IR 05000458/2024001

Integrated Inspection Report 05000458/2024001

ML24128A043
Person / Time
Site:	River Bend
Issue date:	05/14/2024
From:	Jeffrey Josey NRC/RGN-IV/DORS/PBC
To:	Hansett P Entergy Operations
Schaup W
References
IR 2024001
Download: ML24128A043 (36)

Text

May 14, 2024

SUBJECT:

RIVER BEND STATION - INTEGRATED INSPECTION REPORT 05000458/2024001

Dear Phil Hansett:

On March 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at River Bend Station. On April 11, 2024, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

Eight findings of very low safety significance (Green) are documented in this report. All of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations consistent with section 2.3.2 of the Enforcement Policy.

Two licensee-identified violations which were determined to be of very low safety significance are documented in this report. We are treating these violations as non-cited violations consistent with section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at River Bend Station.

If you disagree with a cross-cutting aspect assignment 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at River Bend Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Jeffrey E. Josey, Chief Reactor Projects Branch C Division of Operating Reactor Safety Docket No. 05000458 License No. NPF-47

Enclosure:

As stated

Inspection Report

Docket No. 05000458

License No. NPF-47

Report Nos. 05000458/2024001

Licensee: Entergy Operations, Inc.

Facility: River Bend Station

Location: St. Francisville, Louisiana

Inspection Dates: January 1, 2024, to March 31, 2024

Inspectors: N. Greene, Senior Health Physicist E. Powell, Resident Inspector E. Simpson, Nuclear Systems Scientist C. Wynar, Senior Resident Inspector

Approved By: Jeffrey E. Josey, Chief Reactor Projects Branch C Division of Operating Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at River Bend Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. Two licensees-identified non-cited violations are documented in report section: 71111.1

List of Findings and Violations

Failure to Test Critical Plant Parameters in Diesel Building Ventilation Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.04 Systems NCV 05000458/2024001-01 Open/Closed The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of Title 10 of the Code of Federal Regulations Part 50, appendix B, criterion III, Design Control, when the licensee failed to verify that diesel building ventilation fan (HVP-FN6A) supplied adequate airflow to maintain the diesel generator control room temperature under the design accident limit temperature.

Failure to have Environmental Qualification Evaluation for Safety-Related Rosemount Transmitters Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.1] - 71111.15 Systems NCV 05000458/2024001-02 Resources Open/Closed The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of Title 10 of the Code of Federal Regulations 50.49, Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants, for the licensees failure to qualify an item of electrical equipment important to safety by acceptable methods. Specifically, installed Rosemount transmitters were not in the configuration qualified by the licensees environmental qualification reports. Since the configuration in the plant is not in accordance with the environmental qualification report, the licensee is required to qualify the Rosemount transmitters by one of the methods as described in Title 10 of the Code of Federal Regulations 50.49 to qualify the configuration in the plant.

Failure to Make Adequate Operability Determinations Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71111.15 Systems NCV 05000458/2024001-03 Complacency Open/Closed The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of Title 10 of the Code of Federal Regulations Part 50, appendix B, criterion V, Instructions, Procedures, and Drawings, with three examples, for the licensees failure to follow Procedure EN-OP-104, Operability Determination Process, a quality related procedure. Specifically, the licensee -failed to evaluate operability of Rosemount transmitters, control building chillers, and safety related piping when conditions were identified that questioned whether there was reasonable assurance that the equipment could perform its specified safety function..

Failure to Correct Safety-Related Building Roof Leaks in a Timely Manner Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.5] - Work 71111.18 Systems NCV 05000458/2024001-04 Management Open/Closed The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of Title 10 of the Code of Federal Regulations Part 50, appendix B, criterion XVI, Corrective Actions, when the licensee failed to correct roof leaks in the safety-

-related auxiliary building.

Failure to Control Transient Combustibles Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.8] - 71152A NCV 05000458/2024001-05 Procedure Open/Closed Adherence The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of License Condition 2.C(10), Fire Protection, with numerous examples for the licensees failure to implement all provisions of the approved fire protection program described in section 9.5.1 of the NRC approved safety evaluation report. The safety evaluation report states that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Safety Analysis Report.

Diesel Building Ventilation Design Calculations Utilized Data Contrary to Updated Safety Analysis Report Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.14] - 71152A Systems NCV 05000458/2024001-06 Conservative Open/Closed Bias The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of Title 10 of the Code of Federal Regulations Part 50, appendix B, criterion III, Design Control, when the licensee utilized incorrect values for exhaust fan flow rates while developing a design calculation for limiting temperature in the emergency diesel generator room and emergency diesel generator control rooms.

Inadequate Procedures, AOP-0007, Manual Reactor Scram Due to Lowering Feedwater Temperature Following an Automatic Isolation of Feedwater Heater String Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green None (NPP) 71153 NCV 05000458/2024001-07 Open/Closed The inspectors reviewed a self-revealed finding of very low safety significance (Green) and associated non-cited violation of Technical Specification section 5.4.1.a, Procedures, for the licensees failure to maintain a procedure required by Regulatory Guide 1.33, revision 2,

Quality Assurance Program Requirements, appendix A, dated February 1978. Specifically, the licensee failed to maintain adequate procedures for operation of the feedwater system below 25 percent rated thermal power. As a result, operators initiated a manual reactor scram due to being in an unanalyzed power to temperature region on the chart in attachment 1 of AOP-0007, Loss of Feedwater Heating.

Inadequate Procedures, GOP-0001, Automatic Reactor Scram Due to a Turbine Trip Following a Disconnect Failure at Switchyard Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green None (NPP) 71153 NCV 05000458/2024001-08 Open/Closed The inspectors reviewed a self-revealed finding of very low safety significance (Green) and associated non-cited violation of Technical Specification section 5.4.1.a, Procedures, for the licensees failure to maintain a procedure required by Regulatory Guide 1.33, Quality Assurance Program Requirements, revision 2, appendix A, dated February 1978.

Specifically, the licensee failed to maintain adequate procedures for operation of the disconnect switches in the switchyard. As a result, operators failed to fully close disconnect switches in the switchyard, which caused the disconnect switches to fail resulting in a turbine runback and automatic reactor scram.

Additional Tracking Items

Type Issue Number Title Report Section Status Licensee 05000458/2023-005-00 Manual Reactor Scram Due 71153 Closed Event to Lowering Feedwater Report Temperature Following an Automatic Isolation of Feedwater Heater String Licensee 05000458/2023-006-00 Automatic Reactor Scram 71153 Closed Event Due to a Turbine Trip Report Following a Disconnect Failure at Switchyard

PLANT STATUS

River Bend Station began the inspection period at 100 percent rated thermal power. On March 15, 2024, the unit was at 100 percent power and down powered to 67 percent power for a planned rod pattern adjustment and returned to 100 percent power on March 16, 2024. On March 17, 2024, the unit was at 100 percent power and down powered to 74 percent power for a planned rod pattern adjustment and returned to 100 percent power on March 18, 2024, where it remained for the rest of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of freezing temperatures on January 13-18, 2024, for the following systems:

• instrument air system heaters

• circulating water system cooling towers

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Reactor recirculation loop A (electrical) on January 25, 2024

(2) residual heat removal B on February 21, 2024

(3) reactor core isolation cooling on February 29, 2024

(4) diesel generator building ventilation on March 19, 2024

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) reactor building ventilation system unit cooler HVR UC6 and UC9 room, fire area AB1/Z-3 and AB15/Z-3, on February 8, 2024

(2) standby switchgear 1C room, fire area C-22, on February 8, 2024

(3) battery 1A room, fire area C-18, on February 22, 2024

(4) high pressure core spray battery room, fire area C-21, on March 29, 2024

(5) cable chase II, fire area C-2, on March 29, 2024

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on January 23, 2024.

71111.06 - Flood Protection Measures

Flooding Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated internal flooding mitigation protections in the reactor core isolation cooling room on February 29, 2024

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during down power on March 15, 2024.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated RSES-LOR-24-05 licensed operator requalification exam on January 30, 2024.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (3 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) CR-RBS-2024-00481 maintenance rule functional failure backlog (350+ not screened) on March 6, 2024

(2) instrument air system on March 20, 2024

(3) diesel generator building ventilation on March 25, 2024

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) elevated risk during low pressure coolant injection pump A start time delay channel calibration and channel functional test on February 1, 2023

(2) elevated risk during residual heat removal B maintenance on March 12, 2024

(3) elevated risk during emergency core cooling system/reactor core isolation cooling system reactor vessel water level low low, level 2; low low low level 1; channel functional test on March 17, 2024

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensees justifications and actions associated with the following operability determinations and functionality assessments:

(1) standby gas treatment damper 1GTS-AOD22A rainwater intrusion on January 26, 2024 (CR-RBS-2024-00642)

(2) main steam positive leakage and control system valve 98D operability evaluation on February 14, 2024 (CR-RBS-2024-00065)

(3) division 1 emergency diesel generator control room high temperature on March 30, 2024 (CR-RBS-2024-00479)

(4) control building chilled water system B high oil on March 30, 2024 (CR--RBS--2024-

-00350)

(5) Rosemount transmitters on March 30, 2024 (CR--RBS-2024--01048)

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) ER-RB-2005-009, EJS-SWG2A rain shield, on March 19, 2024

(2) EC-66878, oil reclaim modification for control building chilled water system chillers, on March 30, 2024

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (3 Samples)

(1) work order (WO) 52999927, division 2 emergency diesel generator maintenance, on February 20, 2024

(2) WO 53038073, high pressure core spray maintenance, on February 26, 2024

(3) WO 00529965/WO 0053037974, residual heat removal B maintenance, on March 20, 2024

Surveillance Testing (IP Section 03.01) (4 Samples)

(1) STP-204-6301, DIV I LPCI (RHR) Pump and Valve Operability Test, revision 031, on February 2, 2024

(2) STP-051-4280, HVR-UC1B Logic System Functional Test, revision 11, on February 13, 2024

(3) STP-309-0207, DIV II EDG Run, revision 35, on February 18, 2024

(4) WO 52995769/WO 52950660, high pressure core spray maintenance and testing, on February 26, 2024

Inservice Testing (IST) (IP Section 03.01) (3 Samples)

(1) CR-RBS-2023-08833 for STP-309-6301, Div I EDG Fuel Oil Transfer Pump and Valve Operability Test, revision 26, IST failure on February 7, 2024

(2) CR-RBS-2023-08982 for STP-410-6503, Div I Chilled Water System Check Valve Operability Test, revision 04, IST failure on February 7, 2024

(3) STP-201-6310, SLC Pump and Valve Operability Test, revision 316, on March 30,

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) Observed the licensee conduct surveys of potentially contaminated packages/equipment from the radiologically controlled area and workers exiting potentially contaminated areas.

(2) Walked down the storage locations for several nonexempt radioactive sources listed in the licensees non-exempt source inventory for the following sources: Source ID #s 6019, 9206, 10408, 09-9139, 136-082, 4997BK, and 83CS-26.

(3) Evaluated the licensees physical and programmatic controls for highly activated and contaminated non-fuel materials stored within the spent fuel pool.

Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)

The inspectors evaluated the licensees control of radiological hazards for the following radiological work:

(1) low risk radiological work and job coverage for radwaste liner processing activities (radiation work permit (RWP) #20241034)

(2) low risk radiological work and job coverage for Traversing Incore Probe (TIP) drive troubleshooting (RWP #20241014, Work Order #00595003-01)

(3) low risk radiological work and job coverage for area radiation monitor detector replacement and calibration (Work Order #54122007-01)

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (4 Samples)

The inspectors evaluated licensee controls of the following high radiation areas (HRAs) and very high radiation areas (VHRAs):

(1) Radwaste Building, 65-foot elevation, Rooms G1, G8, and G9

(2) Radwaste Building, 106-foot elevation, Rooms G4 and G5

(3) Turbine Building, 95-foot elevation, Rooms 01, 19, 23, and 26

(4) Turbine Building, 123-foot elevation, Rooms G1 and G5

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP

Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.

Internal Dosimetry (IP Section 03.03) (3 Samples)

The inspectors evaluated the following internal dose assessments:

(1) CR-RBS-2023-02536, Personnel Contamination Event (PCE) 2023-006, Dose Assessment, dated March 25, 2023

(2) CR-RBS-2023-01155, No PCE report, Dose Assessment, dated February 21, 2023

(3) CR-RBS-2023-02960, PCE 2023-007, Dose Assessment, dated April 12, 2023

Special Dosimetric Situations (IP Section 03.04) (3 Samples)

The inspectors evaluated the following special dosimetric situations:

(1) use of multi-pack dosimetry and dose assignment on activities related to RWP 20231295

(2) use of multi-pack dosimetry and dose assignment on activities related to RWP 20221225

(3) monitoring of three declared pregnant workers and their associated NRC Form 5s

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===

(1) January 1, 2023, through December 31, 2023

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)

(1) January 1, 2023, through December 31, 2023

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)

(1) January 1, 2023, through December 31, 2023

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) January 1, 2023, through December 31, 2023

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) January 1, 2023, through December 31, 2023

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) CR-RBS-2023-08025 extent of condition with environmental qualification components not classified correctly in Maximo

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000458/2023-005-00, Manual Reactor Scram Due to Lowering Feedwater Temperature Following an Automatic Isolation of Feedwater String (ADAMS Accession No. ML24016A189)

The inspection conclusions associated with this LER are documented in this report under Inspection Results section 71153. This LER is closed.

(2) LER 05000458/2023-006-00, Automatic Reactor Scram Due to a Turbine Trip Following a Disconnect Failure at Switchyard (ML24039A130)

The inspection conclusions associated with this LER are documented in this report under Inspection Results section 71153. This LER is closed.

INSPECTION RESULTS

Failure to Test Critical Plant Parameters in Diesel Building Ventilation Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.04 Systems NCV 05000458/2024001-01 Open/Closed The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of Title 10 of the Code of Federal Regulations Part 50, appendix B, criterion III, Design Control, when the licensee failed to verify that diesel building ventilation fan (HVP-FN6A) supplied adequate airflow to maintain the diesel generator control room temperature under the design accident limit temperature.

Description:

While reviewing design basis calculation G13.18.2.1*083, Diesel Generator Building Design Basis Calculation - Summer Condition, the inspectors questioned how the licensee was monitoring airflow supplied by fan HVP-FN6A because the calculation determined that for the worst-case conditions, only a quarter of a degree of margin remained to the maximum allowed temperature (104F) for the diesel control room.

With such a small margin the inspectors determined it was necessary for the licensee to demonstrate that the diesel building ventilation fans, specifically fan HVP-FN6A, could supply the minimum airflow the calculation prescribed to maintain the room under design maximum temperature. The USAR and Specification 216.300, AIR CONDITIONING AND VENTILATION SYSTEMS - AIR AND HYDRONC BALANCING, both list the total air flow for FN6A as 3,500 CFM with 2,400 CFM going to the control room and 1,100 CFM going to the exciter cabinet.

The inspectors found only one instance of testing conducted by the licensee in calculation G13.18.2.1*039, D/G BLDG DIV I & II T's BASED ON AS RECORDED CFM where the measured air flow for HVP-FN6A was 2,462 CFM going to the control room, and 1101 CFM going to the exciter cabinet. The inspectors determined that if airflow for the control room was below the calculated required airflow specified in the design calculation, the temperature in the diesel control room would exceed 104F which would result in the diesel generator room exceeding its design temperature. As such, the inspectors determined that the licensee did not have a testing program for the fan to validate that plant conditions ensured the design control standards were met.

Corrective Actions: The licensee entered this issue into their corrective action program.

Corrective Action References: CR-RBS-2024-00667

Performance Assessment:

Performance Deficiency: Title 10 CFR Part 50, requires, in part, that licensee provide for verifying or checking the adequacy of design such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. The inspectors determined that the failure to perform air flow testing of the diesel building ventilation fan to confirm the air flow requirements identified in the USAR and Calculation G13.18.2.1*083 was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, by not verifying the fans output the airflow dropped below the minimum required per calculation G13.18.2.1*083. This may challenge the diesel building ventilation's ability to perform the design basis function of maintaining the temperature of the diesel and diesel control room within limits.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (Green) because

(1) it was not a deficiency affecting the design or qualification of a mitigating SSC

(2) the degraded condition did not represent a loss of the PRA function of a single train TS system for greater than its TS allowed outage time

(3) the degraded condition did not represent a loss of the PRA function of one train of a multi-train TS system for greater than its TS allowed outage time

(4) the degraded condition did not represent a loss of the PRA function of two separate TS systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

(5) the degraded condition did not represent a loss of a PRA system and/or function as defined in the PRIB or the licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and (6)the degraded condition did not represent a loss of the PRA function of one or more non-TS trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program for greater than 3 days.

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that the licensee provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.

Contrary to this requirement, from March 9, 1998, to March 31, 2024, the licensee failed to verify the adequacy of design. Specifically, the licensee failed to verify that the diesel building supply fans provided the correct airflow to maintain the diesel generator control room under the design temperature limit of 104F.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Licensee-Identified Non-Cited Violation 71111.12 This violation of very low safety significance (Green) was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Violation: Title 10 CFR 50.65(a)(2) states, in part, that monitoring as specified in 10 CFR 50.65(a)(1) is not required where it has been demonstrated that the performance or condition of an SSC is being effectively controlled through the performance of appropriate preventive maintenance, such that the SSC remains capable of performing its intended function.

Contrary to the above, on January 18, 2024, the licensee failed to demonstrate that the performance or condition of SSCs are being effectively controlled through the performance of appropriate preventative maintenance, such that the SSC remains capable of performing its intended function. Specifically, by not screening approximately 360 condition reports within 30 days in accordance with the stations -maintenance rule program, the licensee failed to monitor the condition of 35 SSCs.

Significance/Severity: - The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (Green) because

(1) it was not a deficiency affecting the design or qualification of a mitigating SSC

(2) the degraded condition did not represent a loss of the PRA function of a single train TS system for greater than its TS allowed outage time

(3) the degraded condition did not represent a loss of the PRA function of one train of a multi-train TS system for greater than its TS allowed outage time

(4) the degraded condition did not represent a loss of the PRA function of two separate TS systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

(5) the degraded condition did not represent a loss of a PRA system and/or function as defined in the PRIB or the licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and

(6) the degraded condition did not represent a loss of the PRA function of one or more non-TS trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program for greater than 3 days.

Corrective Action References: CR-RBS-2024-00481

Licensee-Identified Non-Cited Violation 71111.12 This violation of very low safety significance (Green) was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Violation: Title 10 CFR 50.65(a)(1), requires, in part, that the holders of an operating license shall monitor the performance or condition of SSCs within the scope of the rule as defined by 10 CFR 50.65(b), against licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs can fulfill their intended functions.

Contrary to the above, on March 19, 2024, the licensee failed to monitor the performance or condition of an SSC within the scope of the rule as defined by 10 CFR 50.65(b), against licensee-established goals, in a manner to provide reasonable assurance the SSC could fulfill its intended function. Specifically, during the licensees review of the CR backlog, it was identified that the instrument air system should have been evaluated for (a)(1) status due to exceeding the (a)(2) criteria of more than two failures to start, with three failures to start of the diesel air compressors.

Significance/Severity: The inspectors assessed the significance of the finding using IMC 0609 appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (Green) because

(1) it was not a deficiency affecting the design or qualification of a mitigating SSC

(2) the degraded condition did not represent a loss of the PRA function of a single train TS system for greater than its TS allowed outage time

(3) the degraded condition did not represent a loss of the PRA function of one train of a multi-train TS system for greater than its TS allowed outage time

(4) the degraded condition did not represent a loss of the PRA function of two separate TS systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

(5) the degraded condition did not represent a loss of a PRA system and/or function as defined in the PRIB or the licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and (6)the degraded condition did not represent a loss of the PRA function of one or more non-TS trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program for greater than 3 days.

Corrective Action References: CR-RBS-2024-01777 and CR-RBS-2024-01932

Failure to have Environmental Qualification Evaluation for Safety-Related Rosemount Transmitters Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.1] - 71111.15 Systems NCV 05000458/2024001-02 Resources Open/Closed The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of Title 10 of the Code of Federal Regulations 50.49, Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants, for the licensees failure to qualify an item of electrical equipment important to safety by acceptable methods.

Specifically, installed Rosemount transmitters were not in the configuration qualified by the licensees environmental qualification reports. Since the configuration in the plant is not in accordance with the environmental qualification report, the licensee is required to qualify the Rosemount transmitters by one of the methods as described in Title 10 of the Code of Federal Regulations 50.49 to qualify the configuration in the plant.

Description:

During a walkdown of the plant, the inspectors identified a difference in configurations for various models of Rosemount pressure and level transmitters. The inspectors noted different components (i.e. fittings, valves, and plugs) on the process connections for Rosemount series 1152, 1153, 1154, and 3153 transmitters. The licensee documented the issue in the corrective action program as condition report CR-RBS-2024-01048.

The inspectors reviewed the environmental qualification assessment reports (EQARs) for each model and concluded that configurations installed in the plant were not environmentally qualified based upon the following.

For the 1153 and 1154 models, the vendor manual design specifications broke down the serial numbers and a note for certain models specifically stated that the customer assumes responsibility for qualifying process interfaces on these options. The vendor provides a specific model option that was environmentally qualified and other model options with the above note.

The qualification reports referenced in each EQAR state that the only tested configuration qualifying these transmitters were ones with welded compression fit Swagelok valves on the process connection interface and the vent/drain interface. The configurations installed in the plant are not ones with the compression fit Swagelok connections and therefore the note about end user having qualification responsibility is applicable. The license had no documentation to support qualification of the alternate configurations.

NUREG 0588 and IEEE Standard 323-1974 both state that environmental qualification for electrical components, to meet Regulatory Guide 1.89 requirements, need to include the process connections that could affect the output of the instrument.

The inspectors identified numerous examples of installed transmitters that were of the model containing the note about customer responsibility for qualifying the equipment. The installed transmitters on site for each model are not the tested configuration qualified in the EQARs and test reports. Therefore, the inspectors concluded that these transmitters were not environmentally qualified and could not be relied upon to perform the required function for the specified mission time under all accident conditions.

Corrective Actions: The license entered this issue into their corrective action program.

Corrective Action References: CR-RBS-2024-01048

Performance Assessment:

Performance Deficiency: Failure to maintain equipment required to be environmentally qualified is reasonably in the licensee ability to foresee and correct and therefore a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to ensure the installed configuration of transmitters were environmentally qualified in order to perform their safety function.

Significance: The inspectors assessed the significance of the finding using IMC 0609, appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using exhibit 2, Mitigating Systems Screening Questions, the inspectors determined this finding to be of very low safety significance (Green) because it was a deficiency affecting the design or qualification of equipment, but the equipment maintained its PRA functionality.

Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. The licensee failed to utilize the environmental qualification report when selecting which configuration of transmitters were to be installed into the plant.

Enforcement:

Title 10 CFR 50.49, Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants, section

(f) requires that each item of electric equipment important to safety must be qualified by one of the following methods:

(1) Testing an identical item of equipment under identical conditions or under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

(2) Testing a similar item of equipment with a supporting analysis to show that the equipment to be qualified is acceptable.

(3) Experience with identical or similar equipment under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

(4) Analysis in combination with partial type test data that supports the analytical assumptions and conclusions.

Contrary to the above since 1985 to March 31, 2024, the licensee failed to qualify an item of electrical equipment important to safety by one of the following methods:

(1) Testing an identical item of equipment under identical conditions or under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

(2) Testing a similar item of equipment with a supporting analysis to show that the equipment to be qualified is acceptable.

(3) Experience with identical or similar equipment under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

(4) Analysis in combination with partial type test data that supports the analytical assumptions and conclusions.

Specifically, the licensee has numerous Rosemount transmitters, important to safety, installed in multiple systems in a configuration that the licensee has not qualified that may not perform their intended function under the environmental conditions described by 10 CFR 50.49.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Failure to Make Adequate Operability Determinations Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71111.15 Systems NCV 05000458/2024001-03 Complacency Open/Closed The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of Title 10 of the Code of Federal Regulations Part 50, appendix B, criterion V, Instructions, Procedures, and Drawings, with three examples, for the licensees failure to follow Procedure EN-OP-104, Operability Determination Process, a quality related procedure. Specifically, the licensee-failed to evaluate operability of Rosemount transmitters, control building chillers, and safety related piping when conditions were identified that questioned whether there was reasonable assurance that eh equipment could perform its specified safety function.

Description:

During the inspection period, the inspectors brought several operability concerns to the licensee, two of which resulted in inadequate operability determinations, and the third did not have an operability performed at all.

The first example was for a condition identified with the control building air conditioning system. The system is composed of four 100 percent capacity chillers each rated at 189 tonnes. Each chiller can handle a design basis accident heat load that maintains all components in the control building below the maximum design temperature for each component.

Condition report CR-RBS-2016-06386 described an event where the D chiller had tripped due to high bearing temperature. The licensee investigation determined that all the chillers were susceptible to a phenomenon called oil stacking. This is when low loading on the compressor results in a buildup of oil in the evaporator. This is significant because the refrigerant flow is the driving force for the oil going through the system to return to the compressor so it can be distributed on the bull gears and bearings for lubrication. The oil is inherently entrained in the refrigerant and during low load conditions there is not enough driving force to carry it through the system, and the result is a buildup of oil in the evaporator. As this occurs, oil is lost from the sump which results in low oil levels in the sight glass.

Operators would find this condition and correct it by performing oil additions. When load conditions increased, typically from weather, the compressor vanes would open and increase the flow of refrigerant. This would cause the stacked oil in the evaporator to then return to the compressor sump and cause a high oil level, resulting in a high temperature bearing trip.

The licensee attempted to correct this by adding a modification under Engineering Change EC66878. This modification is a series of piping designed to tap into the evaporator, skim off the excess oil, and return it to the sump. This significantly reduced the number of low sump levels and oil additions. Additionally, since implementation of the modification no chillers have tripped off due to oil level conditions.

The oil stacking phenomenon still occurs at low load conditions, but stacking and subsequent oil additions still occur. The magnitude and frequency have just been reduced. By auditing the oil addition logs, the inspectors found that there was a buildup of oil in the evaporators that the modification was not returning to the sump. This was evident by the amount of oil additions the licensee was still performing. Since these compressors are sized for accident conditions, they normally operate below 70 percent load for accident conditions.

After inspectors identified the issue the licensee initiated condition report CR-RBS-2024-00496, documenting that the licensee failed to evaluate whether a fully loaded compressor could generate enough refrigerant flow such that the stacked oil in the evaporator could return to the sump and cause a trip, preventing the system from meeting its 30-day accident mission time.

The second example was for a condition that was identified with Rosemount transmitters installed in the plant. The inspectors identified that the Rosemount transmitters were not environmentally qualified because they were installed in a different configuration than what was tested in the qualification package. The licensee failed to address that the transmitters were not environmental qualified as a part of the operability determination as documented in CR-RBS-2024-01048.

The third example was a potential Part 21 notification made by the vendor of a computer software program used by the licensee to calculate seismic loading in piping systems at the site. The notification was documented in corporate condition reports CR-HQN-2023-03844 and CR-RBS-2024-0-1288. These CRs identified several station calculations that used the software to conduct evaluations on safety -related systems. The licensee failed to evaluate how the Part 21 notification could have affected the operability of these safety related systems.

Corrective Actions: The licensee entered this issue into their corrective action program.

Corrective Action References: CR-RBS-2024-01048, CR-RBS-2024-00496, and CR-RBS-2024-01288

Performance Assessment:

Performance Deficiency: Station procedure EN-OP-104, Operability Determination Process, requires that the licensee perform an evaluation for conditions potentially affecting a safety related systems ability to perform its intended safety function to determine if the system remains operable. The inspectors determined that the licensee failed to perform adequate operability evaluations per EN-OP-104 was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failure to conduct adequate operability evaluations does not provide reasonable assurance a safety related system can perform its safety function.

Significance: The inspectors assessed the significance of the finding using IMC 0609, appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (Green) because

(1) it was not a deficiency affecting the design or qualification of a mitigating SSC

(2) the degraded condition did not represent a loss of the PRA function of a single train TS system for greater than its TS allowed outage time

(3) the degraded condition did not represent a loss of the PRA function of one train of a multi-train TS system for greater than its TS allowed outage time

(4) the degraded condition did not represent a loss of the PRA function of two separate TS systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

(5) the degraded condition did not represent a loss of a PRA system and/or function as defined in the PRIB or the licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and

(6) the degraded condition did not represent a loss of the PRA function of one or more non-TS trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program for greater than 3 days.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. The licensee was complacent in evaluating all attributes that go into an operability, for instance whether or not something is environmentally qualified ensures a component can function in an accident environment. Relying on previous tests or current functionality does not ensure this. In regard to the part 21 evaluation an operability was required to determine the scope of the issue and how it affected immediate operability; waiting for the completion of the part 21 process would not have been timely.

Enforcement:

Violation: Title 10 CFR Part 50, appendix B, criterion V, Instructions, Procedures, and Drawings, requires that, activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

The licensee established Procedure EN-OP-104, Operability Determination Process, a quality related procedure, that requires the licensee to determine whether a degraded or nonconforming condition exists, and if one does, to perform an evaluation that assesses all aspects of operation.

Contrary to the above, from January 26, 2024, to March 31, 2024, the licensee failed to follow station procedure EN-OP-104, Operability Determination Process. Specifically, the licensee failed to perform adequate operability evaluations for conditions identified for Rosemount transmitters, control building chillers, and system piping affected by a Part 21 issue describing an error in AutoPipe software to determine if the affected safety related systems remained operable.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Failure to Correct Safety-Related Building Roof Leaks in a Timely Manner Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.5] - Work 71111.18 Systems NCV 05000458/2024001-04 Management Open/Closed The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of Title 10 of the Code of Federal Regulations Part 50, appendix B, criterion XVI, Corrective Actions, when the licensee failed to correct roof leaks in the safety-related auxiliary building.

Description:

During multiple walkdowns and tours of the auxiliary building, the inspectors observed that after rain events, water entered the building through the roof and pooling around safety-related switchgear as well as the perimeter of both safety-related trains of standby gas treatment.

The inspectors reviewed previous condition reports and noted that the licensee had documented water entering through the roof and pooling around safety related equipment numerous times dating back to 2003.

In 2005 the licensee implemented a modification (ER-RB-2005-0009) adding a rain shield canopy on top of Auxiliary Building 480 volt switchgear, EJS-SWG2A. This was done after rain had entered the switchgear causing it to fail. The canopy now diverts rain leakage onto the ground around the switchgear.

Condition reports have documented the rain continuing to be an issue as recently as 2023.

Condition report CR-RBS-2019-00987 which documented rain water intrusion into the auxiliary building in the vicinity of EJS-SWG2A through roof leaks was screened as part of the licensees corrective action process as non-adverse and had an action to generate a work order that was never initiated.

The inspectors identified that for condition reports documenting roof leaks in the auxiliary building both around the switchgear and in other locations were screened as non-adverse.

Various work trackers had been generated to keep track of the issues and correct it; however, work trackers and any non-adverse screened condition reports that generate a work order are outside of the corrective action program and require no controls for cancelling them.

Station procedure EN-LI-102, Corrective Action Program, revision 51, states, any condition report screened as non-adverse is outside of the corrective action program.

Section 3C.4.5.2 of the updated safety analysis report (USAR), states, that there are no sources of external leakage into the auxiliary building.

The inspectors determined that water intrusion via rain, whether it is landing on safety-

-related equipment or not, is a condition adverse to quality and is required to be tracked and corrected in accordance with the licensees corrective action program.

Corrective Actions: The license entered this issue into their corrective action program.

Corrective Action References: CR-RBS-2024-00915

Performance Assessment:

Performance Deficiency: Title 10 CFR Part 50, appendix B, criterion XVI, states that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. EN-LI-102, Corrective Action Program, rev 052 requires the site to identify conditions adverse to quality and track them in the corrective action program in order to correct them. Failure to do this is reasonable and within the licensees ability to foresee and correct and is a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, allowing water intrusion into a safety related building degrades the protection against external factors attribute and puts other safety related equipment at risk. In one case the licensee relied on an expired compensatory measure to divert rain leakage onto the ground.

Significance: The inspectors assessed the significance of the finding using IMC 0609, appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (Green) because -it did not represent a loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiation event for greater than 14 days.

Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities.

Enforcement:

Violation: Title 10 CFR Part 50, appendix B, criterion XVI, Corrective Actions, states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

Contrary to the above, from February 2019 to March 30, 2024, the licensee failed to identify and correct a condition adverse to quality. Specifically, the licensee failed to identify roof leaks in a safety related building as a condition adverse to quality preventing a timely corrective action.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Failure to Control Transient Combustibles Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.8] - 71152A NCV 05000458/2024001-05 Procedure Open/Closed Adherence The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of License Condition 2.C(10), Fire Protection, with numerous examples for the licensees failure to implement all provisions of the approved fire protection program described in section 9.5.1 of the NRC approved safety evaluation report. The safety evaluation report states that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Safety Analysis Report.

Description:

In NRC inspection report 05000458/2023003, the inspectors documented a semi-annual trend review of the licensee failing to follow multiple procedures regarding work in progress (WIP) signs. The licensee was utilizing WIP signs to justify temporary storage of equipment and supplies in the plant.

After 90 days, the licensee was required to either analyze the equipment being stored under the WIP or remove it. The trend write-up provided multiple examples of WIP signs in the plant with equipment still staged or stored past 90 days The inspectors reviewed this issue further and determined the licensee utilized site Procedure ADM-0073, Temporary Services and Equipment, revision 308, as the basis for storing transients throughout the plant, even when no work was in an active status. Section 8.2.2 states, Screen the temporary service and equipment (TSE) to determine if the requirements of station procedure EN-DC-161, Control of Combustibles, revision 26, are satisfied.

The WIP signs have specific locations for personnel to sign off that they reviewed ADM-0073 and EN-DC-161 before staging the temporary services or equipment. Procedure ADM-0073 was no longer being used by the licensee; however, there was still a signature block on the WIP signs saying the procedure was reviewed. Procedure ADM-0073, section 8.4.4, requires reviewing station procedure EN-MA-132, Housekeeping/Facility and Ground Maintenance, which is also a procedure the licensee is no longer using. As part of corrective actions, the licensee has reinstated the use of procedure ADM-0073.

Station procedure EN-DC-161 outlines how combustibles are to be controlled in the plant either with WIP signs or transient combustible permits (TCP) and what amount and type require fire engineer approval prior to staging. EN-DC-161 breaks the plant out into 1 of 4 fire areas.

Level 1 is a fire sensitive area where transients are not allowed to be left unattended unless they meet specific exemptions, level 2 is an area where transients are permitted but only with strict controls, level 3 is an area were controls are still in place but to a lesser extent than level 2, and a level 4 area has no controls beside standard industrial housekeeping practices.

Section 5.3.a states that TCPs can be used for 90 days and extended to 180 days with approval by the fire marshal and assistant operations manager. Section 5.3.c states that TCPs cannot be used for greater than 180 days and after such time a CR must be generated, and an evaluation performed. Work order 00542489 was used for a job in a level 2 area, AB-1/2-3, as designated by EN-DC-161. The TCP was issued on June 1, 2023, and as of December 20, 2023, was still being used with the WIP to justify storage of transient combustibles. The operations manager and fire marshal did not sign the permit for the 90-day extension and no condition report was generated after it had been in place more than 180 days. Additional examples of expired WIP signs on transients have been documented in NRC identified CRs: RBS-2023-05954, 05443, 04807, 04802, 07757. These examples are contrary to EN-DC-161, section 7.1.11.a, which states that, waste, debris, packing materials, scrap, oil spills, or other combustibles resulting from the work activity should be removed promptly following completion of the work or at the end of each shift.

Station procedure EN-DC-161, section 7.5, describes transient combustible controls. It describes what materials are exceptions and the aggregate threshold limit for level 1 through 4 areas. If the aggregate total for any particular level is exceeded, then a TCP and a transient combustible evaluation is required and based on the evaluation, compensatory measures may have to be taken.

The space outside the dry well airlock is classified as a level 1 zone per attachment 3 of EN-DC-161. Section 7.5.2.c defines the aggregate limit of a level 1 area as zero and section 7.5.2.f states that a TCP, TCE, and compensatory measures are required. Contrary to this, the licensee did not have a TCP, TCE, or any measures established for a level 1 zone with far more than the allowable limit of 0. The control rod drive repair room is a designated level 2 fire area. CR-RBS-2024-01846 documented housekeeping issues with the space with no transient combustible controls. The inspectors determined this area exceeded the level of transient combustibles for a level 2 area and required a TCP.

Corrective Actions: The licensee cleaned up all locations with transients without active WIP signs and entered this issue into their corrective action program.

Corrective Action References: CR-RBS-2023-09245

Performance Assessment:

Performance Deficiency: Station procedures ADM-0073 and EN-DC-161 establish requirements to properly control transient combustibles, including using transient combustible permits (TCP) when the values of transient combustibles allowed were surpassed. The inspectors determined that failing to follow station procedures for controlling combustible materials and not using transient combustible permits was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. The site was failing to properly control transient combustibles in the plant per procedure. This prevented their fire engineer from being able to evaluate the transient combustibles against the sites combustible loading calculations in order to determine the remaining margin.

Significance: The inspectors assessed the significance of the finding using IMC 0609, appendix A, The Significance Determination Process (SDP) for Findings At-Power. Because the finding involved the Fire Prevention and Administrative Controls the inspectors applied IMC 0609, appendix F, Fire Protection SDP, to determine the findings significance. Using attachment 2 to appendix F, Fire Protection Significance Determination Process, this issue was determined to be a finding against the combustible controls program, and determined the finding had a low degradation rating. Further, the inspectors determined that there were adequate fire suppression and detection systems in the areas where the transient combustible were stored, and therefore, they concluded that the performance deficiency was of very low safety significance (Green).

Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. The licensee failed to follow procedure EN-DC-161 that governs the use of transient combustibles.

Enforcement:

Violation: The River Bend Station, Unit 1, Renewed Facility Operating License, section 2.C(10), and attachment 4, requires that the licensee implement and maintain in effect all provisions of the approved fire protection program. The approved fire protection plan for controlling transient combustibles in the plant that the licensee uses are procedures EN-DC-161 and ADM-0073.

Contrary to the above, from June 2023 to March 2024, the licensee failed to ensure that procedures controlling TCPs were followed in order to control combustibles and meet the fire protection plan.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Diesel Building Ventilation Design Calculations Utilized Data Contrary to Updated Safety Analysis Report Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.14] - 71152A Systems NCV 05000458/2024001-06 Conservative Open/Closed Bias The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of Title 10 of the Code of Federal Regulations Part 50, appendix B, criterion III, Design Control, when the licensee utilized incorrect values for exhaust fan flow rates while developing a design calculation for limiting temperature in the emergency diesel generator room and emergency diesel generator control rooms.

Description:

While performing an equipment alignment inspection on the emergency diesel generator (EDG) building ventilation system, the inspectors reviewed design calculation G13.18.2.1*083, Diesel Generator Building Design Basis Calculation-Summer Condition, to verify the diesel room and diesel control room could remain under the limiting temperature conditions of 120F for the diesel room and 104F for the diesel control room as stated in the updated safety analysis report (USAR).

The inspectors wanted to verify exhaust fan air flow rates for fans FN6A and FN6B due to the low margin to the maximum allowable temperature. The calculation concluded that during maximum accident conditions the control room would reach 103.96 degrees. The calculation utilized a total air flow rate for FN6A of 3,850 CFM with 2,640 CFM going to the control room and 1,210 CFM going to the exciter panel.

The inspectors reviewed calculation G13.18.2.1*039, D/G BLDG DIV I & II T's BASED ON AS RECORDED CFM, that measured air flow for FN6A as 2,462 CFM to the control room, 178 CFM less than the flow rate used in calculation G13.18.2.1*083 determine maximum room temperature.

Inspectors also noted that specification 216.300, AIR CONDITIONING AND VENTILATION SYSTEMS - AIR AND HYDRONC BALANCING, lists the total air flow for FN6A as 3,500 CFM with 2,400 CFM going to the control room and 1,100 CFM going to the exciter cabinet. Additionally, USAR table 9.4-8 also lists the fan as having a total capacity of 3,500 CFM and figure 9.4-5 is a drawing depicting 2,400 CFM to the control room and 1,100 CFM to the exciter.

The inspectors determined that the licensee had used flow data that was contrary to actual measured flow data in the stations analysis, and if the correct the air flow rates from either the measured air flow rate calculation or the USAR air flow rates are entered into the G13.18.2.1*083 calculation, the temperature in the control room could exceed 104F and exceeds the maximum temperature limit for the space as describe in USAR table 9.4-1.

Corrective Actions: The licensee entered this issue into their corrective action program.

Corrective Action References: CR-RBS-2024-00667

Performance Assessment:

Performance Deficiency: The failure to use the USAR stated or measured air flow values for exhaust fan flow rate into a design calculation demonstrating the EDG room remains under the USAR temperature limits is a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the calculational errors in G13.8.2.1*083 utilize incorrect and unverified values for exhaust fan FN6A. When using the documented values for exhaust fan air flow, the room temperature exceeds the maximum temperature limit during accident conditions.

Significance: The inspectors assessed the significance of the finding using IMC 0609, appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using exhibit 2, Mitigating Systems Screening Questions,, the inspectors determined this finding to be of very low safety significance (Green) because it was a deficiency affecting the design or qualification of equipment, but the equipment maintained its PRA functionality.

Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe to proceed, rather than unsafe to stop. The licensee had two design documents and one testing document all demonstrating what the actual airflow was, but they chose to not question if those were the correct values and instead extrapolated an airflow that worked for the design calculation.

Enforcement:

Violation:

Title 10 CFR Part 50, appendix B, criterion III, Design Control, requires, in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.

Contrary to the above, from December 1998 to March 2024, the licensee utilized extrapolated values contrary to design documents, test results, and the USAR to create a design calculation to ensure the diesel control room remains under its maximum temperature limit. If the correct values were used from the USAR the design calculation for the diesel control room temperature exceeds the 104F limit.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Inadequate Procedures, AOP-0007, Manual Reactor Scram Due to Lowering Feedwater Temperature Following an Automatic Isolation of Feedwater Heater String Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green None (NPP) 71153 NCV 05000458/2024001-07 Open/Closed The inspectors reviewed a self-revealed finding of very low safety significance (Green) and associated non-cited violation of Technical Specification section 5.4.1.a, Procedures, for the licensees failure to maintain a procedure required by Regulatory Guide 1.33, revision 2, Quality Assurance Program Requirements, appendix A, dated February 1978. Specifically, the licensee failed to maintain adequate procedures for operation of the feedwater system below 25 percent rated thermal power. As a result, operators initiated a manual reactor scram due to being in an unanalyzed power to temperature region on the chart in attachment 1 of AOP-0007, Loss of Feedwater Heating.

Description:

On November 17, 2023, during power ascension from 30 percent reactor power, River Bend Station main control room received alarm number 0298, TURBINE RUNBACK FEEDWATER HTR STRING ISOLATION (H13-P870/54A/D03). The alarm cleared immediately. The A low-pressure heater string isolated and low-pressure heater bypass valve (CNM-MOV136) opened as expected. The main control room operators entered AOP-

-0007, Loss of Feedwater Heating, revision 37, and AOP-0024, Thermal Hydraulic Instabilities, revision 36.

Reactor engineering began to monitor reactor power increasing to 1,020 MWth because of the reduced feed water temperature. Reactor engineering noted that the plant was operating in the alternate trip reference region of AOP-0007, attachment 1. Due to the plant conditions, the crew was procedurally prohibited from upshifting reactor recirculation pumps during a loss of feedwater heating event.

Operators verified they were below the 50-degree loss of feedwater heating line and still in the restricted region of the power to flow map. Operations asked reactor engineering to provide control rod insertion to exit the restricted region. Reactor engineering provided reverse insert order sheets for group 8 and a target power of <750 MWth.

The restricted region was exited, but feedwater temperature continued to fall as rods continued to be inserted. As the target power was approached, the control room supervisor noted that reactor power was approaching the minimum power condition of the AOP--0007 feedwater temperature versus power chart. Power was reduced to approximately 24 percent.

No guidance was provided in AOP-0007 for power below 25 percent. Power continued to slowly increase while feedwater temperature slowly decreased.

The control room supervisor requested reactor engineering provide any other information/data for operations at less than 25 percent. Reactor engineering reviewed the AOP-0007 and performed an extrapolation of the last two points on the attachment 1 curve to determine what the limiting temperature could be for 750 MWth / 24.2 percent.

As a result of the plant conditions and lack of procedural guidance, the operators made the decision to scram the plant. At 2355 on November 17, 2023, main control room operators initiated a manual reactor scram due to feedwater heater string A isolation as described in CR--RBS--2023--08569. The plant was placed in a stable condition and GOP-0002 was entered. River Bend Station never fell below the prohibited region of the feedwater temperature graph in AOP-0007.

The inspectors reviewed AOP-0007, Loss of Feedwater Heating, and determined that it did not contain adequate information for power operation below 25 percent rated thermal power to avoid the operators initiating a manual reactor scram.

Corrective Actions: The licensee entered this issue into their corrective action program and revised procedure AOP--0007.

Corrective Action References: CR--RBS--2023--08578

Performance Assessment:

Performance Deficiency: The failure to maintain an adequate procedure for loss of feedwater heating in accordance with the requirements of Technical Specification Section 5.4.1.a, Procedures, for the licensees failure to maintain a procedure required by Regulatory Guide 1.33, Quality Assurance Program Requirements, revision 2, appendix A was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the performance deficiency resulted in a manual scram actuation due to a feedwater heater string isolation.

Significance: The inspectors assessed the significance of the finding using IMC 0609, appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined that the finding was of very low safety significance (Green) because although the feedwater heater isolation did cause a reactor trip, there was no loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, revision 2, appendix A, dated February 1978. Regulatory Guide 1.33, revision 2, appendix A, section 4 addresses, Procedures for Startup, Operation and Shutdown of Safety-Related BWR Systems and section 4.o addresses Feedwater System.

Contrary to the above, from September 25, 1984, to January 2, 2024, the licensee failed to establish a procedure to address the requirements of Regulatory Guide 1.33, appendix A, section 4.o covering the operation of the feedwater system below 25 percent thermal power.

Specifically, station procedure AOP-0007 did not include instructions for operators to continue operation of the feedwater system below 25 percent thermal power resulting in the operator manually scramming the reactor when a scram would not have been required if the instructions were in the procedure.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Inadequate Procedures, GOP-0001, Automatic Reactor Scram Due to a Turbine Trip Following a Disconnect Failure at Switchyard Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green None (NPP) 71153 NCV 05000458/2024001-08 Open/Closed The inspectors reviewed a self-revealed finding of very low safety significance (Green) and associated non-cited violation of Technical Specification section 5.4.1.a, Procedures, for the licensees failure to maintain a procedure required by Regulatory Guide 1.33, Quality Assurance Program Requirements, revision 2, appendix A, dated February 1978.

Specifically, the licensee failed to maintain adequate procedures for operation of the disconnect switches in the switchyard. As a result, operators failed to fully close disconnect switches in the switchyard, which caused the disconnect switches to fail resulting in a turbine runback and automatic reactor scram.

Description:

On December 13, 2023, numerous alarms were received on all panels in the main control room simultaneously. The reactor automatically scrammed, and operators placed the mode switch in the shutdown position and verified all control rods were inserted.

Operators entered EOP-0001, RPV Control, AOP-0001, Reactor Scram, AOP-0002, Turbine Generator Trips, and AOP-0003, Automatic Isolations. All three reactor feed pumps tripped. Operators established level control with the reactor core isolation cooling (RCIC) system. After reactor water level was stabilized, operators returned B reactor feed pump to service as the method for water level control and secured the RCIC system.

The licensee identified catastrophic damage to the main transformer side of the River Bend Station generator output breaker disconnect switches YMCSW20636 and YMCSW20639.

In support of work orders 00593359 and 54072122 performed during a recent planned outage, disconnects switches YMCSW20636 and YMCSW20639 were opened by operations on November 12, 2023, under tagout 1C22-1 111-003-B-Bearing #2 and then closed when the tags were removed later the same day. Upon investigation, the disconnects were found to have been damaged on the C phase. The disconnects were both locked in a partially closed position with the movable members closed, but not properly latched in position. The manual operators had not completed the movement to the mechanical stops but were locked into their positions.

The inspectors reviewed GOP-001, Plant Startup, and determined that it did not contain adequate information for operation of the disconnect switches in the switchyard. It was also determined that the operators did not have any training or qualifications on the operation of the disconnect switches. The lack of information in the procedure and operator training both contributed to the disconnect switches in the switchyard failing and automatic scram that occurred on December 13, 2023.

Corrective Actions: The licensee entered this issue into their corrective action program. The licensee took corrective action so that operators will no longer operate the disconnect switches in the switchyard and the transmission operators, who are trained on the operation, will now perform the task.

Corrective Action References: CR-RBS-2023-09058, CR-RBS-2023-09059, and CR-RBS-2023-09060

Performance Assessment:

Performance Deficiency: The failure to maintain an adequate procedure for operation of the disconnect switches in the switchyard in accordance with the requirements of Technical Specification section 5.4.1.a, Procedures, for the licensees failure to maintain a procedure required by Regulatory Guide 1.33, Quality Assurance Program Requirements, revision 2, appendix A was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the performance deficiency resulted in the disconnect switches failing causing a turbine runback and automatic reactor scram.

Significance: The inspectors assessed the significance of the finding using IMC 0609, appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined that the finding was of very low safety significance (Green) because although the disconnect switches failure caused a reactor trip it did not result in a loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Technical Specification section 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, revision 2, appendix A, dated February 1978.

Regulatory Guide 1.33, revision 2, appendix A, section 4 address, Procedures for Startup Operation and Shutdown of Safety-Related BWR Systems and Section 4.w(1) addresses, Electrical - Offsite.

Contrary to the above, from October 22, 1984, to January 10, 2024, the licensee failed to establish a procedure to addresses the requirements of Regulatory Guide 1.33, appendix A, section 4.w(1). Specifically, station procedure GOP-0001 did not include instructions for station operators on how to properly operate the disconnect switches in the switchyard. The lack of instructions and operator training caused the failure of the disconnect switches resulting in a reactor scram.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On March 28, 2024, the inspectors presented the radiation safety inspection results to Brad Wertz, General Manager of Plant Operations, and other members of the licensee staff.

• On April 11, 2024, the inspectors presented the integrated inspection results to Phil Hansett, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures OSP-0043 Freeze Protection and Temperature Maintenance Revision 48

71111.04 Calculations G13.18.2.1*039 D/G BLDG DIV I & II T's Based on As Recorded CFM 0

G13.18.2.1*083 Diesel Generator Building Design Basis Calculation-Summer 0

Condition

Procedures SOP-0003 Reactor Recirculation Systems SYS #053 322

SOP-0061 Diesel Generator Building Ventilation 016

71111.05 Fire Plans AB-114-522 Unit Cooler HVR-UC6 Room Fire Area AB-1/Z-3 Revision 3

AB-114-524 Unit Cooler HVR-UC9 Room Fire Area AB-15/Z-3 Revision 3

CB-116-131 Standby Switchgear 1C Room Fire Area C-22 Revision 4

CB-116-133 Battery 1A Room Fire Area C-18 Revision 5

CB-116-136 HPCS Battery Room Fire Area C-21 Revision 4

71111.12 Corrective Action CR-RBS-2024-00841

Documents

Procedures EN-DC-205 Maintenance Rule Monitoring Revision 9

71111.13 Procedures ADM-0096 Risk Management Program Implementation and On-Line 338

Maintenance Risk Assessment

EN-OP-119 Protected Equipment Postings 18

STP-051-4525 ECCS/RCIC-Reactor Vessel Water Level Low Low, Level 2; 011

Low Low Low, Level 1; Channel Functional Test (B21-

N692F, B21-N691F

STP-204-1300 LPCI Pump "A" Start Time Delay Channel Calibration and 024

Channel Functional Test

71111.15 Engineering EQAR-057 Rosemount 1153 Series B Alphaline Pressure Transmitters 004

Evaluations EQAR-058 Rosemount 1154 Series B Alphaline Pressure Transmitters 004

EQAR-059 Rosemount 1152 T0280 Alphaline Pressure Transmitters 003

Specification Air Conditioning and Ventilation Systems - Air and Hydronic 001

216.300 Balancing

Operability CR-RBS-2024-

Evaluations 00065 Operability

Evaluation

Procedures EN-LI-10 Event Notification and Reporting 022

EN-OP-104 Operability Determination Process 019

Inspection Type Designation Description or Title Revision or

Procedure Date

EN-OP-115-09 Maintaining the Station Narrative Log 004

GMP-0015 Lubrication Procedure 018

71111.24 Procedures STP-051-4254 HPCS Drywell Pressure - High Channel Calibration and 016

Logic System Functional Test

STP-051-4280 Containment Unit Cooler System Instrumentation, Unit Revision 11

Cooler B - Containment to Annulus Differential Pressure

High Channel Calibration and Logic System Functional Test

(HVRESZ60B, HVR-ESY60B, HVR-ESX60B, HVR-PDT60B)

STP-204-1300 LPCI Pump 'A' Start Time Delay Channel Calibration and Revision 24

Channel Functional Test

STP-204-6301 Div I LPCI (RHR) Pump and Valve Operability Test Revision 31

Work Orders 52950660-31 E22-S004 Global PM EM - Relay Testing E22B-K33A 02/21/2024

71124.01 ALARA Plans 1295-RWP Comment Sheet/Work in Progress Log NA

EN-RP-105, RWP Termination and Post-job ALARA Review 03/26/2024

EN-RP-110-03, Emergent Dose Approval Form 09/03/2023

9.6

IPR RWP-2024-RWP Revision/In-Progress Review RWP-2024-1040 SFC 1

1040 P14/P2A Maintenance Activities

RWP-2023-1715, ALARA Plan RF-22 - Risk Based: Emergent Work 02/08/2023

RWP-2023-1750 RWP Close Out 04/25/2023

Corrective Action CR-RBS-2022-06551, 2022-06689, 2022-07079, 2022-07383, 2023-

Documents 00568, 2023-01011, 2023-01148, 2023-01216, 2023-01252,

23-01415, 2023-01548, 2023-02115, 2023-02172, 2023-

2173, 2023-02472, 2023-02507, 2023-02536, 2023-02548,

23-02576, 2023-02593, 2023-03249, 2023-03271, 2023-

03373, 2023-03606, 2023-04275, 2023-05687, 2023-06063,

23-06394, 2023-06701, 2023-06709, 2023-06982, 2023-

07015, 2023-07044, 2023-07151, 2023-07534, 2023-07765,

23-08470, 2023-08471, 2023-08478, 2023-08560, 2023-

09012, 2024-00654, 2024-00672, 2024-00746

Procedures ADM-0071 Fuel Pools Material Control 8

EN-MA-125 Troubleshooting Control of Maintenance Activities 28

Inspection Type Designation Description or Title Revision or

Procedure Date

EN-RP-100 Radiation Worker Expectations 14

EN-RP-108 Radiation Protection Posting 23

EN-RP-110 ALARA Program 14

EN-RP-152 Conduct of Radiation Protection 8

RWS-0336 Set-up and Operation of the RDS-1000 Dewatering Unit 13

Radiation RBS-2208-00124 Turbine Building 95-foot Heater Bay 08/15/2022

Surveys RBS-2310-00049 Turbine Building 123-foot Elevation West MSR Bay 10/09/2023

RBS-2401-00055 RWCU Pump Rooms 01/10/2024

RBS-2401-00232 Radwaste Building 106-foot Elevation Liner Process Area 01/31/2024

RBS-2402-00086 Fuel Building 113-foot Elevation Spent Fuel Pool 02/13/2024

Radiation Work RWP-2023-1295 RWCU Seal Replacement Activities 0

Permits (RWPs) RWP-2023-1312 Recirculation A Motor Replacement Activities 1

RWP-2023-1715 Medium/High Risk Emergent Work Activities 0

RWP-2023-1750 Medium/High Risk Activities in the RWCU Pump Room and 0

Above

RWP-2024-1014 Emergent Work Activities 0

RWP-2024-1034 Radwaste Liner Processing Activities 0

Self-Assessments LO-RLO-2022-Self-Assessment of the ALARA Program 08/15/2023

00129

LO-RLO-2023-ALARA BWROG Inquiry via Telephone: Benchmark on 11/07/2023

00018-0002 equipment identification after shielding installation

Work Orders WO #00595003-C51-J600 5A Perform Troubleshooting 1

WO #54122007-Replace RMS-RE143 Detector 1

71124.04 Calculations Whole Body Count Evaluation Data Sheet, Attachment 9.4

for Personnel Contamination Event Numbers: 2023-006,23-007, 2023-010

Corrective Action CR-RBS-2022-06551, 2022-06579, 2022-07079, 2023-01148, 2023-

Documents 01493, 2023-02172, 2023-02960, 2023-02938, 2023-03056,

23-03250, 2023-03251, 2023-03274, 2023-04220, 2023-

06063, 2023-08470, 2024-00758, 2024-01622

Corrective Action CR-RBS-2024-01920

Documents

Inspection Type Designation Description or Title Revision or

Procedure Date

Resulting from

Inspection

Miscellaneous River Bend Station Full 5-Year Exposure Reduction Plan 02/12/2024

24-2028

List of Declared Pregnant Workers and NRC Form 5s for 02/06/2024

three workers

List of Multipack TLD Assignment Report and NRC Form 5s 02/06/2024

for seven workers

List of Multipack TLD Assignment Report 2023

23-1312-10 Recirc A Motor Replacement Activities 10/24/2023

24-1004-10-01 Resin Recovery and Cleanup 01/24/2024

24-1040-10 Maintenance Activities and Internal Inspections 02/01/2024

RBS-RPT-14-001 Neutron Study 07/11/2019

RBS-RPT-20-003 RBS 2020 Background Subtraction Study 09/14/2020

RBS-RPT-21-003 Alpha/Plant Characterization Data 09/14/2021

RBS-RPT-24-002 Alpha/Plant Characterization Data 01/31/2024

RPG-14-24-003 Landauer 2024 NVLAP Certificate and Scope 01/08/2024

RPG-M-23-006 10 CFR 20.2206(b) 2022 Annual Dose Report 04/05/2023

Procedures EN-RP-100 Radiation Worker Expectations 14

EN-RP-104 Personnel Contamination Events 11

EN-RP-122 Alpha Monitoring 10

EN-RP-131 Air Sampling 18

EN-RP-201 Dosimetry Administration 5

EN-RP-202 Personnel Monitoring 16

EN-RP-203 Dose Assessment 10

EN-RP-204 Special Monitoring Requirements 11

EN-RP-204-01 Effective Dose Equivalent (EDEX) Monitoring 3

EN-RP-205 Prenatal Monitoring 5

EN-RP-206 Dosimeter of Legal Record Quality Assurance 7

EN-RP-208 Whole Body Counting/In-Vitro Bioassay 7

EN-RP-503 Selection, Issue and Use of Respiratory Protection 10

Equipment

Radiation Work 20221148 Dry Fuel Storage Campaign 0

Inspection Type Designation Description or Title Revision or

Procedure Date

Permits (RWPs)

Self-Assessments LO-RLO-2022-RP Pre-NRC Focused Self-Assessment Radiation Safety 10/24/2023

00135 Inspection

QA-14/15-2023-Combined Radiation Protection and Radwaste 10/31/2023

RBS-01

71152A Procedures AOP-0052 Fire Outside the Main Control Room in Areas Containing Revision 33

Safety Related Equipment

OSP-0022 Operations General Administrative Guidelines Revision 128

SEP-FPP-RBS-River Bend Station Fire Fighting Procedure Revision 4

2

71153 Procedures AOP-0024 Thermal Hydraulic Stability Controls 37

AOP-0007 Loss of Feedwater Heating Revision 37

GOP-0001 Plant Startup 114

34