IR 05000458/2024002
| ML24205A039 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 07/30/2024 |
| From: | Jeffrey Josey NRC/RGN-IV/DORS/PBC |
| To: | Hansett P Entergy Operations |
| References | |
| EA-21-017, EA-21-030, EA-21-050 IR 2024002 | |
| Preceding documents: |
|
| Download: ML24205A039 (1) | |
Text
July 30, 2024
SUBJECT:
RIVER BEND STATION - INTEGRATED INSPECTION REPORT 05000458/2024002 AND NOTICE OF VIOLATION
Dear Phil Hansett:
On June 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at River Bend Station. On July 15, 2024, the NRC inspectors discussed the results of this inspection with Brad Wertz, General Manager, Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report in Enclosure 2.
The enclosed report documents a Green Notice of Violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, appendix B, criterion III for the failure ensure that the design basis for both the standby and high pressure core spray diesel generator air receivers was demonstrated, through appropriate testing or calculational methods to ensure the ability to perform five 10-second starts from either subsystem from the lowest possible air pressure under the most adverse design conditions.
The NRC evaluated this violation in accordance section 2.3.2 of the NRC Enforcement Policy, which can be found at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.
The violation is cited in Enclosure 1, Notice of Violation. We determined that this violation did not meet the criteria to be treated as a non-cited violation because you failed to restore compliance for non-cited violation 05000458/2023001-01 from NRC Inspection Report 05000458/2023001, Agencywide Documents Access and Management System (ADAMS)
Accession No. ML23296A251, within a reasonable period of time after the violation was identified.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice of Violation when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response. The NRCs review of your response will also determine whether further enforcement action is necessary to ensure your compliance with regulatory requirements. Additionally, three findings of very low safety significance (Green) are documented in this report.
All of these findings involved violations of NRC requirements, one of which was determined to be Severity Level IV. 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.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter, its enclosures, and your response will be made available electronically for public inspection in the NRC Public Document Room and from the NRCs ADAMS, accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction.
Sincerely, Jeffrey E. Josey, Chief Reactor Projects Branch C Division of Operating Reactor Safety Docket No. 05000458 License No. NPF-47
Enclosures:
1. Notice of Violation 2. Inspection Report 05000458/2024002
Inspection Report
Docket No.
05000458 License No.
NPF-47 Report No.
05000458/2024002 Enterprise Identifier:
I-2024-002-0004 Licensee:
Entergy Operations, Inc.
Facility:
River Bend Station Location:
St. Francisville, LA Inspection Dates:
March 1, 2024 to June 30, 2024 Inspectors:
R. Alexander, Regional State Liaison Officer S. Graves, Senior Reactor Inspector S. Hedger, Senior Emergency Preparedness Inspector E. Powell, Resident Inspector W. Schaup, Senior Project Engineer A. Smallwood, Senior Resident Inspector C. Wynar, Senior Resident Inspector Approved By:
Jeffrey E. Josey, Chief Reactor Projects Branch C Division of Operating Reactor Safety
2-2
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.
List of Findings and Violations
Failure to Correctly Classify In-service Testing Valves Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2024002-01 Open/Closed None (NPP)71111.15 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 (10 CFR) 50.55(a)(f)(4),
In-service Testing Requirements, for the licensees failure to categorize the low pressure core spray minimum flow check valve, CSL-V10, as a category 'A/C' valve. Specifically, the low pressure core spray minimum flow check valve was categorized as a 'C' valve and the licensees in-service testing program did not test the valve in accordance with ASME OM code subsection, ISTC-1300, Valve Categories, to ensure it could meet seat leakage requirements. As a result, undiscovered leakage past the valve caused flow to rotate the low pressure core spray pump in the opposite direction at approximately 60 rpm. This occurred while residual heat removal 'A' was in suppression pool cooling mode due to shared piping between residual heat removal 'A' and low pressure core spray.
Inadequate Operability for Control Building Air Conditioning Unit Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2024002-02 Open/Closed
[H.12] - Avoid Complacency 71152A The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of 10 CFR Part 50, appendix B, criterion V, Instructions, Procedures, and Drawings, 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 control building chillers when conditions were identified that questioned whether there was reasonable assurance that the equipment could perform its specified safety function.
Failure to Restore Compliance of Emergency Diesel Generator Air Starts Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NOV 05000458/2024002-03 Open
[H.14] -
Conservative Bias 71152A The inspectors identified a Green finding and associated Notice of Violation of 10 CFR Part 50, appendix B, criterion III, Design Control, when the licensee failed to ensure 2-3 that the design basis was correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to ensure that the minimum required pressure in both the standby and the high pressure core spray diesel generator starting air receivers, were suitably designed to meet the required number and timing of consecutive starts as described in the updated safety analysis report under the most adverse design conditions.
Installed Power Supply in Division 1 Emergency Diesel Generator Does Not Meet Updated Safety Analysis Report Requirements Cornerstone Significance/Severity Cross-Cutting Aspect Report Section Mitigating Systems Green Severity Level IV NCV 05000458/2024002-04 Open/Closed
[H.14] -
Conservative Bias 71152A The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, appendix B, criterion III, when the licensee created and approved a design calculation that documents design parameters contrary to updated safety analysis report. The licensee then used that calculation as a basis to install safety-related equipment into the plant that did not meet the updated safety analysis report criteria. Specifically, in July of 2022, the licensee installed a power supply in the division 1 emergency diesel generator with a humidity rating of 95 percent contrary to updated safety analysis report Table 9.4-1 which states the maximum humidity in the emergency diesel generator control room is 100 percent. The inspectors additionally identified a traditional enforcement aspect to this finding as a Severity Level IV non-cited violation of 10 CFR 50.59(c)(1), Changes, Tests and Experiments, when the licensee failed to conduct an evaluation to determine if the change could be made without a license amendment.
Additional Tracking Items
Type Issue Number Title Report Section Status NOV 05000458/2021090-01 Falsification of Magnetic Particle Exam by Non-Destructive Examination Proctor EA-21-017 92722 Closed NOV 05000458/2021090-02 Failure to Perform Operator Rounds EA-21-050 92722 Closed NOV 05000458/2021090-03 Failure to Control Critical Digital Asset Key EA-21-030 92722 Closed 2-4
PLANT STATUS
River Bend Station began the inspection period at 100 percent rated thermal power. On May 31, 2024, the unit down powered to approximately 63 percent power for a planned rod pattern adjustment and returned to 100 percent power on June 1, 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.
REACTOR SAFETY
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)condensate storage and transfer system on April 22, 2024 (2)standby gas treatment system on May 16, 2024 (3)penetration valve leakage control system on May 17, 2024 (4)residual heat removal C system on June 11, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (2 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)division 2 emergency diesel generator, fire area DG-4/Z-1 on June 18, 2024 (2)fuel pool cooling pump 1A pump room, fire area FB-1/Z-1 on June 21, 2024
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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 May 31, 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)condensate storage tank system 106 on May 16, 2024 (2)standby service water pump C breaker E22-S004 ACB5 on May 16, 2024 (3)spent fuel pool cooling pump 1A caliper on June 24, 2024
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
(1)environmental qualification of lubricants for 4160 voltage circuit breakers and emergency core cooling system pumps on May 17, 2024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 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 replacement of relay EJS-SWG2B ACB76-62A on April 18, 2024 (2)revised station risk map from updated probabilistic risk assessment on May 10, 2024 (3)elevated risk during unplanned reactor core isolation cooling system outage on May 10, 2024 (4)elevated risk mitigated by dedicated operator during division 2 control building chilled water system pump and valve operability test on June 12, 2024 (5)elevated risk during division 2 chilled water quarterly operability test on June 12, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
2-6 (1)operability of division 2 MOV-98B penetration valve leakage control system packing leak on May 1, 2024 (CR-RBS-2024-00065)
(2)operability of 4160V magneblast circuit breakers on May 7, 2024 (CR-RBS-2024-02591)
(3)operability of shutdown cooling system pipe support on May 31, 2024 (CR-RBS-2024-02698)
(4)low pressure core spray minimum flow check valve CSL V-10 past operability for low pressure core spray pump spinning backwards at 60 rpm on June 17, 2024 (CR-RBS-2023-08796 and CR-RBS-2024-01640)
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) (5 Samples)
(1)work order (WO) 52995932-01, EHS-MCC2E-1E current injection test/trip coil replacement on May 6, 2024
- (2) WO 53005015, division 1 emergency diesel generator jacket water relief valve on May 13, 2024
- (3) WO 52965277/WO 52984836, low pressure core spray outage window on May 17, 2024
- (4) WO 52986027, high pressure core spray cone repair on June 30, 2024
- (5) WO 53037967, residual heat removal C motor lead replacement on June 30, 2024
Surveillance Testing (IP Section 03.01) (3 Samples)
- (1) STP-410-3603, Performance Monitoring Program for Control Building Chiller HVK-CHL1C (Division 1), revision 307 on June 11, 2024
- (2) STP-209-6310, RCIC Quarterly Pump & Valve Operability Test, revision 042 on May 7, 2024
- (3) STP-410-6312, Div II Control Building Chilled Water System Pump and Valve Operability Test, revision 026 on June 30, 2024
71114.01 - Exercise Evaluation
Inspection Review (IP Section 02.01-02.11) (1 Partial)
(1)
(Partial)
The inspectors evaluated the biennial emergency plan exercise conducted on June 25, 2024. However, at the end of 2nd Quarter 2024, the licensee had not completed its critique process for the exercise. As such, the inspectors had not completed the full evaluation of the exercise and the critique process. The inspectors will complete the inspection in the 3rd Quarter, and the results of the inspection will be documented in NRC Inspection Report 05000458/2024003.
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71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated the following emergency plan changes:
- Evacuation Time Estimate Report, revision 73 [NRC notified on October 4, 2023 (ML23277A077)]
- River Bend Station Emergency Plan, revision 49 [NRC notified on June 24, 2024 (ML24177A185)]
This evaluation does not constitute NRC approval.
71114.06 - Drill Evaluation
Required Emergency Preparedness Drill (1 Sample)
(1)emergency preparedness drill on June 25, 2024
Additional Drill and/or Training Evolution
The inspectors evaluated:
(1)drill/exercise performance operations on May 14, 2024
71114.08 - Exercise Evaluation - Scenario Review
Inspection Review (IP Section 02.01 - 02.04) (1 Sample)
- (1) The inspectors reviewed the licensee's preliminary exercise scenario that was submitted to the NRC on April 29, 2024 (ML24123A048, ML24123A049, ML24123A070), for the exercise scheduled June 25-26, 2024. The inspectors discussed the preliminary scenario comments with J. McCoy, Manager, Emergency Preparedness, and other members of the emergency preparedness staff on May 15, 2024. The inspectors review does not constitute NRC approval of the scenario.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) April 1, 2023, through March 31, 2024
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
- (1) April 1, 2023, through March 31, 2024 2-8
MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)
- (1) April 1, 2023, through March 31, 2024
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) July 1, 2023, through March 31, 2024 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) July 1, 2023, through March 31, 2024 EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) July 1, 2023, through March 31, 2024
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)offsite fire brigade member on April 23, 2024 (2)control building chilled water system A past operability on May 16, 2024 (3)diesel generator humidity limits on May 31, 2024 (4)criterion 3 emergency diesel generator starts from minimum pressure on May 31, 2024 (5)motor operated valve beta dose on June 12,
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
===92722 - Follow-Up Inspection for Any Severity Level I or II Traditional Enforcement Violation or for Two or More Severity Level III Traditional Enforcement Violations in a 12-Month Period The inspectors reviewed the licensees response to the Notice of Violations (NOVs) listed below and determined that the cause was understood, the extent of condition, the extent of cause, corrective actions, and the contribution of safety culture was adequately addressed and captured on the docket.
Follow-Up Inspection for Any Severity Level I or II Traditional Enforcement Violation or for Two or More Severity Level III Traditional Enforcement Violations in a 12-Month Period===
- (1) NOV 05000458/2021090-01, Falsification of Magnetic Particle Exam by Non-Destructive Examination Proctor
- (2) NOV 05000458/2021090-02, Failure to Perform Operator Rounds
- (3) NOV 05000458/2021090-03, Failure to Control Critical Digital Asset Key
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INSPECTION RESULTS
Failure to Correctly Classify In-service Testing Valves Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2024002-01 Open/Closed None (NPP)71111.15 The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of 10 CFR 50.55(a)(f)(4), In-service Testing Requirements, for the licensees failure to categorize the low pressure core spray minimum flow check valve, CSL-V10, as a category 'A/C' valve. Specifically, the low pressure core spray minimum flow check valve was categorized as a 'C' valve and the licensees in-service testing program did not test the valve in accordance with ASME OM code subsection, ISTC-1300, Valve Categories, to ensure it could meet seat leakage requirements. As a result, undiscovered leakage past the valve caused flow to rotate the low pressure core spray pump in the opposite direction at approximately 60 rpm. This occurred while residual heat removal 'A' was in suppression pool cooling mode due to shared piping between residual heat removal 'A' and low pressure core spray.
Description:
On November 30, 2023, while running the residual heat removal (RHR) 'A' system in suppression pool cooling mode for testing, an operator in the low pressure core spray (LPCS) cubicle observed the pump rotating in the opposite direction at approximately 60 rpm. The flow path was from the RHR 'A' return line to the suppression pool, which is the shared path for LPCS minimum flow line to the suppression pool, through check valve CSL-V10 and the normally open LPCS minimum flow valve to the pump. Operators shut the minimum flow valve to cease flow and stopped LPCS from rotating backwards. At the time LPCS was rotating backwards, it was declared inoperable. The licensee has implemented a compensatory measure to maintain the minimum flow valve shut to prevent backflow to LPCS when RHR 'A' is running in suppression pool cooling mode. The minimum flow valve is normally open by procedure, but it has automatic features to open and close as required to protect the pump.
Corrective Actions: The licensee entered this issue into their corrective action program.
Corrective Action References: CR-RBS-2023-08796 and CR-RBS-2024-01640
Performance Assessment:
Performance Deficiency: The failure to correctly test and categorize the LPCS minimum flow check valve as category 'A/C' in accordance with 10 CFR 50.55(a)(f)(4) 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, the failure to test for valve leakage on the LPCS minimum flow check valve adversely affected the availability and capability of the LPCS system. This resulted in the LPCS pump rotating backwards at approximately 60 rpm and rendered the pump inoperable while RHR 'A' was running in suppression pool cooling mode.
2-10 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 is not a deficiency affecting the design or qualification of a mitigating SSC; the finding does not represent a loss of function of a technical specification (TS) train, system, or two separate TS systems for greater than their TS allowed outage time; the finding does not represent a loss of system and/or function for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and the finding does not represent an actual loss of function of one or more non-TS trains of equipment designated as risk significant in accordance with the licensees maintenance rule program. Therefore, the inspectors determined the finding was of very low safety significance (Green).
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: Title 10 CFR 50.55a(f)(4) requires, in part, that pumps and valves which are classified as ASME Class 1, Class 2, and Class 3 must meet the in-service test requirements set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in paragraphs (f)(2) of this section and that are incorporated by reference in paragraph (a)(1)(iv) of this section. Title 10 CFR 50.55a(f)(4)(ii) requires, in part, that in-service tests to verify operational readiness of pumps and valves, whose function is required for safety, conducted during successive 120-month intervals must comply with the requirements of the latest edition and addenda of the ASME OM Code incorporated by reference in paragraph (a)(1)(iv) of this section 18 months before the start of the 120-month interval. ASME Code subsection ISTC-1300, Valve Categories, requires, in part, that valves within this subsection shall be placed in one or more of the following categories. Category 'A' is for valves for which the seat leakage is limited to a specific maximum amount in the closed position for fulfillment of their required function as specified in ISTA-1100.
Contrary to the above, from November 20, 1985, to June 30, 2024, the licensee failed to categorize the LPCS minimum flow check valve, CSL-V10, as category 'A/C' in accordance with the ASME code requirements. Specifically, by categorizing the LPCS minimum flow check valve as a 'C' valve the leakage was not tested and accounted for to ensure no adverse effects on the LPCS system, which has shared piping with the RHR 'A' system in the suppression pool cooling mode.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Inadequate Operability for Control Building Air Conditioning Unit Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2024002-02 Open/Closed
[H.12] - Avoid Complacency 71152A The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of 10 CFR Part 50, appendix B, criterion V, Instructions, Procedures, and Drawings, for the licensees failure to follow Procedure EN-OP-104, Operability Determination Process, a quality-related procedure. Specifically, the licensee failed to
2-11 evaluate operability of control building chillers when conditions were identified that questioned whether there was reasonable assurance that the equipment could perform its specified safety function.
Description:
The inspectors were reviewing trends in the control building chillers oil level and questioned why the licensee was routinely adding oil to the control building chiller 'A',
HVK-CHL1A. The licensee provided the inspectors information that HVK-CHL1A had an ongoing oil leak from March 26, 2020, until October 19, 2023, ranging from two to five drops per minute. This leak rate caused oil to lower in the sight glass prompting operations to add oil to restore it to the proper operating band. The residents then questioned if operations had performed a past operability evaluation to determine if there were any instances where the known oil leak rate and the level at which the low oil was discovered would have resulted in the chiller being unable to meet its 30-day mission time. This was captured in condition report (CR) CR-RBS-2024-2034. In the CR, the licensee identified five instances where the oil level was found to be below the top of the bottom quarter of the lower sight glass, and leak rates of 2.8 drops per minute, or greater, were noted. The licensee determined that under these conditions, the leakage rate would have caused the oil level to drop out of the visible range in the sight glass and therefore resulting in insufficient oil for the equipment to meet its 30-day mission time. The licensee identified five instances of inoperability; however, none of which exceeded the TS allowed outage time because oil level was restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and control building chiller 'C' was operable at the time. Prior to October 19, 2023, when an oil leak was identified and corrected, the licensee failed to perform an adequate operability evaluation based on oil level, leak rate, and mission time. In some cases, the licensee incorrectly credited operator actions to restore oil level to maintain mission time while no procedure documented this.
Corrective Actions: The licensee entered this issue into their corrective action program.
Corrective Action References: CR-RBS-2024-03859
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 failure 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 that 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 probabilistic risk assessment (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
2-12 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 Plant Risk Information eBook 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.
Enforcement:
Violation: Title 10 CFR Part 50, appendix B, criterion V, Instructions, Procedures, and Drawings, requires, in part, 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, revision 19, 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 March 26, 2020, to October 19, 2023, when a degraded or nonconforming condition existed, the licensee failed to perform an evaluation that assesses all aspects of operation. Specifically, the licensee failed to perform adequate operability evaluations for oil leaks on control building chiller 'A'.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Failure to Restore Compliance of Emergency Diesel Generator Air Starts Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NOV 05000458/2024002-03 Open
[H.14] -
Conservative Bias 71152A The inspectors identified a Green finding and associated Notice of Violation of 10 CFR Part 50, appendix B, criterion III, Design Control, when the licensee failed to ensure that the design basis was correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to ensure that the minimum required pressure in both the standby and the high pressure core spray diesel generator starting air receivers, were suitably designed to meet the required number and timing of consecutive starts as described in the updated safety analysis report under the most adverse design conditions.
Description:
The inspectors reviewed corrective actions associated with non-cited violation (NCV)05000458/2023001-01 from Inspection Report 05000458/2023001 ((Agencywide Document and Access Management System (ADAMS) Accession No. ML23296A251), of 10 CFR Part 50, appendix B, criterion III, Design Control, and identified that the licensee did not restore compliance with the requirements of 10 CFR Part 50, appendix B, criterion III.
Specifically, the licensee failed to correct the NCV and restore compliance when they closed the corrective actions for the violation.
2-13 In March of 2023, while performing an inspection on the alignment and configuration of diesel generator starting air systems, the inspectors questioned the licensee on how they verified that the starting air receivers had sufficient air pressure to meet the design requirements as specified in the licensing basis. The standby diesel generators, consist of two diesel generators, division 1 and division 2. These two diesel generators, have a total of four air receivers grouped into two banks, with a minimum air pressure of 160 psig. The high pressure core spray (HPCS) diesel generator has two air receivers grouped into two banks, with a minimum air pressure of 200 psig. Each bank was part of a redundant diesel generator starting air system train such that each of the three diesel generators could start with either of the two starting air system trains. The inspectors requested the design basis for the minimum required pressure.
The licensees updated safety analysis report (USAR), section 9.5.6.1, Design Bases, specified the following design requirements for the standby and HPCS diesel generator starting systems: Each redundant DGSS train is capable of providing the standby diesel generator with eight starts (five of them are 10-second starts) from two air receivers without recharging the associated air receivers. The HPCS diesel generator air start subsystem has sufficient capacity to accelerate the diesel generator from standby conditions to operating speed within 10 seconds five times without recharging. Either the forward or rear air start subsystem has the capacity to satisfy these multiple start requirements when initially charged to 200 psig. The inspectors determined that the licensee had not used any calculational methods to demonstrate that the receiver air pressures met the design basis requirements.
Instead, the licensee relied on preoperational testing to demonstrate the adequacy of the receivers. The inspectors reviewed the preoperational testing data for the standby and HPCS diesel generators.
Example 1: Standby Diesel Generators The inspectors found that the preoperational test data for the standby diesel generators did not demonstrate the ability to perform eight starts, five of them 10-second starts, from each air bank if the air receivers were at the minimum air pressure of 160 psig. The inspectors determined that the preoperational testing consisted of eight starts, none of which were timed, from a pressure of approximately 250 psig. The inspectors noted that the licensee recorded that the fourth start was from a pressure of 160 psig for division 1 and from a pressure of 165 psig for division 2. The inspectors identified multiple issues with using that data. First, the fourth start on division 2 was from a pressure above 160 psig. Next, the inspectors noted that the licensee only recorded pressure on one of two receivers of only one of two banks. The inspectors concluded that the licensee had not demonstrated that the other receiver was not at a higher pressure which could invalidate the test data. Additionally, the licensee had not demonstrated the second starting system train on either division could also perform the required starts. Furthermore, the inspectors noted that the test data used the pressure as read on the mechanical gauges. The licensees surveillance procedure to verify the pressure was maintained above TS limits also used the pressure as read on the gauges.
The inspectors reviewed the specifications for the gauges and determined that the instruments had a calibration tolerance of plus or minus 4 psig. The inspectors concluded that if both receivers in a bank read 160 psig, the actual pressure could be as low as 156 psig.
The inspectors also reviewed additional test data that the licensee considered relevant. The inspectors determined that in 1992 the licensee had performed additional starts from approximately 160 psig that were timed. The inspectors noted that in these tests, the licensee performed a single timed start from one of the two air banks with the pressures on all receivers recorded. The inspectors determined that the licensee started the division 1 diesel
2-14 in 8.49 seconds from a starting pressure of 165 psig in receiver 1A and 160 psig in receiver 1C. The licensee did not account for instrument tolerance which meant the 1C receiver could have had an actual pressure as high as 169 psig if the instrument was calibrated. The inspectors also determined that the licensee started the division 2 diesel in 9.75 seconds from a starting pressure of 161 psig in receiver 1B and 160 psig in receiver 1D. The inspectors noted that the 1B receiver could have been as high as 165 psig if the instrument was calibrated. Overall, the inspectors concluded that the licensee failed to demonstrate the ability to perform eight starts, including five 10-second starts, from the lowest pressure that could exist under design conditions, specifically a pressure of 156 psig in both receivers of either air bank. The inspectors determined that the licensee failed to:
- (a) ensure the test data accounted for the lowest possible air pressure,
- (b) ensure that both air banks were verified to meet design requirements,
- (c) account for instrument error or calibration tolerances, and
- (d) ensure the required starts could be performed within the design start times. The inspectors noted that, after the inspectors raised the above concerns, the licensee made a change to their licensing basis. The licensee removed the requirement to perform eight starts and removed the requirement for the five starts to be 10-second starts.
Example 2: HPCS Diesel Generator The inspectors found that the preoperational test data for the HPCS diesel generators did not demonstrate the ability to perform five 13-second starts from each air receiver if the air receivers were at the minimum air pressure of 200 psig. The inspectors noted that the licensee had submitted license amendment 63 in 1991, which was subsequently approved, to increase the required start time for the HPCS diesel generator from 10 seconds to 13 seconds. Section 9.5.6 of the USAR still states a design requirement for five 10-second starts, but the inspectors reviewed the test data in consideration of the 13 second requirement. The inspectors documented a separate violation of 10 CFR 50.71.e for the failure to update the USAR. The inspectors determined that the preoperational testing consisted of five timed starts from a pressure of approximately 200 psig on receiver 1B and from approximately 225 psig on receiver 1A. The inspectors identified multiple issues with using that data. First, the first start on receiver 1A was from a pressure above 200 psig. Next, the inspectors noted that the test data used the pressure as read on the mechanical gauges.
The licensees surveillance procedure to verify the pressure was maintained above TS limits also used the pressure as read on the gauges. The inspectors reviewed the specifications for the gauges and determined that the instruments had a calibration tolerance of plus or minus 6 psig. The inspectors concluded that if each receiver read 200 psig, the actual pressure could be as low as 194 psig. Overall, the inspectors concluded that the licensee failed to demonstrate the ability to perform five 13-second starts, from the lowest pressure that could exist under design conditions, specifically a pressure of 194 psig in either air bank. The inspectors determined that the licensee failed to:
- (a) ensure the test data accounted for the lowest possible air pressure in either air receiver, and
- (b) account for instrument error or calibration tolerances.
As a result of NRC Inspection Report 05000458/2023003, this NCV was tracked in the licensee's corrective action program under CR-RBS-2023-03301. This CR-RBS-2023-03301 was then closed to CR-RBS-2023-00875, which is documented in the report as the CR the licensee used to track a separate 10 CFR 50.71(e) NCV for the HPCS diesel generator regarding the time requirements for air starts on the HPCS emergency diesel generator (EDG). Additionally, in the same report, the licensee received a third EDG related violation which was a 10 CFR 50.59(c)(2)(viii) violation regarding a change made to reduce the number of required starts for each EDG from eight to five starts without a license amendment.
2-15 This 50.59 violation was tracked in the corrective action program under CR-RBS-2023-03307 and then subsequently closed to CR-RBS-2023-00875. After NRC Inspection Report 05000458/2023001 was issued, the licensee closed two CRs for two separate violations to a single CR tracking a third violation. The license then disputed the 50.59 violation (ADAMS Accession No. ML23145A266), and after independent NRC review, the violation was retracted and reissued in a revised report as a 10 CFR 50.71.e violation. The licensee only contested the 10 CFR 50.59 violation and the NRC only reviewed and revised that violation. The 10 CFR Part 50, appendix B, criterion III and the other 10 CFR 50.71(e)remained upheld. Since the licensee had closed the other two violations to a CR for the violation that got revised, they inappropriately believed that no corrective actions for CR-RBS-2023-00875 were required to be completed, including the actions developed from the other violations that had been closed to this CR. By tracking three separate violations in a single CR, the licensee mistakenly mistook the retraction of the original violation tracked in CR-RBS-2023-00875 to be applied to the other two violations whose CRs were closed to CR-RBS-2023-00875. This ultimately resulted in the 10 CFR Part 50, appendix B, criterion III violation not being tracked in the licensees corrective action program to restore compliance and why compliance was not restored within a reasonable period of time.
Corrective Actions: The licensee entered this issue into their corrective action program.
Corrective Action References: CR-RBS-2024-03844
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to ensure the design basis was correctly translated into specifications, drawings, procedures, and instructions was a performance deficiency. Specifically, the licensee failed to ensure the design basis for the standby and HPCS diesel generator starting system air receivers was correctly translated into appropriate calculations or test procedures.
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 performance deficiency resulted in the standby and HPCS diesel generator starting systems failing to meet design requirements for multiple starts.
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 System Screening Questions, the inspectors determined that the finding is a deficiency affecting the design or qualification of a mitigating SSC, but the SSC maintained its operability and PRA functionality and was of very low safety significance (Green).
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 in order to proceed, rather than unsafe in order to stop.
Enforcement:
Violation: Title 10 CFR Part 50, appendix B, criterion III, Design Control, requires in part, that for those SSCs to which 10 CFR Part 50 appendix B applies, measures shall be established to ensure that the design basis is correctly translated into specifications,
2-16 drawings, procedures, and instructions.
Contrary to the above, from March 2023, to June 30, 2024, for quality-related components associated with both the standby and HPCS diesel generator starting systems to which 10 CFR Part 50, appendix B applies, the licensee failed to ensure that the design basis was correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to ensure that the design basis for both the standby and HPCS diesel generator air receivers was demonstrated, through appropriate testing or calculational methods, to ensure the ability to perform five 10-second starts from either subsystem from the lowest possible air pressure under the most adverse design conditions.
Enforcement Action: This violation is being cited because the licensee failed to restore compliance within a reasonable period of time after the violation was identified consistent with section 2.3.2 of the Enforcement Policy.
Installed Power Supply in Division 1 Emergency Diesel Generator Does Not Meet Updated Safety Analysis Report Requirements Cornerstone Significance/Severity Cross-Cutting Aspect Report Section Mitigating Systems Green Severity Level IV NCV 05000458/2024002-04 Open/Closed
[H.14] -
Conservative Bias 71152A The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, appendix B, criterion III, when the licensee created and approved a design calculation that documents design parameters contrary to updated safety analysis report. The licensee then used that calculation as a basis to install safety-related equipment into the plant that did not meet the updated safety analysis report criteria. Specifically, in July of 2022, the licensee installed a power supply in the division 1 emergency diesel generator with a humidity rating of 95 percent contrary to updated safety analysis report Table 9.4-1 which states the maximum humidity in the emergency diesel generator control room is 100 percent. The inspectors additionally identified a traditional enforcement aspect to this finding as a Severity Level IV non-cited violation of 10 CFR 50.59(c)(1), Changes, Tests and Experiments, when the licensee failed to conduct an evaluation to determine if the change could be made without a license amendment.
Description:
In July of 2022, the inspectors reviewed engineering change EC-87792, which documented the replacement of two power supplies, EGS-E/EX43A and EGS-E/EY43A, in the division 1 EDG control cabinets. This replacement effort was prompted after the failure of one of the power supplies had rendered the EDG inoperable. The EC noted that the design parameters of the new power supplies have a humidity rating of 95 percent. The inspectors then reviewed Engineering Calculation G13,18.2.1*083, which documents that with maximum humidity in the EDG control room never exceeds 81 percent during summer months. USAR Table 9.4-1 states that the division 1 EDG control room is rated for up to 100 percent humidity. Additionally, Environmental Design Criteria Specification 215.150, which is incorporated by reference to the USAR via note 27 of Table 9.4-1, states in note 4 that the EDG control room will see 100 percent humidity approximately 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> per year. These conclusions of this calculation are in direct conflict with the USAR. It is important to note that this calculation is based on inputs that have been shown to be incorrect. The inspectors identified a non-cited violation of 10 CFR Part 50, criterion III, in resident inspection report 05000458/2024001 (ADAMS Accession No. ML24128A043), where the licensee utilized
2-17 calculated heating, ventilation, and air conditioning air flow rates, contrary to the USAR and measured values for airflow, in calculation G13.18.2.1*083 in order to determine the maximum temperature and humidity the room would see, thus invalidating the calculation.
This calculation is the basis for EC-87792 which the licensee used to make the determination that the new power supply, with a 95 percent humidity rating was acceptable and that they did not need to perform a 10 CFR 50.59 evaluation.
As stated above, the licensee referenced this invalidated calculation in EC-87792, which was used to justify their determination that a power supply with a 95 percent humidity rating was adequate to be installed in the division 1 EDG control cabinets. Presently, there is not an updated version of the calculation. Additionally, the licensee failed to perform a 10 CFR 50.59 screening to evaluate if prior commission approval was required before installing the aforementioned power supply. Presently, the division 1 EDG has a power supply installed with a humidity rating lower than that specified in the USAR. Equipment installed with a lower humidity rating than what the room is rated for could increase the risk of that component failing, and therefore lead to the inoperability of the EDG.
Corrective Actions: The licensee entered this issue into their corrective action program.
Corrective Action References: CR-RBS-2024-02495, CR-RBS-2024-02957, and CR-RBS-2024-03842
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to ensure the design basis was correctly translated into specifications, drawings, procedures, and instructions was a performance deficiency. Specifically, the licensee failed to ensure the design calculation was in compliance with the USAR which led to a non-compliant power supply being installed into the division 1 EDG control cabinets.
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.
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 System Screening Questions, the inspectors determined that the finding is a deficiency affecting the design or qualification of a mitigating SSC, but the SSC maintained its operability and PRA functionality and was of very low safety significance (Green).
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 in order to proceed, rather than unsafe in order to stop. Specifically, the licensee failed to apply conservative bias when they screened EC-87792 out of a 50.59 evaluation and installed equipment into the plant not meeting the design requirements of the USAR.
Enforcement:
The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is
2-18 necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.
Severity: The inspectors assessed the severity level using the NRC Enforcement Policy, dated January 12, 2024, section 6.1.d.2 and determined that the violation was Severity Level IV because it was a violation of 10 CFR 50.59 that resulted in conditions evaluated as having very low safety significance (Green) by the significance determination process.
Violation: Title 10 CFR Part 50, appendix B, criterion III, Design Control, requires in part, that for those SSCs to which 10 CFR Part 50 appendix B applies, measures shall be established to ensure that the design basis is correctly translated into specifications, drawings, procedures, and instructions.
Title 10 CFR 50.59(c)(1), states in part, that the licensee may make changes in the facility as described in the USAR (as updated), make changes in the procedures as described in the USAR (as updated), and conduct tests or experiments not described in the USAR (as updated) without obtaining a license amendment pursuant to section 50.90 only if the change, test, or experiment does not meet any of the criteria in paragraph (c)(2).
Contrary to the above, from February 2000 to June 30, 2024, for those SSCs to which 10 CFR Part 50 appendix B applies, the licensee failed to ensure that the design basis was correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to maintain the design control requirements for the EDG control rooms when they approved engineering calculation G13.18.2.1*083 that documented results contrary to the USAR. The licensee used EC-87792 that incorporated the calculation to install a power supply with a lower humidity rating than specified in the USAR. Additionally, the licensee failed conduct an evaluation in accordance with the requirements of paragraph (c)(2)of 10 CFR 50.59 in order to ensure a license amendment was not required.
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 May 15, 2024, the inspectors presented the emergency preparedness exercise scenario inspection results to Jack McCoy, Manager, Emergency Preparedness, and other members of the licensee staff.
- On July 3, 2024, the inspectors presented the emergency preparedness performance indicator verification and emergency plan change review inspection results to Phil Hansett, Site Vice President, and other members of the licensee staff.
- On July 15, 2024, the inspectors presented the integrated inspection results to Brad Wertz, General Manager, Plant Operations, and other members of the licensee staff.
2-19
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
SOP-0007
Condensate System (SYS 104)
314
SOP-0008
Condensate Storage, Makeup and Transfer (system #106)
Procedures
SOP-0043
Standby Gas Treatment System (Sys #257)
21
DG-098-050
Diesel Generator B Room Fire Area DG-4/Z-1
005
Fire Plans
Fuel Pool Cooling Pump 1A Room Fire Area FB-1/Z-1
Corrective Action
Documents
CR-RBS-
23-08250, 2024-00759, 2024-00835, 2024-01048, 2024-
01668, 2024-02083, 2024-02087, 2024-02108, 2024-02423,
24-02530, 2024-02549, 2024-02550, 2024-02551, 2024-
2553, 2024-02554, 2024-02555, 2024-02556, 2024-02557,
24-02558, 2024-02709, 2024-02854
Corrective Action
Documents
Resulting from
Inspection
CR-RBS-
24-03120, 2024-03248, 2024-03252, 2024-03254
Address EQ Life of Durez Switches
Update Standard PE-S-002-R to Include Relay EHS-
MCC2C-2B-62/62X in Order to Accept As-Is the Installation
Under WO 512292 (Ref. CR-RBS-2019-06344 and CR-RBS-
2019-071590
000
HVR-UC11A, HVR-UC11B Motor Replacement - Design
Equivalent Change
000
Acceptance of Homewood Motors Environmental
Qualification Report NKO-2119-WW
000
Eval EC to Approve Connectors in IRM and SRM
Applications in EQ Zone DW-1 and DW-3
000
E51-MOVF063 Equivalent Replacement.
000
Engineering
Changes
Evaluate EQPM Extension for HTS-PNL2M & N
Miscellaneous
21.418-000-
003A
Instruction Manual for E22*S004
B
EDP-EQ-23
Equipment Qualification Assessment Reports (EQAR)
Procedures
EDP-EQ-24
Environmental Qualification Thermal Aging Program
(EQTAP)
301
2-20
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Commercial Grade Dedication Lab Conduct of Operation
000
Environmental Qualification (EQ) Program
Environmental Qualification Master List Control
006
Lubrication Program
Acceptance of Commercial-Grade Items/Services in Safety-
Related Applications
010
Procurement Engineering Process
2
EN-DC-313-02
Procurement Engineering - Technical Evaluation of
Replacement Parts
008
018
Material Issues and Returns
010
Control of Materials
20
In-Storage Maintenance Process
006
EQAR-054
FCI Model FR72 Flow Switch
EQAR-068
Square D Masterpact Breakers for 480 VAC Load Centers
MCP-4066
Calibration of Rosemount Transmitters
301
QR-052-7860-1
Square-D Masterpact Breaker Qualification Report
Work Orders
WO 00467067, 00499874, 00508761, 00516660, 00524884,
00530827, 00538082, 00544373, 00558267, 00570792,
00583157, 00591779, 00592492, 52813788, 52882893,
2888530, 52908356, 52931725, 52957104, 53007183,
53015498, 53038200, 54077042, 54115676
Corrective Action
Documents
CR-RBS-
24-02624
STP-410-6304
Div II Chilled Water System Quarterly Valve Operability Test
004
Procedures
STP-410-6312
Div II Control BLDG Chilled Water System Pump and Valve
Operability Test
26
Work Orders
21A9443AX
RCIC Purchase Data Sheet
Miscellaneous
21.452-000-
001F
RCIC Turbine Instruction Manual
Operability
Evaluations
CR-RBS-2024-
2421
B21-MOVF098B Operability Evaluation
000
2-21
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
SOP-0032
Low Pressure Core Spray (Sys #205)
030
211.161-997-
360B
Nuclear High Voltage Kits
Miscellaneous
Specification No.
248.000
Specification for Electrical Installation
CMP-1277
Lugging, Splicing and Termination of Power, Control and
Instrument Cable
CMP-EM-203-
1001
Inspection and Maintenance of 4.16kv Magne-Blast Circuit
Breakers
EQAR-068
Square D Masterpact Breakers for 480 VAC Load Centers
QR-052-7860-1
Square-D Masterpact Breaker Qualification Report
Procedures
STP-209-6310
RCIC Quarterly Pump and Valve Operability Test
2
Work Orders
Corrective Action
Documents
Condition Reports
(CR-RBS-)
22-02007, 2022-02599, 2022-06039, 2022-06064, 2022-
06138, 2023-03515, 2023-06386, 2023-06596, 2023-07612,
24-01883, 2024-01884, 2024-02343
ECP-2-001
Joint Information Center (JIC) Staff Position Instructions
EIP-2-006
Notifications
EIP-2-007
Protective Action Recommendation Guidelines
EIP-2-018
EIP-2-020
EIP-2-023
EIP-2-024
Offsite Dose Calculations
Procedures
Post-Accident Airborne Radiation Levels in Various Plant
Ventilation Systems
Calculations
EP-CALC-RBS-
1801
Radiological Effluent EAL Threshold Values
Corrective Action
Documents
Resulting from
Inspection
Condition Reports
(CR-RBS-)
24-03638
Miscellaneous
10CFR50.54(q)(3) Evaluation - 2022 Evacuation Time
Estimate Impact on Protective Action Recommendations
9/7/2023
2-22
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
10CFR50.54(q)(3) Evaluation - River Bend Station
Emergency Plan, Revision 49
6/3/2024
10CFR50.54(q)(3) Screening - PR-C-422, Revision 1, Title:
Post-Accident Airborne Radiation Levels in Various Plant
Ventilation Systems
9/13/2022
RBG-48257
River Bend Station Unit 1, Evaluation of Evacuation Time
Estimate Report; River Bend Station - Unit 1; NRC Docket
No. 50-458; Renewed Facility Operating License No. NPF-47
10/4/2023
RBG-48297
Submittal of Emergency Plan, Revision 49; River Bend
Station - Unit 1; NRC Docket No. 50-458; Renewed
Operating License No. NPF-47
6/24/2024
EIP-2-001
Classification of Emergencies
Procedures
Emergency Planning 10CFR50.54(q) Review Program
Corrective Action
Documents
Resulting from
Inspection
Condition Reports
(CR-RBS-)
24-02463
Miscellaneous
RBG-48290
Draft Emergency Preparedness 2024 Exercise Scenario -
River Bend Station; River Bend Station - Unit 1; NRC Docket
Nos. 50-458; Renewed Facility Operating License No. NPF-
4/29/2024
EIP-2-001
Classification of Emergencies
EIP-2-002
Classification Actions
Procedures
EIP-2-007
Protective Action Recommendation Guidelines
Corrective Action
Documents
Condition Reports
(CR-RBS-)
22-06063, 2022-06064
EN-LI-114 Performance Indicator Technical Data
Sheets/Package: Emergency Preparedness - Alert and
Notification System Reliability
3Q/2023,
4Q/2023, &
1Q/2024
EN-LI-114 Performance Indicator Technical Data
Sheets/Package: Emergency Preparedness - Drill/Exercise
Performance
3Q/2023,
4Q/2023, &
1Q/2024
71151
Miscellaneous
EN-LI-114 Performance Indicator Technical Data
Sheets/Package: Emergency Preparedness - ERO
3Q/2023,
4Q/2023, &
2-23
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Participation
1Q/2024
LOR Cycle 23-03 As Found Exam Package (DEP PI)
08/01/2023
River Bend Alert and Notification System Siren Warning
System Upgrade Project, FEMA REP-10 Design Report
Addendum
03/01/2013
RSES-LOR-24-06
LOR Cycle 24-06 As Found Exam Package (DEP PI)
03/07/2024
EN-FAP-EP-005
Emergency Preparedness Performance Indicators
Procedures
EPP-2-701
Prompt Notification System Maintenance and Testing
06/15/2021
Corrective Action
Documents
CR-RBS-
22-04772, 2023-01053, 2023-03301, 2024-02034
Common Cause Worksheet CR-RBS-2021-06336
ACA CR-HQN-
20-00269
Examination Administration Integrity Trend
Final
ACA CR-RBS-
20-03687
Operator Rounds
Final
ACA CR-RBS-
21-04488
Operator Rounds
Final
CR-HQN
2017-01968, 2018-02142,2020-00269,2021-02143
CR-RBS
2018-01917, 2019-05764, 2019-05833, 2020-03687, 2020-
03599, 2021-04382, 2021-04625, 2021-04488, 2021-06166,
21--6167, 2021-06336
CR-RBS-
2018-02712, 2018-06677, 2019-06462, 2020-01535, 2021-
06165, 2021-06868, 2022-04920
RCE CR-HQN-
2017-01968
Integrity Events
Final
RCE CR-RBS-
2018-01917
Operator Rounds
Final
Corrective Action
Documents
RCE CR-RBS-
22-00413
Security Patrols
Final
Corrective Action
Documents
Resulting from
Inspection
CR-RBS
24-02264
2722
Miscellaneous
CR-RBS-2020-
Schedule and Status of Corrective Actions
2-24
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
01535 Corrective
Actions List
CR-RBS-2021-
06165 Corrective
Actions List
Schedule and Status of Corrective Actions
EN-IT-103-07
WT-WTRBS-
2018-00541 CA-
Owner Key Inventory Check - March 2023
EN-IT-103-07-
WT-RBS-2024-
00060-CA-2
Owner Key Inventory Check - February 2024
EN-IT-103-07-
WTRBS-2018-
000541-CA-67
Owner Key Inventory Check - December 2023
LO-RLO-2021-
00129 CA - 01
Effectiveness Review - CR-RBS-2021-6165
10/04/2022
QA-16-2022-
RBS-1
Audit - Security (including Cyber Security)
10/04/2022
QA-16-2023-
RBS-1
Security, Including Cyber Security Audit Notification/Audit
Plan Memorandum
10/24/2023
CEP-NDE-0100
Administration and Control of NDE Entergy Nuclear
Engineering Programs
EN-FAP-LI-001
Performance Improvement Review Group (PRG) Process
EN-FAP-LI-017
Integrity Audits
EN-FAP-PM-006
Conduct of Integrity Audits for Projects and Maintenance
Services
EN-IT-103-07
Cyber Security Physical Access Requirements for Critical
Digital Assets
Corrective Action Program
Casual Analysis Process
Examination Security
JA-PI-01
Analysis Manual
Procedures
JA-PI-16
Sample Size
2-25
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-RBS-2018-
06677
Casual Evaluation - Operations Key Control QAF
01/29/2019
CR-RBS-2020-
01535
Casual Evaluation - Unauthorized Access to CDA
04/21/2020
CR-RBS-2021-
06165
Root Cause Evaluation Summary for NRC Notice of Violation
- Failure to Implement the Cyber Security Physical Access
Requirements for Critical Digital Assets
11/18/2021
Self-Assessment - NRC follow-up 92722 inspection
5/22/2022
LO-HQNLO-
21-00081
NDE Certification Program Self-Assessment
6/24/2022
LO-RLO-2018-
00179/00183
Operations Field Verification Assessment
LO-RLO-2018-
00180/00184
Operations Field Verification Assessment
LO-RLO-2018-
00181/00185
Operations Field Verification Assessment
LO-RLO-2019-
20
Operations Field Verification Assessment
LO-RLO-2019-
21
Operations Field Verification Assessment
LO-RLO-2019-
22
Operations Field Verification Assessment
RO-RLO-2012-
0119
Operations Field Verification Assessment
RO-RLO-2018-
00182/00186
Operations Field Verification Assessment
RO-RLO-2021-
0063
Operations Field Verification Assessment
RO-RLO-2021-
0064
Operations Field Verification Assessment
RO-RLO-2021-
0065
Operations Field Verification Assessment
Self-Assessments
RO-RLO-2021-
Operations Field Verification Assessment
2-26
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0066
RO-RLO-2022-
0052
Operations Field Verification Assessment
RO-RLO-2022-
0053
Operations Field Verification Assessment
RO-RLO-2022-
0054
Operations Field Verification Assessment
RO-RLO-2022-
0055
Operations Field Verification Assessment
RO-RLO-2022-
0194
Operations Field Verification Assessment
RO-RLO-2022-
0195
Operations Field Verification Assessment
RO-RLO-2022-
0196
Operations Field Verification Assessment
RO-RLO-2022-
0197
Operations Field Verification Assessment
0