspector W. Sifre, Senior Reactor Inspector G. George, Reactor Inspector I. Anchondo, Reactor Inspector Approved By:

Geoffrey B. Miller, Chief, Project Branch C Division of Reactor Projects

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Enclosure

SUMMARY OF FINDINGS

IR 05000458/2009003; 04/01/2009 - 06/30/2009; River Bend Station, Integrated Resident and

Regional Report; Drill Evaluation

The report covered a 3-month period of inspection by resident inspectors and announced baseline inspections by region based inspectors. One Green noncited violation was identified.

The significance of most findings is indicated by their color (Green, White, Yellow, or 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 NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 4, dated December 2006.

Cornerstone: Emergency Preparedness

Green.

The inspectors identified a violation of 10 CFR 50.47(b)(14) for failure to identify and critique a nonrisk significant planning standard weakness demonstrated during a site emergency preparedness drill. Specifically, the licensee demonstrated a weakness in controlling radiological exposures for emergency workers during an emergency, without key emergency response organization decision maker consideration or input, when simulated emergency workers were left in containment during changing radiological conditions. The licensee entered this issue into their corrective action program as Condition Report CR-RBS-2009-02458.

This finding is more than minor because it is associated with the emergency response organization performance attribute of the Emergency Preparedness Cornerstone which ensures the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The inspectors evaluated the significance of this finding using Sheet 1, Failure to Comply, of Inspection Manual Chapter 0609,

Appendix BProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix B" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Emergency Preparedness Significance Determination Process, and determined it to be of very low safety significance (Green) because the finding was a failure to comply with the requirements of 10 CFR 50.47(b)(14), the finding was associated with an emergency preparedness planning standard, the associated planning standard was not risk significant as defined by Manual Chapter 0609, Appendix B, and the finding was not a functional failure of the planning standard function. The inspectors determined that the finding has a crosscutting aspect in the area of problem identification and resolution because the licensee did not identify issues completely, accurately, and in a timely manner commensurate with their safety significance P.1(a)(Section 1EP6).

Licensee-Identified Violations

None.

REPORT DETAILS

Summary of Plant Status

River Bend Station began the inspection period at 100 percent core thermal power. The plant remained at 100 percent power except for: May 2, 2009, when reactor power was reduced to 88 percent to repair a steam leak on Valve MSS-MOV111, steam supply to the moisture separator reheater; May 29, 2009, when reactor power was reduced to 66 percent power for a rod sequence exchange; June 13, 2009, when reactor power was reduced to 83 percent power for a control rod sequence exchange; and June 27, 2009, when reactor power was reduced to 67 percent for another control rod sequence exchange.

REACTOR SAFETY

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

1R01 Adverse Weather Protection

Summer Readiness for Offsite and Alternate-ac Power

a. Inspection Scope

The inspectors performed a review of the licensees preparations for summer weather for selected systems, including conditions that could lead to loss-of-offsite power and conditions that could result from high temperatures. The inspectors reviewed the licensees procedures affecting these areas and the communications protocols between the transmission system operator and the plant to verify that the appropriate information was being exchanged when issues arose that could affect the offsite power system.

Examples of aspects considered in the inspectors review included:

• Coordination between the transmission system operator and the plant during off-normal or emergency events

• Explanations for the events

• Estimates of when the offsite power system would be returned to a normal state

• Notifications from the transmission system operator to the plant when the offsite power system was returned to normal During the inspection, the inspectors focused on plant-specific design features and the licensees procedures used to mitigate or respond to adverse weather conditions.

Additionally, the inspectors reviewed the Updated Safety Analysis Report and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant-specific procedures. Specific documents reviewed during this inspection are listed in the attachment. The inspectors also reviewed corrective action program items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their corrective action program in accordance with station corrective action procedures. The inspectors reviews focused specifically on the following plant systems:

• Fancy Point 500 kV and 230 kV substation

• River Bend transformer yard

• Circulating water system

• Normal service water system

• Service water cooling system

These activities constitute completion of one readiness for summer weather affect on offsite and alternate ac power sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignments

Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

• Division 1 control building heating, ventilation, and air conditioning

• Division 2 penetration valve leakage control

• Division 3 emergency diesel generator

The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Safety Analysis Report, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three partial system walkdown samples as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

Quarterly Fire Inspection Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

• April 17, 2009, reactor building 70-foot level, 114-foot level, 141-foot level, 162-foot level, and 186-foot level

• April 20, 2009, fuel building 70-foot level, 95-foot level, 113-foot level, and 148-foot level

• April 28, 2009, tunnels B, E, F, and G

• May 6, 2009, turbine building 67-foot level, 95-foot level, and tunnel C

• May 6, 2009, auxiliary building 95-foot level, 114-foot level, and 141-foot level

• May 7, 2009, reactor building 70-foot level, 114-foot level, 141-foot level, 162-foot level, and 186-foot level

• June 4, 2009, fire pump house

The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out-of-service, degraded, or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees corrective action program.

These activities constitute completion of seven quarterly fire-protection inspection samples as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors reviewed the Updated Safety Analysis Report, the flooding analysis, and plant procedures to assess susceptibilities involving internal flooding; reviewed the corrective action program to determine if licensee personnel identified and corrected flooding problems; inspected underground bunkers/manholes to verify the adequacy of sump pumps, level alarm circuits, cable splices subject to submergence, and drainage for bunkers/manholes; and verified that operator actions for coping with flooding can reasonably achieve the desired outcomes. The inspectors also walked down the area listed below to verify the adequacy of equipment seals located below the flood line, floor and wall penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers.

Specific documents reviewed during this inspection are listed in the attachment.

• May 11, 2009, control building and diesel generator building, 98-foot elevation

These activities constitute completion of one flood protection measures inspection sample as defined in Inspection Procedure 71111.06-05.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk-significant systems:

• Service air system

• Control building heating, ventilation, and air conditioning system

• Control rod drive system

• Instrument air system

The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• Implementing appropriate work practices

• Identifying and addressing common cause failures

• Scoping of systems in accordance with 10 CFR 50.65(b)

• Characterizing system reliability issues for performance

• Charging unavailability for performance

• Trending key parameters for condition monitoring

• Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or (a)(2)

• Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described in 10 CFR 50.65(a)(1)

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four quarterly maintenance effectiveness samples as defined in Inspection Procedure 71111.12-05.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed licensee personnel's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• Division 1 control building chilled water chiller emergent maintenance, March 31, 2009

• Division 1 control building chilled water and emergency diesel generator planned maintenance, June 3, 2009

• Main transformer number 2 emergent maintenance, June 22-25, 2009

The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified

that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three maintenance risk assessments and emergent work control inspection samples as defined in Inspection Procedure 71111.13-05.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• CR-RBS-2009-1584, control building 98-foot elevation clogged drain hub, reviewed on April 4, 2009

• CR-RBS-2009-1894, qualification of submerged electrical cable, reviewed on April 22, 2009

The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and Updated Safety Analysis Report to the licensees evaluations, to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

Additionally, the inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of two operability evaluations inspection samples as defined in Inspection Procedure 71111.15-04.

b. Findings

No findings of significance were identified.

==1R17 Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications (71111.17)

a.

==

Inspection Scope

The inspectors reviewed the effectiveness of the licensees implementation of evaluations performed in accordance with 10 CFR 50.59, Changes, Tests, and Experiments, and changes, tests, experiments, or methodology changes that the licensee determined did not require 10 CFR 50.59 evaluations. The inspection procedure requires the review of 6 to 12 licensee evaluations required by 10 CFR 50.59, 12 to 25 changes, tests, or experiments that were screened out by the licensee and 5 to 15 permanent plant modifications.

The inspectors reviewed 13 evaluations required by 10 CFR 50.59; 26 changes, tests, and experiments that were screened out by licensee personnel; and 14 permanent plant modifications. Document numbers of the evaluations, changes, and modifications reviewed are listed in the attachment.

The inspectors verified that when changes, tests, or experiments were made, that evaluations were performed in accordance with 10 CFR 50.59 and that licensee personnel had appropriately concluded that the change, test, or experiment can be accomplished without obtaining a license amendment. The inspectors also verified that safety issues related to the changes, tests, or experiments were resolved. The inspectors reviewed changes, tests, and experiments that licensee personnel determined did not require evaluations and verified that the licensee personnels conclusions were correct and consistent with 10 CFR 50.59. The inspectors also verified that procedures, design, and licensing basis documentation used to support the changes were accurate after the changes had been made.

In the inspection of modifications, the inspectors verified that supporting design and license basis documentation had been updated accordingly and was still consistent with the new design. The inspectors verified that procedures, training plans, and other design basis features had been adequately accounted for and updated. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of 53 samples as defined in Inspection Procedure 71111.17-05.

b. Findings

No findings of significance were identified.

1R19 Postmaintenance Testing

a. Inspection Scope

The inspectors reviewed the following postmaintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

• WO 00151164, CRD Suction Filter Replacement, reviewed on April 14, 2009

• WO 00189009, Tasks 1 - 7, Remove/Repair/Replace HVC-ACU2B, reviewed on May 11, 2009

• WO 00149509, Tasks 6 and 17, EGS-EG1B #8 Cylinder Exhaust Pipe Crack, reviewed on June 11, 2009

The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following:

• The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed

• Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate

The inspectors evaluated the activities against the technical specifications, the Updated Safety Analysis Report, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with postmaintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three postmaintenance testing inspection samples as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the Updated Safety Analysis Report, procedure requirements, and technical specifications to ensure that the four surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed

test data to verify that the significant surveillance test attributes were adequate to address the following:

• Preconditioning

• Evaluation of testing impact on the plant

• Acceptance criteria

• Test equipment

• Procedures

• Jumper/lifted lead controls

• Test data

• Testing frequency and method demonstrated technical specification operability

• Test equipment removal

• Restoration of plant systems

• Fulfillment of ASME Code requirements

• Updating of performance indicator data

• Engineering evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct

• Reference setting data

• Annunciators and alarms setpoints

The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.

• STP-207-4550, RCS Leakage Detection Sys - DW and Pedestal Floor Drain Sump Monitoring Channel Functional Test, performed on March 15, 2009

• STP-309-0203, Division III Diesel Generator Operability Test, performed on May 27, 2009

• STP-309-0612, Division II Diesel Generator 24 Hour Run, reviewed on May 27, 2009

• STP-201-6310, Standby Liquid Control Quarterly Pump and Valve In Service Operability Test, performed on May 28, 2009

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four surveillance testing inspection samples as defined in Inspection Procedure 71111.22-05.

b. Findings

No findings of significance were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

The inspectors performed an in-office review of the River Bend Station Emergency Plan, Revision 34, and emergency plan implementing Procedure EIP 2-001, Classification of Emergencies, Revision 17. These revisions changed a requirement for one on-shift instrument and control technician to a requirement for two on-shift maintenance technicians filled by any combination of electrical and instrument and control technicians, added details regarding responsibilities assigned to the Emergency Preparedness Manager, and made minor editorial and typographic corrections.

These revisions were compared to their 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, to NEI Report 99-01, Emergency Action Level Methodology, Revision 4, and to the standards in 10 CFR 50.47(b) to determine if the revisions adequately implemented the requirements of 10 CFR 50.54(q). These reviews were not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, these revisions are subject to future inspection.

These activities constitute completion of two samples as defined in Inspection Procedure 71114.04-05.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on April 21, 2009, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulated control room, technical support center, operations support center, and emergency off-site facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weaknesses with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly

identifying weaknesses and entering them into the corrective action program. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.06-05.

b. Findings

Introduction.

The inspectors identified a noncited violation of 10 CFR 50.47(b)(14)involving failure to identify and critique a nonrisk-significant planning standard weakness demonstrated during a site emergency preparedness drill. Specifically, the licensee demonstrated a weakness in controlling radiological exposures for emergency workers during an emergency, without key emergency response organization decision maker consideration or input, when simulated workers were left in containment during changing radiological conditions.

Description.

On April 21, 2009, Entergy conducted Site Drill Scenario RDRL-EP-902 at River Bend Station to demonstrate emergency response organization performance in the simulator control room, technical support center, operations support center, and the emergency operations facility. The scenario started with the reactor at 100 percent power while simulated maintenance workers inside containment gathered data on the train A residual heat removal injection valve. As the scenario progressed, the main steam isolation valves closed due to high temperature in the steam tunnel. The simulated workers remained inside the containment for over an hour, during which time the reactor control rods failed to insert following the automatic reactor scram, the reactor safety relief valves lifted and dumped steam to the suppression pool, reactor vessel water level decreased, fuel elements failed, and the simulator control room crew performed an emergency depressurization. These simulated conditions could have caused the emergency workers in containment to exceed administrative and regulatory radiation dose limits and exposed them to dangerous steam and high temperatures.

Although the simulated workers were performing a prioritized task at the request of the control room staff and the workers location was posted on a status board in the operations support center, key decision makers of the emergency response organization in the technical support center were unaware that simulated workers were inside containment during degrading plant conditions. The emergency response team did not consider means to control the simulated workers radiological exposure in accordance with station emergency procedures and did not address the simulated workers radiological exposure during a technical support center brief conducted 45 minutes after the failure of the control rods to insert following a scram. The failure to adequately address radiological exposure controls for simulated workers in accordance with Entergy procedures was not identified and presented as a weakness requiring corrective action during the formal drill critique.

Analysis.

The emergency response organizations failure to implement procedures and control radiological exposures for emergency workers during an emergency drill is a weakness because the failure to control the radiological exposures of emergency workers could prevent the effective implementation of the licensees emergency plan during an actual emergency. Failure to identify and address this emergency response organization performance weakness via a formal critique process was a performance deficiency that was within the licensees ability to foresee and correct. This finding is

more than minor because it is associated with the emergency response organization performance attribute of the emergency preparedness cornerstone which ensures the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The inspectors evaluated the significance of this finding using Sheet 1, Failure to Comply, of Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, and determined it to be of very low safety significance (Green) because the finding was a failure to comply with the requirements of 10 CFR 50.47(b)(14), the finding was associated with an emergency preparedness planning standard, the associated planning standard was not risk significant as defined by Manual Chapter 0609, Appendix B, and the finding was not a functional failure of the planning standard function. The inspectors determined that the finding has a crosscutting aspect in the area of problem identification and resolution because the licensee did not identify issues completely, accurately, and in a timely manner commensurate with their safety significance P.1(a).

Enforcement.

Title 10 CFR 50.47(b)(14) requires that periodic drills be conducted to evaluate major portions of emergency response capabilities, periodic drills be conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills be corrected. Contrary to the above, during a site drill scenario, conducted on April 21, 2009, the licensee failed to identify a deficiency related to Planning Standard 10 CFR 50.47(b)(11) which requires that means for controlling radiological exposures, in an emergency, are established for emergency workers. Because the finding is of very low safety significance and has been entered into the corrective action program as Condition Report CR-RBS-2009-2458, this violation is being treated as a noncited violation consistent with Section VI.A.1 of the NRC Enforcement Policy:

NCV 05000458/2009003-01, Failure to Identify and Formally Critique an Emergency Plan Weakness.

4OA1 Performance Indicator Verification

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the data submitted by the licensee for the first quarter 2009 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, Performance Indicator Program.

This review was performed as part of the inspectors normal plant status activities and, as such, did not constitute a separate inspection sample.

b. Findings

No findings of significance were identified.

.2 Safety System Functional Failures (MS05)

a. Inspection Scope

The inspectors sampled licensee submittals for the Safety System Functional Failures performance indicator for the period from the second quarter of 2008 through the first quarter of 2009. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73 definitions and guidance were used. The inspectors reviewed the licensees operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports, and NRC integrated inspection reports for the period of April 2008 through March 2009 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of one safety system functional failures sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.3 Mitigating Systems Performance Index - Emergency ac Power System (MS06)

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance Index - Emergency ac Power System performance indicator for the period from the second quarter 2008 through the first quarter of 2009. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, was used. The inspectors reviewed the licensees operator narrative logs, mitigating systems performance index derivation reports, issue reports, event reports, and NRC integrated inspection reports for the period of April 2008 through March 2009 to validate the accuracy of the submittals. The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of one mitigating systems performance index emergency ac power system sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.4 Mitigating Systems Performance Index - High Pressure Injection Systems (MS07)

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance Index - High Pressure Injection Systems performance indicator for the period from the second quarter of 2008 through the first quarter of 2009. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, was used. The inspectors reviewed the licensees operator narrative logs, issue reports, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports for the period of April 2008 through March 2009 to validate the accuracy of the submittals. The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of one mitigating systems performance index high pressure injection system sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included: the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition

reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective actions. Minor issues entered into the licensees corrective action program because of the inspectors observations are included in the attached list of documents reviewed.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings of significance were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees corrective action program. The inspectors accomplished this through review of the stations daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings of significance were identified.

.3 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees corrective action program and associated documents to identify trends that could indicate the existence of a more significant safety issue. Specifically, the inspectors reviewed the corrective action program to identify long term trends with balance of plant equipment reliability and availability concerns that could challenge overall plant safety and stability. The inspectors focused their review on repetitive equipment issues, but also considered the results of daily corrective action item screening discussed in Section 4OA2.2, above, licensee trending efforts, and licensee human performance results. The inspectors nominally considered the 6-month period of October 2008 through March 2009, although some examples expanded beyond those dates where the scope of the trend warranted.

The inspectors also included issues documented outside the normal corrective action program in major equipment problem lists, repetitive and/or rework maintenance lists, departmental problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self-assessment reports, and maintenance rule assessments.

The inspectors compared and contrasted their results with the results contained in the licensees corrective action program trending reports. Corrective actions associated with

a sample of the issues identified in the licensees trending reports were reviewed for adequacy.

These activities constitute completion of one single semi-annual trend inspection sample as defined in Inspection Procedure 71152-05.

b. Findings

No findings of significance were identified.

.4 Selected Issue Follow-up Inspection

a. Inspection Scope

During a review of items entered in the licensees corrective action program, the inspectors recognized a corrective action item documenting foreign material control inside the reactor building. The inspectors looked for proper implementation of Procedure EN-MA-118, Foreign Material Exclusion, Revision 4. Specifically, the inspectors questioned the method in which the reactor building was posted as a foreign material exclusion zone or an exclusion area; whether a loss of control applied to scaffold items, wood, and plastic bags on the refuel floor; the fail-safe design of stored material in the foreign material exclusion zone 1; and whether temporary modifications packages for temporary pumps, power cords, and small motor control centers were appropriately prepared.

These activities constitute completion of one in-depth problem identification and resolution sample as defined in Inspection Procedure 71152-05.

b. Findings

No findings of significance were identified.

4OA5 Other Activities

Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors performed observations of security force personnel and activities to ensure that the activities were consistent with River Bend security procedures and regulatory requirements relating to nuclear plant security.

These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status review and inspection activities.

b. Findings

No findings of significance were identified.

4OA6 Meetings

Exit Meeting Summary

The branch chief met with the licensee on April 23, 2009, to convey the results of the End-of-Cycle Review of plant performance. The licensee acknowledged the results of the review.

On May 5, 2009, the inspectors presented the evaluations of changes, tests, or experiments and permanent plant modifications inspection results to Mr. M. Perito, Site Vice President, and other members of his staff. The inspectors reviewed some proprietary information and verified that none would be included in this report.

On May 7, 2009, the inspector conducted a telephonic exit meeting to present the results of the in-office inspection of changes to the licensees emergency plan and emergency action levels to Mr. J. Leavines, Manager, Emergency Planning. The licensee acknowledged the issues presented.

On July 8, 2009, the resident inspectors presented the integrated baseline inspection results to Mr. M. Perito, Site Vice President, and other members of his staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Bolke, Licensing Specialist

G. Bush, Manager, Plant Maintenance

M. Chase, Manager, Training and Development

J. Clark, Assistant Operations Manager - Shift

F. Corley, Electrical Design Engineering Supervisor

B. Cox, Manager, Operations

M. Feltner, Manager, Outage

C. Forpahl, Manager, Engineering Programs & Components

D. Heath, Radiation Protection Supervisor

R. Heath, Superintendent, Chemistry

G. Hendl, Senior Engineer, Engineering

B. Houston, Manager, Radiation Protection

K. Huffstatler, Senior Licensing Specialist

A. James, Manager, Plant Security

L. Kitchen, Manager, Planning and Scheduling

R. Kowaleski, Manager, Corrective Actions & Assessments

J. Leavines, Manager, Emergency Preparedness

D. Lorfing, Manager, Licensing

W. Mashburn, Manager, Design Engineering

R. McAdams, Manager, System Engineering

J. McElwain, Manager, Human Resources

E. Olson, General Manager, Plant Operations

M. Perito, Vice President, Operations

R. Persons, Superintendent, Training

J. Roberts, Director, Nuclear Safety Assurance

J. Schlesinger, Supervisor, Engineering

J. Schroeder, Assistant Operations Manager - Training

D. Wiles, Director, Engineering

L. Woods, Manager (Acting), Quality Assurance

NRC Personnel

D. Proulx, Senior Project Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000458/2009003-01 NCV Failure to Identify and Formally Critique an Emergency Plan Weakness (Section 1EP6)