IR 05000458/2011003

IR 05000458-11-003, on 04/01/11 - 06/30/11, Entergy Operations, Inc

ML112210162
Person / Time
Site:	River Bend
Issue date:	08/09/2011
From:	Vincent Gaddy NRC/RGN-IV/DRP/RPB-C
To:	Olson E Entergy Operations
References
IR-11-003
Download: ML112210162 (45)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGI ON I V 612 EAST LAMAR BLVD, SUITE 400 ARLINGTON, TEXAS 76011-4125 August 9, 2011 Eric Site Vice President Entergy Operations, Inc.

River Bend Station 5485 US Highway 61 St. Francisville, LA 70775 Subject: RIVER BEND STATION - NRC INTEGRATED INSPECTION REPORT NUMBER 05000458/2011003

Dear Mr. Olson:

On June 30, 2011, 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 12, 2011, with you and other members of your staff.

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

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

Based on the results of this inspection, the NRC has identified one issue that was evaluated under the risk significance determination process as having very low safety significance (Green). The NRC has determined that no violations are associated with this issue.

Additionally, two licensee-identified violations, which were determined to be of very low safety significance, are listed in this report. However, because of the very low safety significance and because they were entered into your corrective action program, the NRC is treating these findings as noncited violations, consistent with Section 2.3.2 of the NRC Enforcement Policy.

If you contest the violations or the significance of the noncited violations, 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 cross-cutting aspect assigned to 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.

Entergy Operations, Inc. -2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if you choose to provide one for cases where a response is not required, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the Public without redaction.

Sincerely,

/RA/

Vincent G. Gaddy, Chief Project Branch C Division of Reactor Projects Docket: 50-458 License: NPF-47

Enclosure:

NRC Inspection Report 05000458/2011003 w/Attachment: Supplemental Information

REGION IV==

Docket: 05000458 License: NPF-47 Report: 05000458/2011003 Licensee: Entergy Operations, Inc.

Facility: River Bend Station Location: 5485 U.S. Highway 61 St. Francisville, LA Dates: April 1 through June 30, 2011 Inspectors: G. Larkin, Senior Resident Inspector, Project Branch C A. Barrett, Resident Inspector, Project Branch C P. Elkmann, Senior Emergency Preparedness Inspector, Plant Support Branch 1 B. Latta, Senior Reactor Inspector, Engineering Branch 1 Approved By: Vincent G. Gaddy, Chief, Project Branch C Division of Reactor Projects-1- Enclosure

SUMMARY OF FINDINGS

IR 05000458/2011003; 04/01/2011 - 06/30/2011; River Bend Station; Integrated Resident and

Regional Report; Operability Evaluations The report covered a 3-month period of inspection by resident inspectors and two region-based inspectors. One Green finding of significance 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. The cross-cutting aspect is determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting Areas. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The 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: Mitigating Systems

Green.

The inspectors identified a finding for the failure to properly document equipment oil additions in the oil lubrication accountability log per General Maintenance Procedure GMP-0015, Lubrication Procedure. To correct the programmatic deficiencies, the station revised General Maintenance Procedure GMP-0015 instructions to enhance and amplify the requirement to record all oil additions in the lubrication accountability log, revise preventative maintenance tasks that sample or change oil to explicitly state record oil additions in the lubrication accountability log, and to brief station personnel concerning changes to General Maintenance Procedure GMP-0015. The licensee entered this issue into their corrective action program as Condition Report CR-RBS-2011-02883.

The finding is more than minor because if left uncorrected the performance deficiency would have the potential to lead to a more significant safety concern.

Using Inspection Manual Chapter 0609, Significance Determination Process,

Phase 1 Worksheet, the finding was determined to be of very low safety significance (Green) because it was not a design or qualification deficiency; did not represent either a loss of system safety function, an actual loss of safety function of a single train, or an actual loss of safety function; and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors determined that the apparent cause of the performance deficiency was incomplete work package instructions that did not explicitly state to record oil additions in the lubrication accountability log per General Maintenance Procedure GMP-0015, thereby making equipment operability conclusions based on incomplete monitored trends suspect and potentially inaccurate. Consequently, this finding has a cross-cutting aspect in the human performance area associated with the resources component because the stations work packages lacked the necessary instructions to adequately control the lubrication monitoring program H.2(c) (Section 1R15).

Licensee-Identified Violations

Two violations 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 action tracking numbers (condition report numbers) are listed in Section 4OA7.

REPORT DETAILS

Summary of Plant Status

River Bend Station began the inspection period at 100 percent rated thermal power. On April 15, 2011, the plant reduced reactor power to 68 percent to perform control rod insertion tests, perform turbine bypass valve testing, and complete a control rod sequence exchange.

The plant returned to full power on April 17, 2011. On April 29, 2011, the plant reduced reactor power to 94 percent to perform a leak injection repair on moisture separator reheater A steam supply shutoff valve, MSS-MOV111. The plant returned to full power on April 29, 2011. On June 9, 2011, the plant began to reduce reactor power to 40 percent power to locate and repair a through wall steam leak on a main steam drain line running from the main steam equalizing header to just upstream from the main condenser. Following the drain pipe repair, reactor feedwater regulating valve B packing began to leak steam. The steam leak was repaired during power ascension at 95 percent reactor power. The plant returned to 100 percent reactor power on June 13, 2010, and remained at 100 percent reactor power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

Since thunderstorms with potential tornados and high winds were forecast in the vicinity of the facility, the inspectors reviewed the plant personnels overall preparations/

protection for the expected weather conditions. On April 15, 2011, the inspectors walked down the 125 Vdc and instrument air systems because their safety-related functions could be affected, or required, as a result of high winds or tornado-generated missiles or the loss of offsite power. The inspectors evaluated the plant staffs preparations against the sites procedures and determined that the staffs actions were adequate. During the inspection, the inspectors focused on plant-specific design features and the licensees procedures used to respond to specified adverse weather conditions. The inspectors also toured the plant grounds to look for any loose debris that could become missiles during a tornado. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. Additionally, the inspectors reviewed the Updated Safety Analysis Report and performance requirements for the systems selected for inspection, and verified that operator actions were appropriate as specified by plant-specific procedures. The inspectors also reviewed a sample of corrective action program items to verify that the licensee-identified adverse weather issues at an appropriate threshold and dispositioned them through the corrective action program in accordance with station corrective action procedures.

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

These activities constitute completion of one readiness for impending adverse weather condition sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

.2 Readiness for Seasonal Extreme Flooding Conditions

a. Inspection Scope

The inspectors performed a review of site actions for seasonal extreme flooding of the Mississippi River. The inspectors verified that the site had developed detailed plans and contingency actions for the record flooding of the Mississippi River. Inspectors attended flooding preparation meetings, reviewed the licensees plans, and ensured that the site had addressed requirements for plant shutdown if required. The inspectors evaluated the design and procedures for coping with the design basis probable maximum flood.

The evaluation included a review to check for deviations from the descriptions provided in the Updated Safety Analysis Report for features intended to mitigate the potential for flooding from external factors. The inspectors reviewed the protective strategies for the plants make-up water system to ensure that it would be effective against the record flooding. The inspectors reviewed previously identified deficiencies to determine if these had been addressed prior to the onset of higher than normal flooding in the area.

Inspectors also evaluated the implementation of the site plan for flooding preparation and compensatory measures before the onset of, and during, the flooding conditions.

During the inspection, the inspectors focused on plant-specific design features and the procedures used by plant personnel to mitigate or respond to the record flooding conditions.

Specific documents reviewed during this inspection are listed in the attachment. The inspectors also reviewed corrective action program items to verify that plant personnel were identifying flooding 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:

• Make up water system

• Emergency diesel generators

• Offsite power These activities constitute completion of one readiness for seasonal adverse weather sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

.3 Readiness to Cope with External Flooding

a. Inspection Scope

The inspectors evaluated the design, material condition, and procedures for coping with the design basis probable maximum flood. The evaluation included a review to check for deviations from the descriptions provided in the Updated Safety Analysis Report for features intended to mitigate the potential for flooding from external factors. As part of this evaluation, the inspectors checked for obstructions that could prevent draining, checked that the roofs did not contain obvious loose items that could clog drains in the event of heavy precipitation, and determined that barriers required to mitigate the flood were in place and operable. Additionally, the inspectors performed an inspection of the protected area to identify any modification to the site that would inhibit site drainage during a probable maximum precipitation event or allow water ingress past a barrier.

The inspectors also reviewed the abnormal operating procedure for mitigating the design basis flood to ensure it could be implemented as written. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one external flooding sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignments

Partial Walkdown

a. Inspection Scope

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

• Division 2 emergency diesel generator

• Division 1 125 Vdc system 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 inspected 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 two partial system walkdown samples as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 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 29, 2011, normal switchgear building

• May 5, 2011, fuel building, 70-foot elevation, 95-foot elevation, and 114-foot elevation; Tunnels B, C, and E

• June 1, 2011, control building, 98-foot elevation and 116-foot elevation; diesel generator building, 98-foot elevation, fire area DG-6/Z-1

• June 3, 2011, reactor building, fire area RC-3/Z-5

• June 3, 2011, reactor building, fire area RC-4/Z-4

• June 22, 2011, tunnel B, control building, 98-foot elevation and 116-foot elevation; diesel generator building, 98-foot elevation, fire area DG-5/Z-1 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.

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

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

b. Findings

No findings were identified.

.2 Annual Fire Protection Drill Observation

a. Inspection Scope

On June 7, 2011, the inspectors observed a fire brigade activation for combined onsite and offsite fire resource response to the main warehouse. The observation evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies, openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions. Specific attributes evaluated were:

(1) proper wearing of turnout gear and self-contained breathing apparatus;

(2) proper use and layout of fire hoses;

(3) employment of appropriate fire fighting techniques;

(4) sufficient firefighting equipment brought to the scene;

(5) effectiveness of fire brigade leader communications, command, and control;

(6) search for victims and propagation of the fire into other plant areas;

(7) smoke removal operations;

(8) utilization of preplanned strategies;

(9) adherence to the preplanned drill scenario; and

(10) drill objectives.

These activities constitute completion of one annual fire protection inspection sample as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings 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 inspected the areas 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.

• April 18-29, 2011, residual heat removal pump room B, residual heat removal pump room C, reactor core isolation cooling room These activities constitute completion of three flood protection measures inspection samples as defined in Inspection Procedure 71111.06-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

a. Inspection Scope

On June 28, 2011, the inspectors observed a crew of licensed operators in the plants simulator to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• Licensed operator performance

• Crews clarity and formality of communications

• Crews ability to take timely actions in the conservative direction

• Crews prioritization, interpretation, and verification of annunciator alarms

• Crews correct use and implementation of abnormal and emergency procedures

• Control board manipulations

• Oversight and direction from supervisors

• Crews ability to identify and implement appropriate technical specification actions and emergency plan actions and notifications The inspectors compared the crews performance in these areas to pre-established operator action expectations and successful critical task completion requirements.

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

This inspection activity represents a review of Operating Experience Smart Sample FY2010-02 related to issues associated with licensed operator examinations and training conducted on the plant-referenced simulator.

These activities constitute completion of one quarterly licensed-operator requalification program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

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

• Switchyard and offsite power 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 one quarterly maintenance effectiveness samples as defined in Inspection Procedure 71111.12-05.

b. Findings

No findings 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:

• Planned maintenance on remote shutdown panel calibration of residual heat removal flow transmitter, April 22, 2011

• Planned maintenance in Fancy Point electrical switchyard, with transformer yard scaffold erection and removal, and emergency diesel generator surveillance testing, April 27, 2011

• Planned testing of standby cooling tower fans with service water snubber maintenance with potential severe weather, May 3, 2011

• Unexpected half scram during planned average power range monitor maintenance, May 19, 2011

• Severe weather with on-going planned maintenance, June 1, 2011 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 five maintenance risk assessments and emergent work control inspection samples as defined in Inspection Procedure 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• CR-RBS-2011-03117, residual heat removal subsystem C operability, reviewed on April 4, 2011

• CR-RBS-2011-03395, cracks on Division 1 emergency diesel generator vertical support saddle welds, reviewed on April 8, 2011

• CR-RBS-2011-03247, reactor core isolation cooling turbine steam leaks, reviewed on April 11, 2011

• CR-RBS-2011-3913, meteorological tower secondary temperature RTD primary processor serial number mismatch, reviewed on May 3, 2011

• CR-RBS-2011-2267, main steam isolation valve accumulator drain valve leakage, reviewed on May 5, 2011

• CR-RBS-2011-2883, reactor core isolation cooling lube oil logs and log keeping practices, reviewed on May 13, 2011

• CR-RBS-2011-3251, reactor core isolation cooling turbine steam flow indication bias, reviewed on May 23, 2011 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 licensee personnels 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 seven operability evaluations inspection samples as defined in Inspection Procedure 71111.15-04.

b. Findings

Introduction.

The inspectors identified a Green finding for the failure to properly document equipment oil additions in the oil lubrication accountability log per general maintenance General Maintenance Procedure GMP-0015, Lubrication Procedure.

Description.

On January 12, 2011, the inspectors identified oil leaks on the inboard side of the reactor core isolation cooling turbine lube oil temperature indicator probes.

Condition Report CR-RBS-2011-00205 evaluated the condition as operable because of the small amount of oil found and because there was no history of excessive oil additions to the reactor core isolation cooling system which demonstrated that this condition would not in any way prevent the reactor core isolation cooling system from performing its technical specification required design function. The operability statement was based on the stations lubrication accountability logs oil addition history. The inspectors noted that the lubrication accountability log failed to appropriately document oil added to the reactor core isolation cooling turbine lube oil system by a work request.

General Maintenance Procedure GMP-0015, Lubrication Procedure, was the procedure used for checking and maintaining oil levels in all equipment. Although the procedure was not safety related it governed the addition of oil to all plant equipment and was therefore, the standard to be followed. General Maintenance Procedure GMP-0015 required personnel to record the quantity of lubricant added to the component to the lubrication database. Failing to maintain an accurate oil addition record could prevent engineering and operations personnel from reasonably determining unacceptable component oil leakage that affects equipment operability. The inspectors also identified that personnel failed to update the lubrication accountability log for high pressure core spray motor and control building chillers lube oil reservoirs oil additions.

To correct the programmatic deficiencies, the station revised General Maintenance Procedure GMP-0015 instructions to enhance and amplify the requirement to record all oil additions in the lubrication accountability log, revise preventative maintenance tasks that sample or change oil to explicitly state record oil additions in the lubrication accountability log, and to brief station personnel concerning changes to General

Maintenance Procedure GMP-0015. Although the reactor core isolation cooling turbine lube oil leaks represented a degraded condition and a programmatic breakdown in the use of the stations lubrication procedure, the inspectors did not identify any instances where deficiencies impacted the operability or function of station equipment. In each instance the measured oil level was within the required oil level band.

Analysis.

The failure to record the oil usage in the lubrication accountability log for safety-related and risk important equipment was a performance deficiency. General Maintenance Procedure GMP-0015, Lubrication Procedure, required the quantity of lubricant added to components be tracked in the lubrication accountability log. Contrary to this standard, station personnel failed to update the log after oil additions were made to station equipment. This finding is more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and it affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events. Also, if left uncorrected the performance deficiency would have the potential to lead to a more significant safety concern. Using Inspection Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheet, the finding was determined to be of very low safety significance (Green) because it was not a design or qualification deficiency; did not represent either a loss of system safety function, an actual loss of safety function of a single train, or an actual loss of safety function; and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors determined that the apparent cause of the performance deficiency was incomplete work package instructions that did not explicitly state to record oil additions in the lubrication accountability log per General Maintenance Procedure GMP-0015, thereby making equipment operability conclusions based on incomplete monitored trends suspect and potentially inaccurate.

Consequently, this finding has a cross-cutting aspect in the human performance area associated with the resources component because the stations work packages lacked the necessary instructions to adequately control the lubrication monitoring program

H.2(c).

Enforcement.

Enforcement action does not apply because the performance deficiency did not involve a violation of regulatory requirements. Because this finding does not involve a violation of regulatory requirements and has very low safety significance, it is characterized as a finding and is designated as FIN 05000458/2011003-01, Failure to Track and Document Plant Equipment Oil Usage.

1R18 Plant Modifications

.1 Temporary Modifications

a. Inspection Scope

To verify that the safety functions of important safety systems were not degraded, the inspectors reviewed the temporary modification identified as Engineering Change EC-28545, G33-EB002A Lower Flange Leak Repair, Revision 0.

The inspectors reviewed the temporary modification and the associated safety-evaluation screening against the system design bases documentation, including the Updated Safety Analysis Report and the technical specifications, and verified that the modification did not adversely affect the system operability/availability. The inspectors also verified that the installation and restoration were consistent with the modification documents and that configuration control was adequate. Additionally, the inspectors verified that the temporary modification was identified on control room drawings, appropriate tags were placed on the affected equipment, and licensee personnel evaluated the combined effects on mitigating systems and the integrity of radiological barriers.

These activities constitute completion of one sample for temporary plant modifications as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings were identified.

.2 Permanent Modifications

a. Inspection Scope

The inspectors reviewed key parameters associated with energy needs, materials, replacement components, timing, heat removal, control signals, equipment protection from hazards, operations, flow paths, pressure boundary, ventilation boundary, structural, process medium properties, licensing basis, and failure modes for the permanent modification identified as Engineering Change EC-RBS-0000024645, EGS-EG1A Combustion Air Pipe Vibration Damper Installation, Revision 000, and EC-RBS-0000024647, EGS-EG1A Combustion Air Pipe support Base Structure Installation and Trunnion Installation, Revision 000.

The inspectors verified that modification preparation, staging, and implementation did not impair emergency/abnormal operating procedure actions, key safety functions, or operator response to loss of key safety functions; postmodification testing will maintain the plant in a safe configuration during testing by verifying that unintended system interactions will not occur; systems, structures, and components performance characteristics still meet the design basis; the modification design assumptions were appropriate; the modification test acceptance criteria will be met; and licensee personnel identified and implemented appropriate corrective actions associated with permanent plant modifications. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample for permanent plant modifications as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings 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 00212752, MMS RTD5B is Reading 24 Degrees Low Out of Spec, reviewed on April 29, 2011

• WO -00277993, E31-PDTN083A Is At The Max Differential Per STP-000-0001, reviewed on May 23, 2011 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 two postmaintenance testing inspection samples as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings 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 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:

• 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-207-4248, RCIC/RHR Isolation - RCIC Steam Line Flow-High Channel Calibration and LSFT (E31-N084A, E31-N684A, E31-N691A), performed on October 11, 2010

• STP-209-6310, RCIC Quarterly Pump and Valve Operability Test, performed on May 13, 2011

• STP-508-4244, RPS/EOC-RPT Turbine First Stage Pressure Channel Calibration and Logic System Functional Test (C71-N652D, C71-N052D),performed on January 24, 2011

• STP-554-4210, Meteorological Monitoring - Air Temperature Difference Elev 30/150 Ft. (Secondary) Semi-Annual Channel Calibration, performed on September 4, 2010

• STP-740-3001, Control Room Envelope Habitability Assessment, performed on March 11, 2010 Specific documents reviewed during this inspection are listed in the attachment.

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

b. Findings

No findings 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 37. This revision updated Table 13.3-2, USAR Postulated Accidents and Related Emergency Classification, and Table 13.3-3, Accident Assessment Techniques. These changes maintain consistency between the emergency plan and the stations Updated Safety Analysis Report for the implementation of a 24-month fuel cycle.

This revision was compared to its previous revision, 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 standards in 10 CFR 50.47(b) to determine if the revision adequately implemented the requirements of 10 CFR 50.54(q). This review was not documented in a safety-evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.04-05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on June 7, 2011, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator, emergency operating center, technical support center, and in the outage support center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensees drill critique to compare any inspector-observed weakness 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

No findings were identified.

.2 Training Observations

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on June 8, 2011, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that the licensee evaluators noted the same issues and entered them into the corrective action program. As part of the inspection, the inspectors reviewed the scenario 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

No findings were identified.

4OA1 Performance Indicator Verification

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the performance indicator data submitted by the licensee for the first quarter 2011 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 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 2010 through the first quarter 2011. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73." 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 2010 through March 2011 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 during this inspection are listed in the attachment.

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

b. Findings

No findings 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 2010 through the first quarter 2011. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. 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 2010 through March 2011 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 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 2010 through the first quarter 2011. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. 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 2010 through March 2011 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 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 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 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 with piping system steam leaks that could indicate the existence of a more significant safety issue. 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 2010 through March 2011 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 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 identified a corrective action item documenting numerous missed quality control hold points during Refueling Outage 16. The inspectors addressed the missed hold points primarily as a maintenance department/work control issue that could adversely impact the licensees quality assurance program implementation. The

inspectors also noted that the corrective action review group assigned a C or D significance codes for each of the identified deficiencies and non-conformances and that each condition was addressed in isolation. Based on the results of these reviews, the inspectors were concerned that the corrective action review group might fail to identify an apparent adverse trend in missed quality control hold points.

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

b. Findings

No findings were identified.

.5 Selected Issue Follow-up Inspection

a. Inspection Scope

During a review of items entered in the licensees corrective action program, the inspectors identified a corrective action item documenting an unplanned reactor recirculation pump trip resulting in single loop operation and a down power to 55 percent power. The station initially identified a failed optical isolator in the reactor recirculation pump B trip logic as the likely failure mechanism. Later an evaluation determined that the root cause was indeterminate. The licensee entered the event into their corrective action program as Condition Reports CR-RBS-2010-06059 and CR-RBS-2011-03196.

The inspectors discussed the event with licensee management, engineering, operations, and maintenance personnel to understand the scope of the root cause and the root cause indeterminate conclusion.

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

b. Findings

No findings were identified.

.6 In-depth Review of 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 April 11, 2011, the inspectors reviewed the cumulative effect of the existing operator workarounds and contingency plans. 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.

These activities constitute completion of one in-depth review of operator workarounds sample as defined in Inspection Procedure 71152-05.

b. Findings

No findings were identified.

4OA3 Event Follow-up

.1 (Closed) Licensee Event Report 05000458/2010-004-00: High Pressure Core Spray

System Inoperable Due to Failed Motor Oil Reservoir Drain Plug On November 7, 2010, the high pressure core spray pump was declared inoperable following the discovery of an oil leak on the pump motor. The source of the oil leak was found to be a cracked drain plug on the lower motor bearing oil reservoir. The oil plug was replaced. The high pressure core spray system was restored to its standby condition that same day. This licensee event report was a preliminary report, as the causal analysis of this event was not yet complete. A supplemental report (see item 4OA3

.2 below) provided the failures causal analysis. This failed motor oil reservoir

drain plug was reported in accordance with 10 CFR 50.73(a)(2)(v)(D) as the loss of a system needed to mitigate the consequences of an accident. Inspection documentation was provided in NRC Inspection Report 05000458/2010005, Sections 1R19.b.1 and

1R19 .b.2. This licensee event report is closed.

.2 (Closed) Licensee Event Report 05000458/2010-004-01: High Pressure Core Spray

System Inoperable Due to Failed Motor Oil Reservoir Drain Plug This was a supplemental report to the preliminary report, item 4OA3

.1 above. This

supplemental report postulated that the cause of the leakage from the cracked lower motor bearing oil reservoir drain plug resulted initially from an O-ring failure. It appeared that an attempt to mitigate the leakage was made by further tightening the drain plug.

This further tightening caused the drain plug to fail. Corrective actions to prevent recurrence included replacing all emergency core cooling pump drain plug assemblies with new stainless steel parts and new O-ring and develop preventative maintenance tasks to replace the drain plug O-rings on a periodic bases. See NRC Inspection Report 05000458/2010005, Sections 1R19.b.1 and 1R19.b.2 for additional details. This licensee event report is closed.

.3 (Closed) Licensee Event Report 05000458/2011-002-00: Operations Prohibited by

Technical specifications Due to Instrument Isolation Valve Mispositioning On February 13, 2011, during power ascent following a refueling outage, operators noticed the control valve fast closure and turbine stop valve trip bypass alarm had not cleared. Operators found main turbine first stage pressure channel D instrumentation was not responding to changing reactor plant pressures. Main turbine first stage

pressure indication provided a reactor protection system permissive to enable a reactor scram signal from either main turbine control valve or stop valve fast closure; and to enable a reactor recirculation pump trip during main turbine stop valve fast closure. The stations technical specifications required this instrument channel to be operable at greater than 40 percent reactor power. Troubleshooting activities found a mispositioned valve that isolated the main turbine first stage pressure instrument D from reactor plant pressures. The isolation valve was apparently left closed following instrument calibration during the outage. The licensee determined that self-checking and concurrent verification was inadequate to ensure the instrument isolation valve was properly positioned per the work order and during the tag out restoration. The stations corrective actions included a site broadcast to discuss adequate self-check and concurrent verification during preventative maintenance restoration, and to change General Operating Procedure GOP-0001, Plant Startup, to verify a satisfactory channel check of turbine first stage pressure instruments prior to exceeding 40 percent reactor power.

The enforcement aspects of this finding are discussed in Section 40A7. This licensee event report is closed.

.4 Radwaste Building Flooding

a. Inspection Scope

On April 9, 2011, the inspectors were notified by the control room that the radwaste building had experienced internal flooding. The inspectors responded to the control room to ensure that the plant did not experience adverse effects from the flooding event. The inspectors walked down the radwaste building and observed the flooding, and then walked down the lower levels in the auxiliary building and verified that penetration seals into the building were not leaking. The inspectors determined that no safety related equipment was impacted by the flooding. Investigation of the flooding event found that a radwaste building sump pump check valve had been blocked open by foreign material.

b. Findings

No findings were identified.

.5 Instrument Air Header Pressure

a. Inspection Scope

On May 18, 2011 at 12:55 p.m., River Bend Station control room operators made a plant announcement that the plant had experienced a slight drop in instrument air header pressure, and for plant personnel that may have knowledge of a leak to report it to the control room. The inspectors responded to the control room at 12:58 p.m. to observe operator response and instrument air header pressure indications. The inspectors verified that the appropriate alarm response procedure had been entered and verified that entry into the abnormal operating procedure for loss of instrument air was not required. The inspectors walked down the instrument air compressors and instrument air header and did not identify any system deficiencies.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 (Closed) NRC Temporary Instruction 2515/183, Followup to the Fukushima Daiichi

Nuclear Station Fuel Damage Event

a. Inspection Scope

The inspectors assessed the activities and actions taken by the licensee to assess its readiness to respond to an event similar to the Fukushima Daiichi nuclear plant fuel damage event. This included:

(1) an assessment of the licensees capability to mitigate conditions that may result from beyond design basis events, with a particular emphasis on strategies related to the spent fuel pool, as required by NRC Security Order Section B.5.b issued February 25, 2002, as committed to in severe accident management guidelines, and as required by 10 CFR 50.54(hh);

(2) an assessment of the licensees capability to mitigate station blackout conditions, as required by 10 CFR 50.63 and station design bases;

(3) an assessment of the licensees capability to mitigate internal and external flooding events, as required by station design bases; and

(4) an assessment of the thoroughness of the walkdowns and inspections of important equipment needed to mitigate fire and flood events, which were performed by the licensee to identify any potential loss of function of this equipment during seismic events possible for the site.

b. Findings

Inspection Report 05000458/2011007 (ML11133A144) documented detailed results of this inspection activity. Following issuance of the report, the inspectors conducted detailed follow-up on selected issues. No findings were identified during this follow-up inspection.

.2 (Closed) NRC Temporary Instruction 2515/184, Availability and Readiness Inspection of

Severe Accident Management Guidelines (SAMGs)

On May 18, 2011, the inspectors completed a review of the licensees severe accident management guidelines (SAMGs), implemented as a voluntary industry initiative in the 1990s, to determine:

(1) whether the SAMGs were available and updated;

(2) whether the licensee had procedures and processes in place to control and update its SAMGs;

(3) the nature and extent of the licensees training of personnel on the use of SAMGs; and

(4) licensee personnels familiarity with SAMG implementation.

The results of this review were provided to the NRC task force chartered by the Executive Director for Operations to conduct a near-term evaluation of the need for agency actions following the Fukushima Daiichi fuel damage event in Japan. Plant-

specific results for River Bend Station were provided as Enclosure 10 to a memorandum to the Chief, Reactor Inspection Branch, Division of Inspection and Regional Support, dated May 26, 2011 (ML111470264)

4OA6 Meetings

Exit Meeting Summary

On May 5, 2011, the inspector conducted a telephonic meeting to discuss the results of in-office inspection of changes to the licensees emergency plan with Mr. D. Burnett, Manager, Emergency Preparedness, and other members of the licensees staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On July 12, 2011, the inspectors presented the integrated inspection results to Mr. E. Olson, Site Vice President, and other members of the licensee 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.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by the licensee and are violations of NRC requirements which meet the criteria of Section 2.3.2 of the NRC Enforcement Policy for being dispositioned as noncited violations:

.1 The licensee identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V,

Instructions, Procedures, and Drawings, for failure to prescribe an activity affecting quality by a procedure that was appropriate to the circumstances. Specifically, Procedure AOP-0050, Station Blackout, has an option to start the emergency diesel generators when no standby starting air is available. The licensee included instructions to attach nitrogen bottles to the starting air system and use nitrogen to air-start the emergency diesel generators. Those instructions were inappropriate because if only nitrogen was injected into the diesels cylinders, no oxygen would be available for combustion and the engine would not start. The licensee implemented corrective actions to revise the appropriate procedure step to use compressed air. The licensee addressed this issue in Condition Report CR-RBS-2011-03488. The finding was more than minor because it affected the equipment performance attribute of the Mitigating Systems Cornerstone and affected the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

As described in Inspection Manual Chapter 0609, the inspectors performed a Phase 1 significance determination process evaluation and determined that a Phase 2 evaluation was required because this finding represented an actual loss of safety function of a single train of equipment for greater than the technical specification allowed outage time.

The inspectors performed a Phase 2 evaluation using the presolved significance determination process worksheets for River Bend Station and determined that this finding screened as Yellow. The senior reactor analyst performed a Phase 3

significance determination process evaluation and determined that the risk significance of the finding was very low because there was only a very small probability that the compressed nitrogen would need to be used for any given diesel start, such that the overall diesel failure probability was only negligibly higher than the baseline value.

.2 In Section 40A3, Licensee Event Report 05000458/2011-002-00, Operations Prohibited

by Technical Specifications Due to Instrument Isolation Valve Mispositioning, discusses a violation of Technical Specifications 3.3.1.1, Reactor Protection System (RPS)

Instrumentation, and 3.3.4.1, End of Cycle Recirculation Pump Trip (EOC-RPT)

Instrumentation. These technical specification sections required reactor protection system channel D functions for turbine control valve and turbine stop valve fast closure, and end of cycle recirculation pump trip function for turbine stop valve number 2 closure initiation be operable prior to exceeding 40 percent reactor thermal power. Contrary to that, on February 13, 2011, the operating shift crew did not recognize that reactor protection system channel D functions for turbine control valve and turbine stop valve fast closure, and end of cycle recirculation pump trip function for turbine stop valve number 2 closure initiation were disabled while the reactor exceeded 40 percent power.

Using Inspection Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheet, the finding was determined to be of very low safety significance (Green),because it was not a design or qualification deficiency; did not represent either a loss of system safety function, an actual loss of safety function of a single train, or an actual loss of safety function; and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event.

.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Burnett, Manager, Emergency Preparedness

G. Bush, Manager, Material, Procurement, and Contracts

M. Chase, Manager, Training

J. Clark, Manager, Licensing

C. Colman, Manager, Engineering Programs & Components

F. Corley, Manager, Design Engineering

R. Creel, Acting Manager, Security

M. Feltner, Manager, Planning and Scheduling, Outages

C. Forpahl, Manager, System Engineering

A. Fredieu, Manager, Outage

W. Fountain, Senior Licensing Specialist

R. Gadbois, General Manager, Plant Operations

T. Gates, Assistant Operations Manager - Shift

H. Goodman, Director, Engineering

R. Heath, Manager, Chemistry

K. Huffstatler, Senior Licensing Specialist

F. Hurst, Planner, Emergency Preparedness

L. Kitchen, Manager, Maintenance

G. Krause, Assistant Operations Manager - Support

C. Loebs, Quality Control Specialist

E. Olson, Site Vice President

R. Persons, Superintendent, Training

G. Pierce, Manager, Radiation Protection

J. Roberts, Director, Nuclear Safety Assurance

T. Shenk, Assistant Operations Manager - Training

M. Spustack, Supervisor, Engineering

J. Standridge, Planner, Emergency Preparedness

N. Tison, Planner, Emergency Preparedness

D. Vines, Manager, Corrective Actions and Assessments

J. Vukovics, Supervisor, Reactor Engineering

L. Woods, Manager, Quality Assurance

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

Failure to Track and Document Plant Equipment Oil Usage

05000458/2011003-01 FIN (Section 1R15)

Attachment

Closed

High Pressure Core Spray System Inoperable Due to Failed

05000458/2010-004-00 LER Motor Oil Reservoir Drain Plug (Section 4OA3)

High Pressure Core Spray System Inoperable Due to Failed

05000458/2010-004-01 LER Motor Oil Reservoir Drain Plug (Section 4OA3)

Operations Prohibited by Technical specifications Due to

05000458/2011-002-00 LER Instrument Isolation Valve Mispositioning (Section 4OA3)