IR 05000458/2024003
| ML24285A067 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 10/31/2024 |
| From: | Jeffrey Josey NRC/RGN-IV/DORS/PBC |
| To: | Hansett P Entergy Operations |
| References | |
| IR 2024003 | |
| Download: ML24285A067 (36) | |
Text
October 31, 2024
SUBJECT:
RIVER BEND STATION - INTEGRATED INSPECTION REPORT 05000458/2024003
Dear Phil Hansett:
On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at River Bend Station. On October 16, 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.
Five findings of very low safety significance (Green) are documented in this report. All of these findings involved violations of NRC requirements. One Severity Level IV violation without an associated finding is 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 Number:
05000458
License Number:
Report Number:
Enterprise Identifier:
I-2024-003-0012
Licensee:
Entergy Operations, Inc.
Facility:
River Bend Station
Location:
St. Francisville, LA
Inspection Dates:
July 1, 2024, to September 30, 2024
Inspectors:
L. Carson, Senior Health Physicist
N. Eckhoff, Health Physicist
S. Hedger, Senior Emergency Preparedness Inspector
E. Powell, Resident Inspector
R. Williams, Operations Engineer
C. Wynar, Senior Resident Inspector
D. You, Operations Engineer
Approved By:
Jeffrey E. Josey, Chief
Reactor Projects Branch C
Division of Operating Reactor Safety
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 Conduct an (a)(3) Evaluation Within 24 Months Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2024003-01 Open/Closed
[H.8] -
Procedure Adherence 71111.12
- 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 50.65(a)(3) for the licensees failure to evaluate performance and condition monitoring activities and associated goals and preventive maintenance activities at least every refueling cycle provided the interval between evaluations does not exceed 24 months. Specifically, the licensee has not completed the required evaluation since December of 2021.
Inadequate Performance Criteria for (a)(2) Structures, Systems, and Components Prevented Effective Monitoring of Maintenance Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2024003-02 Open/Closed
[H.14] -
Conservative Bias 71111.12 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 50.65(a)(2) when the licensee failed to demonstrate the systems were effectively controlled through appropriate maintenance. Specifically, when operability evaluations and compensatory measures were used as acceptable reasons for not performing maintenance preventable functional failure evaluations or maintenance preventable functional failures were just not identified. When the evaluations are not completed the licensee cannot monitor the system against the established criteria for functional failures and condition monitoring events.
Failure to Perform Testing for Safety-Related Unit Cooler Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2024003-03 Open/Closed None (NPP)71111.12 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 XI, Test Control, when the licensee failed to incorporate a test program to verify that the main steam tunnel unit cooler, HVR-UC8, was supplying adequate airflow to maintain the main steam tunnel under Updated Safety Analysis Report specified maximum temperatures.
Failure to Correct Conditions Adverse to Quality in a Timely Manner Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2024003-04 Open/Closed
[H.12] - Avoid Complacency 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 50, appendix B, criterion XVI, when the licensee failed to correct a condition adverse to quality in a timely manner. Specifically, the licensee identified a condition where the main steam tunnel temperature exceeded its Updated Safety Analysis Report allowed value of 135 degrees Fahrenheit as far back as 2010. The licensee has documented the issue in condition reports repeatedly over the last 14 years.
Failure to Meet Surveillance Requirement 3.0.1 for Control Room Envelope Habitability Failed Surveillance Test Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000458/2024003-05 Open/Closed Not Applicable 71111.15 The inspectors identified a Severity Level IV non-cited violation of Technical Specifications Surveillance Requirement Applicability 3.0.1 for the licensees failure to meet a surveillance requirement. Specifically, the licensee failed to meet Surveillance Requirement 3.7.2.4 requiring them to enter the action statements of Limiting Condition for Operation 3.7.2.
Specifically, after not meeting flow requirements during a control room envelope (CRE)habitability tracer gas surveillance test the licensee did not declare LCO 3.7.2 not met and enter the required action of the TS.
Failure to Critique a Weakness During a Biennial Exercise Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000458/2024003-06 Open/Closed
[H.1] -
Resources 71114.01 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 50.47(b)(14) for the licensees failure to identify and correct weaknesses in emergency response organization performance during a biennial emergency preparedness exercise conducted on June 25, 2024. Specifically, the licensee did not identify an example of performance that would have precluded effective implementation of the emergency plan if it occurred during an actual radiological emergency (inadequate emergency worker protection).
Additional Tracking Items
None.
PLANT STATUS
River Bend Station began the inspection period at 100 percent rated thermal power. On September 6, 2024, the unit down powered to approximately 80 percent power for a rod pattern adjustment and returned to 100 percent power on September 7, 2024, where it remained for the rest of the quarter.
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
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending hurricane Francine on September 13, 2024.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)division 1 emergency diesel generator system on August 16, 2024 (2)reactor auxiliary building heating, ventilation, and air conditioning containment unit coolers on September 12, 2024
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the high pressure core spray system on July 25, 2024.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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)cable area B, fire area C-6 on July 30, 2024
- (2) H-tunnel, fire area ET-3 on August 7, 2024 (3)reactor core isolation cooling, fire area AB-4/Z-1 and Z-2 on August 29, 2024 (4)containment unit cooler area, fire area RC-4/Z-5 on September 12, 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 September 17, 2024.
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in the emergency diesel generator control room based on control building standby service water pipe break on August 2, 2024.
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) division 1 emergency diesel generator jacket water heat exchanger EGT-E1A on September 18, 2024
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification operating and written exams administered between August 26, 2024, and September 27, 2024.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
- (1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on Aug 30, 2024.
Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.
Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by Title 10 of the Code of Federal Regulations (10 CFR) 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
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 performance of surveillance test procedure STP-309-0603, Division III ECCS Test, revision 052, on July 23, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)
- (1) The inspectors observed and evaluated emergency action plan opportunity and proficiency training on July 16, 2024.
- (2) The inspectors observed and evaluated crew proficiency in the simulator on September 10, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)system 409 auxiliary building ventilation on September 17, 2024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)
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 division 1 emergency diesel generator planned outage on August 26, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)containment unit cooler HVR-UC1A on July 9, 2024 (CR-RBS-2024-03598, CR--RBS-
-2024-03601, and CR-RBS-2024-03613)
(2)main steam stop packing leaks on August 22, 2024 (CR-RBS-2024-04120)
(3)control room envelope habitability on August 28, 2024 (CR-RBS-2024-03134)
(4)reactor core isolation cooling turbine trip on September 10, 2024 (CR--RBS--2024-
-02624)
(5)main steam tunnel high temperature on September 30, 2024 (CR-RBS-2024-02572)
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) (8 Samples)
(1)work order (WO) 54158955, service water air accumulator tank A outlet line solenoid isolation valve SWP-SOV522A on August 16, 2024
- (2) WO 52968263, control room envelope tracer gas test on August 28, 2024
- (3) WO 00284020, 54037720, 54142462, and 54142464, calibrate reactor core isolation cooling flow controller E51-FCR600 on September 10, 2024
- (4) WO 54172255, replaced rod control information system power supply on September 12, 2024
- (5) WO 54109072, penetration valve leakage control system compressor unloader valve LSV-SOV44B replacement on September 12, 2024
- (6) WO 53022011, division 1 emergency diesel generator jacket water cooler tube plugging on September 12, 2024
- (7) WO 53025162, division 1 emergency diesel generator lube oil heater replacement on September 24, 2024
- (8) WO 54177208, replace division 3 emergency diesel generator air dryer EGA-DRY3B on September 30, 2024
Surveillance Testing (IP Section 03.01) (2 Samples)
- (1) STP-309-0603, Division III ECCS Test, revision 052 on August 28, 2024
- (2) STP-309-6315, Div III HPCS Fuel Oil Transfer Pump and Valve Operability Test, revision 018 on September 17, 2024
71114.01 - Exercise Evaluation
Inspection Review (IP Section 02.01-02.11) (1 Sample)
- (1) The inspectors evaluated the biennial emergency plan exercise conducted on June 25, 2024. The exercise scenario simulated seismic event, recirculation system leak, and multiple injection source failures. This, and rising radiation levels in containment, resulted in a rapid escalation to a Site Area Emergency. This was followed by simulated ruptures of makeup water resources onsite. Further fuel and reactor degradation led to a simulated radiological release offsite.
The licensee completed its critique process for the exercise on July 24, 2024, and the inspectors subsequently evaluated the effectiveness of the critique process to identify performance weaknesses and deficiencies to ensure they were entered into the corrective action program for resolution.
This documents completion of this inspection sample which was documented as a partial sample in Inspection Report 05000458/2024002 (ADAMS Accession No. ML24205A039).
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (1 Sample)
The inspectors evaluated:
- (1) emergency preparedness drill on August 14,
RADIATION SAFETY
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (4 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
(1)unit 1, liquid waste system recovery sample tank 4A&B - 95-foot radwaste building (2)unit 1, offgas building ventilation radiation monitor #RE-124 (3)unit 1, turbine building ventilation radiation monitor #RE-118 (4)unit 1, liquid radwaste effluent radiation monitor #RE-107
Sampling and Analysis (IP Section 03.02) (4 Samples)
Inspectors evaluated the following effluent samples, sampling processes and compensatory samples:
(1)unit 1, particulate filter air sample from 1RMS-RE5A, fuel building ventilation exhaust (2)unit 1, particulate filter air sample from 1RMS-RE6A, radwaste building ventilation exhaust (3)unit 1, iodine charcoal sample from 1RMS-RE126, main plant exhaust stack (4)unit 1, liquid effluent sample from radwaste tank B and C
Dose Calculations (IP Section 03.03) (2 Samples)
The inspectors evaluated the following dose calculations:
(1)unit 1, liquid effluent discharge permit #L-20210324-040-B (2)unit 1, liquid effluent discharge permit #L-20221127-178-B
Abnormal Discharges (IP Section 03.04) (1 Sample)
The inspectors evaluated the following abnormal discharges:
- (1) unplanned release of radioactive gasses from the turbine building in June of 2023
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.
Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.
GPI Implementation (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative (GPI) program to identify incomplete or discontinued program elements.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) July 1, 2023, through June 30, 2024
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
- (1) July 1, 2023, through June 30, 2024
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
- (1) July 1, 2023, through June 30, 2024
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program to identify potential trends in equipment qualification program controls that might be indicative of a more significant safety issue.
INSPECTION RESULTS
Failure to Conduct an (a)(3) Evaluation Within 24 Months Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2024003-01 Open/Closed
[H.8] -
Procedure Adherence 71111.12 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 50.65(a)(3) for the licensees failure to evaluate performance and condition monitoring activities and associated goals and preventive maintenance activities at least every refueling cycle provided the interval between evaluations does not exceed 24 months. Specifically, the licensee has not completed the required evaluation since December of 2021.
Description:
In July 2024, the inspectors requested the previous two (a)(3) evaluations as part of a baseline 71111.12 sample. The licensee provided the (a)(3) evaluations from December 2019 and December 2021. The inspectors questioned where the evaluation from December 2023 was and were informed it was not completed and would not be complete until December 2024. Title 10 CFR 50.65(a)(3) specifies that evaluation of performance and condition monitoring activities and associated goals and preventive maintenance activities be evaluated on a frequency not to exceed 24 months. Additionally, NRC endorsed NUMARC 93-01, revision 4f, section 12 also states evaluations are not to exceed 24 months.
To aid in meeting the regulations, the licensee has Procedure EN-DC-207, Maintenance Rule Periodic Assessment, which in section 7.3.1.2 states that the assessment interval shall not exceed 24 months. By not having the review completed by December of 2023, the licensee has exceeded the 24-month period and is therefore in violation of 10 CFR 50.65(a)(3).
The inspectors determined that had the licensee completed the (a)(3) evaluation on time in December of 2023, there would have been multiple issues requiring evaluation and adjustments would be required to ensure the objective of preventing failures is balanced against the objective of minimizing unavailability. The inspectors identified the following examples:
The station received a white finding within the (a)(3) assessment period; see NOV 05000458/2023092-01 for radiation monitors-RMS-RE125, Main Plant Exhaust Primary, MidRange and High-Range Detectors-; RMS-RE126, Main Plant Exhaust Secondary, LowRange Detector;- RMS-RE5A, Fuel Building Ventilation Primary, Low/Mid/High-Range Detectors; RMSRE6A, Radwaste Building Vent Primary, Low-Range and Mid-Range Detectors; RMS-RE107, LiquidRadwaste Effluent, Low-Range Detector.
The licensee failed to capture and access the availability time of the station's nuclear boiler main steam safety and relief valve compressors. The system was down for maintenance so frequently the licensee utilized a temporary modification to install a third backup compressor to reduce single point vulnerability.
The licensee also installed an external air conditioning unit implemented as a temporary modification for the service air compressors to maintain their availability and reliability that should have been scoped into the maintenance rule.
Corrective Actions: The licensee entered this issue into their corrective action program.
Corrective Action References: CR-RBS-2024-04013
Performance Assessment:
Performance Deficiency: Title 10 CFR 50.65(a)(3) requires the licensee to perform an evaluation of their maintenance rule program on an interval not to exceed 24 months. The licensee failed to conduct a maintenance effectiveness evaluation which is reasonably within their ability to foresee and correct and is 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. Failing to conduct required maintenance effectiveness evaluations and assess system performance could degrade equipment reliability and therefore performance. Specifically, the licensee should have tracked availability and evaluated temporary modifications implemented to balance availability and reliability of the service air and main steam safety relief valve compressor systems.
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 the finding to be of very low safety significance (Green) because the finding affected the qualification of a mitigating SSC and did not affect its operability or probabilistic risk assessment (PRA) functionality.
Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. The licensee failed to follow fleet Procedure EN-DC-207 which was a contributing cause to their noncompliance with the regulation.
Enforcement:
Violation: Title 10 CFR 50.65(a)(3) requires, in part, that performance and condition monitoring activities and associated goals and preventive maintenance activities shall be evaluated at least every refueling cycle provided the interval between evaluations does not exceed 24 months.
Contrary to the above, from December 2023 to September 30, 2024, the licensee failed to evaluate the performance and condition monitoring activities and associated goals and preventive maintenance activities every 24-months. Specifically, the licensee failed to perform the required evaluation since December 2021.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Inadequate Performance Criteria for (a)(2) Structures, Systems, and Components Prevented Effective Monitoring of Maintenance Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2024003-02 Open/Closed
[H.14] -
Conservative Bias 71111.12 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 50.65(a)(2) when the licensee failed to demonstrate the systems were effectively controlled through appropriate maintenance. Specifically, when operability evaluations and compensatory measures were used as acceptable reasons for not performing maintenance preventable functional failure evaluations or maintenance preventable functional failures were just not identified. When the evaluations are not completed the licensee cannot monitor the system against the established criteria for functional failures and condition monitoring events.
Description:
In order to meet the requirements of 10 CFR 50.65 (a)(1) and (a)(2), the licensee establishes performance criteria for (a)(2) systems as maintenance preventable functional failures (MPFFs) and condition monitoring events (CMEs) each with a respective allowed number of occurrences. When reached, an evaluation for moving the system to (a)(1) is required. The licensee established station Procedure EN-DC-205, Maintenance Rule Monitoring, to implement this process.
The inspectors reviewed several maintenance rule systems and determined that the licensee is not completing maintenance rule functional failure evaluations when required by the licensees maintenance rule program. Four examples are provided below:
For the first example, the inspectors reviewed the licensees implementation of the maintenance rule for the auxiliary building ventilation system. The system was monitored in the maintenance rule program as system 409, heating, ventilation, and air conditioning (HVAC) auxiliary building ventilation, and monitored against licensee established criteria for MPFFs and CMEs. The licensee established zero MPFFs as the limit and defined an MPFF as inability or failure to maintain auxiliary area/room temperatures within allowable limits.
The description further states an MPFF is the inability or failure to maintain an area/room within the allowable limits of the Technical Requirements Manual (TRM) technical limiting condition for operation (LCO) 3.7.10. The licensee believed that after identifying an adverse condition, as long as the system remained operable using an operability evaluation, that even if the function of the system was unable to be met it did not need to be evaluated as an MPFF.
The main steam tunnel (MST) is an area that is cooled by auxiliary building ventilation unit cooler HVR-UC8 scoped as part of system 409. The maximum temperature for the MST from Updated Safety Analysis Report (USAR) Table 9.4-1 is 135 degrees Fahrenheit. This value is in Table 3.7.10.1 of TLCO 3.7.10 as the allowable limit for the MST. The MST routinely exceeds 135 degrees Fahrenheit. When temperature exceeds 135 degrees Fahrenheit in the MST, the licensee has performed an operability evaluation to provide for the continued operation of the equipment; therefore, the adverse condition was not evaluated as an MPFF, despite the equipment failing to perform its function to maintain the MST under maximum design temperature.
For the second example, the inspectors reviewed the licensees implementation of the maintenance rule for the digital radiation monitoring system, system 511. For this system, the licensee established a performance criterion of less than or equal to 2 MPFFs over 24 months and CMEs less than or equal to 12 events over 24 months.
The licensee defined an MPFF as inability or failure to perform process radiation monitoring requirements for each individual monitor. The description further states that an MPFF only occurs if compensatory actions and a redundant monitor fail. The licensee defines a CME as the failure of any process radiation monitor that results in reliance on a redundant monitor or compensatory actions.
The licensee believes MPFFs do not have to be evaluated if a compensatory measure can be performed. Compensatory measures utilizing components outside the scoped system have no bearing on the ability of the scoped system being able to accomplish its function. In fact, if a compensatory measure is required, then it is because the system has failed to perform its function. Relying on compensatory measures is not an effective way to evaluate maintenance of a system. When a CME occurs even with compensatory measures in place, the licensee should evaluate for an MPFF to determine if the maintenance performed on the equipment is the reason for the failure.
The third example is for system 256, service water cooling. This is a high risk scoped system in the licensee's maintenance rule program. The licensee established the functional failure criteria as inability or failure of both trains of SSW to provide heat removal capability. During the station's last refueling outage in spring of 2023, they documented excessive leakage of SWP-MOV57A and B in two separate CRs (CR-RBS-2023-02997 and CR-RBS-2023-43125).
These valves are the isolation valves between the safety related (SR) standby service water (SSW) system and the non-safety-related (NSR) normal service water system. Upon a valid signal for SSW to initiate, these valves close and provide isolation between the SR and NSR systems that require service water cooling. However, because these valves were not maintained properly, they had developed excessive seat leakage. This leakage would ultimately drain the ultimate heat sink as service water would be lost from the SR side of the system by leaking passed the degraded valves to the NSR side of the system. The CRs document significant enough leakage that the site would not have the inventory of water required in the ultimate heat sink to meet the accident mission time of 30 days. The licensee documented the event as a safety system functional failure (SSFF) and reported it in licensee event report (LER) 05000458/2023-001-01. Incidentally, the licensee has the same criteria as an SSFF for an MPFF. Each excessive leakage CR for the respective valves was documented as a CME for system 256, but the site had no procedures driving extent of condition from one division to another to access an MPFF. The CME has a criterion of less than or equal to two occurrences, so the licensee did not evaluate this system for (a)(1)status because the two individual failures together did not exceed the value. However, the excessive leakage for each valve occurred at the same time which is why they reported a loss of safety function in an LER. This meets their criteria for MPFF which has a threshold of
0. The licensee should have evaluated these CRs as an MPFF for the SSW system and
evaluated and placed the system in (a)(1) status.
The fourth example is for system 203, high pressure core spray (HPCS). An SSFF was not counted as an MPFF, and the system was not evaluated or moved to (a)(1) status. The licensee scoped HPCS into the maintenance rule with the functional failure criteria of inability or failure of the HPCS system to provide high pressure reactor coolant to the reactor vessel when required. In September of 2022, the licensee had a catastrophic failure of the division 3 480V transformer leaving HPCS incapable of performing its function. This is captured in LER 05000458/2022-004-01 and NOV 05000458/2023090-01. It is important to note the NOV documented an appendix B, criterion V violation which was specifically attributed to maintenance. The licensee did not count this event as an MPFF against the HPCS system, despite meeting the criteria, as HPCS was unable to provide coolant to the vessel. Instead, the licensee counted this event as a CME against 480VAC distribution system, system 303.
This system is allowed less than or equal to one CME before an evaluation for (a)(1) and therefore remains in (a)(2). System 303 also has no MPFF criteria. The licensee should have counted the failure against the HPCS system which would have tripped the criteria for an (a)(1) evaluation.
Corrective Actions: The licensee entered this issue into their corrective action program.
Corrective Action References: CR-RBS-2024-04957
Performance Assessment:
Performance Deficiency: The inspectors determined the licensee failed to demonstrate that maintenance rule systems were effectively controlled through appropriate maintenance when operability evaluations, compensatory measures, and inadequate testing were used as acceptable reasons for not performing maintenance rule functional failure evaluations. This was reasonably within the licensee's 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, by not establishing adequate performance criteria, the licensee can mask equipment failures and not evaluate systems for (a)(1) status which could overall reduce reliability and availability of the system.
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 the finding to be of very low safety significance (Green) because the finding affected the qualification of a mitigating SSC and did not affect its operability or 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 in order to proceed, rather than unsafe in order to stop.
Enforcement:
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, from December 21, 2021, to September 30, 2024, the licensee failed to demonstrate that the performance or condition of an SSC was being effectively controlled through the performance of appropriate preventative maintenance, such that the SSC remained capable of preforming its intended function.
Specifically, for auxiliary building HVAC, digital radiation monitors, Standby service water and high pressure core spray the licensee failed to demonstrate the systems were effectively controlled through appropriate maintenance when operability evaluations, compensatory measures, and inadequate testing were used as acceptable reasons for not performing maintenance rule functional failure evaluations. When the evaluations are not completed the licensee cannot monitor the system against the established criteria for functional failures and CMEs.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Perform Testing for Safety-Related Unit Cooler Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2024003-03 Open/Closed None (NPP)71111.12 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 XI, Test Control, when the licensee failed to incorporate a test program to verify that the main steam tunnel unit cooler, HVR-UC8, was supplying adequate airflow to maintain the main steam tunnel under Updated Safety Analysis Report (USAR) specified maximum temperatures.
Description:
The inspectors identified that there is no current test program to ensure auxiliary building unit cooler, HVR-UC8, will perform satisfactorily. Since 2010, the licensee has generated numerous condition reports (CR) that document temperature deviations in the main steam tunnel (MST) ranging from 136-142 degrees Fahrenheit. USAR Table 9.4-1 and the TRM both indicate the MST temperature shall not exceed 135 degrees Fahrenheit. The MST is cooled by SR unit cooler, HVR-UC8. This unit cooler is comprised of finned cooling coils, where service water flows on the tube side, and an adjustable-blade fan assembly that directs airflow across the finned coils. The cooled air is then routed to the MST room via ductwork. Calculation G13.18.2.1*061, auxiliary building design basis heat loads and unit cooler sizing verification, analyzed that unit cooler HVR-UC8 must supply an air flow of at least 18,000 cubic feet per minute (cfm) to meet cooling requirements. The inspectors reviewed document 7215.253-809-009A, Auxiliary Building Unit Cooler Performance at 95 F Service Water Temperature, that indicates the required service water flow to HVR-UC8 is 120 gallons per minute. The most recent division 1 flow balance (WO 00323938) and CR-RBS-2018-05468 indicate that flow was measured at 129 gallons per minute. The inspectors noted that the fan output and airflow to the MST has not been measured since 2010 and is not currently being measured. To meet design basis conditions, the heat input to the service water and heat input through the airflow must be within their minimum specifications for unit cooler HVR-UC8 to function properly.
The inspectors noted that the 18,000 cfm air flow was based on the fan blade pitch being set at 32 degrees. In 2010, CR-RBS-2010-03625 was generated during a period where high temperatures were being seen in the MST. This led to WO 00238423 which recorded HVR-UC8 air flow as 15,269 cfm. Engineering subsequently measured flow resulting in a reading of 13,013 cfm. Based on these low flow measurements, WO 00246296 was initiated to verify the blade pitch. Blade pitch was not recorded in this WO. In 2013, WO 00324081 was generated to replace the fan motor. This also required fan blade pitch to be recorded, but only the fan blade position on the hub on a scale of 1-6 was recorded and not the pitch angle as required. The range recorded varied from 4 to 5. The WO was closed without any correlation or justification that the fan blade set point was equivalent to the required pitch angle. The licensee was unable to determine why the fan blade pitch was not recorded in either of the two WOs. Also, the inspectors did not find any information for any post-maintenance testing of air flow after the motor replacement had been completed. Because the design basis requirement for the fan requires a minimum flow of 18,000 cfm and since 2010, the licensee has not measured the airflow into the MST, even after repetitive temperature indications of 136-142 degrees Fahrenheit over a span of 14 years that exceeded the design requirement of 135 degrees Fahrenheit per USAR Table 9.4-1. There exists a concern that MST unit cooler HVR-UC8 may not be able to supply adequate cooling to the MST.
Corrective Actions: The licensee entered this issue into their corrective action program.
Corrective Action References: CR-RBS-2024-03067 and CR-RBS-2024-03091
Performance Assessment:
Performance Deficiency: Title 10 CFR Part 50, appendix B criteria XI, Testing Control, requires that all testing required to demonstrate that an SSC will perform satisfactorily in service is identified and performed in accordance with the written test procedures. The inspectors determined that the licensee failed to perform air flow testing of the MST unit cooler HVR-UC8 to confirm the air flow requirements identified in calculation G13.18.21*06 and therefore 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. As a result of not establishing a test program to verify critical design parameters to ensure unit cooler HVR-UC8 operates satisfactorily, the MST has exceeded its maximum allowed temperature of 135 degrees Fahrenheit for 14 years.
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 the finding to be of very low safety significance (Green) because the finding affected the qualification of a mitigating SSC and did not affect its operability or PRA functionality.
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 Part 50, appendix B, criterion XI, Testing Control, requires a test program be established to assure that all testing required to demonstrate that SSCs will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Contrary to the above, from 2010 to September 30, 2024, the licensee failed to establish testing required to demonstrate that an SSCs will perform satisfactorily in service.
Specifically, the licensee failed to establish a testing program for unit cooler HVR-UC8 with acceptance limits incorporated from design documents.
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 Conditions Adverse to Quality in a Timely Manner Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2024003-04 Open/Closed
[H.12] - Avoid Complacency 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 50, appendix B, criterion XVI, when the licensee failed to correct a condition adverse to quality in a timely manner. Specifically, the licensee identified a condition where the MST temperature exceeded its USAR allowed value of 135 degrees Fahrenheit as far back as 2010. The licensee has documented the issue in CRs repeatedly over the last 14 years.
Description:
In May of 2024 during routine control room walkdowns, the inspectors began questioning the status of the MST temperature. Readings indicated that the temperature was between 137-141 degrees Fahrenheit. The MST high temperature alarm comes in at 145 degrees Fahrenheit. The inspectors noted that the USAR in Table 9.4-1 states the maximum allowed temperature in the MST is 135 degrees Fahrenheit with note 17 stating it was applicable to normal and post loss of coolant accident conditions. The inspectors discovered the licensee has documented this issue as far back as 2010 in CR-RBS-2010-01981. In 2024, CR-RBS-2024-03017 captured the condition of the MST exceeding its USAR. There have been no attempts at corrective actions to restore the operating temperature of the MST. The licensee uses operability evaluations to justify the equipment life of components in the MST operating at temperatures exceeding USAR values.
Corrective Actions: The licensee entered this issue into their corrective action program.
Corrective Action References: CR-RBS-2024-03067
Performance Assessment:
Performance Deficiency: The issue of the MST temperature exceeding its USAR value is a condition adverse to quality. Failing to correct this condition and accepting the deficiency for 14 years is reasonably within the licensee's 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.
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 the finding to be of very low safety significance (Green) because the finding affected the qualification of a mitigating SSC and did not affect its operability or PRA functionality.
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 Part 50, appendix B, criterion XVI (corrective action), requires in part, that measures shall be established to assure that conditions adverse to quality, such as failures, deficiencies, and deviations are promptly identified and corrected.
Contrary to the above, between May 2, 2010, and September 30, 2024, a condition adverse to quality at River Bend Station was not corrected in a timely manner. Specifically, a condition in the MST where temperature exceeded allowed values per USAR Table 9.4-1 was left uncorrected for 14 years.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Meet Surveillance Requirement 3.0.1 for Control Room Envelope Habitability Failed Surveillance Test Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000458/2024003-05 Open/Closed Not Applicable 71111.15 The inspectors identified a Severity Level IV non-cited violation of Technical Specifications Surveillance Requirement Applicability 3.0.1 for the licensees failure to meet the limiting condition for operation for TS 3.7.2 Control Room Fresh Air System when the licensee did not meet surveillance requirement 3.7.2.4. Specifically, after not meeting flow requirements during a control room envelope (CRE) habitability tracer gas surveillance test the licensee did not declare LCO 3.7.2 not met and enter the required action of the TS.
Description:
On June 7, 2024, the licensee performed the control room envelope (CRE)habitability tracer gas surveillance test. The result of the test was 159 standard cubic feet per minute (scfm) with an uncertainty of +/- 192 scfm for a total of 351 scfm, with an acceptance criterion of less than or equal to 300 scfm per Technical Specifications (TS) Surveillance Requirement 3.7.2.4 and the control room habitability program. This condition was documented in CR-RBS-2024-03134.
The licensee did an operability evaluation in CR--RBS--2024-03134 to justify operability of the CRE and did not enter into the associated 90-day completion time per TS 3.7.2. Condition B.
The licensee's operability evaluation incorrectly used engineering evaluation ER-RBS-2004-0094 and calculations G13.18.2.1*090-0 and G13.18.9.5*070 to justify operability of the CRE and not enter into the 90-day completion time after failing to meet the surveillance requirement.
On July 25, 2024, the licensee performed a retest of the CRE habitability tracer gas surveillance and again failed to meet the acceptance criteria. This time the test result was 204 scfm with an uncertainty of +/- 225 scfm for a total of 429 scfm. This condition was documented in CR-RBS-2024-04019. At this time the licensee declared the CRE inoperable and entered into the 90-day completion time. It was not until the inspectors questioned why the licensee did not enter TS 3.7.2 Condition B back on June 7, 2024, that the licensee agreed that they failed to enter LCO 3.7.2 Condition B when they first failed the surveillance.
The licensee wrote CR--RBS--2024--04030 documenting the inspectors operability concern.
The licensee revised the start time for entering TS 3.7.2 Condition B to reflect the June 7, 2024, surveillance failure.
Corrective Actions: The licensee entered this issue into their corrective action program.
Corrective Action References: CR-RBS-2024-03134, CR-RBS-2024-04019, and CR-RBS-2024-04030
Performance Assessment:
The inspectors determined this violation was associated with a minor performance deficiency.
Enforcement:
The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.
Severity: Because this performance deficiency had the potential to impact the NRCs ability to perform its regulatory function, it is necessary to address this violation using traditional enforcement to adequately deter noncompliance. In accordance with NRC Enforcement Policy Section 6.1.d.1, the violation was categorized as Severity Level IV because a failure to comply with a TS action requirement demonstrates misapplication of the allowances for LCO and surveillance requirement applicability in TS section 3.0.
Violation: TS Surveillance Requirement Applicability 3.0.1 states in part, that the failure to meet a surveillance shall be failure to meet the LCO.
Surveillance Requirement 3.7.2.4 requires, in part, the performance of CRE unfiltered air in
-leakage testing in accordance with CRE habitability program.
Contrary to the above, from June 7, 2024, to July 26, 2024, the licensee failed to meet a surveillance requirement and therefore failed to meet the LCO. Specifically, on June 7, 2024, the licensee failed to meet Surveillance Requirement 3.7.2.4. This resulted in the failure to meet LCO 3.7.2. The licensee failed to enter the TS 3.7.2and apply the required action statements.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Critique a Weakness During a Biennial Exercise Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000458/2024003-06 Open/Closed
[H.1] -
Resources 71114.01 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 50.47(b)(14) for the licensees failure to identify and correct weaknesses in emergency response organization performance during a biennial emergency preparedness exercise conducted on June 25, 2024. Specifically, the licensee did not identify an example of performance that would have precluded effective implementation of the emergency plan if it occurred during an actual radiological emergency (inadequate emergency worker protection).
Description:
The inspectors observed an emergency preparedness exercise conducted June 25, 2024, and observed the licensees formal exercise critique conducted on July 24, 2024. Based on these observations, and review of corrective action documentation, the inspectors determined that the licensee failed to identify an emergency response organization weakness in emergency worker protective action and as a result did not ensure that the weakness would be corrected.
The NRC inspectors observed the performance of the licensees emergency response organization, including organization members in the control room simulator, Operations Support Center (OSC), Technical Support Center (TSC) and the Emergency Operations Facility (EOF). During an emergency, a range of protective actions have been developed for emergency workers in the plume exposure pathway emergency planning zone (EPZ) by established processes.
The River Bend Station Emergency Plan states the expectations for emergency worker radiological protection provided within the EOF. Section 13.3.6.1.5.1 describes its method designed to protect against radiological hazards. To ensure habitability, three things are provided:
- Exterior wall shielding
- Ventilation
- Radiological monitoring It says that the EOF ventilation system, containing both high efficiency particulate air (HEPA)and charcoal filters, is isolated from the external environment. Further, the HEPA filter is inserted by remote or manual operation. Radiological monitoring to determine radiation levels within the EOF also takes place. This implements part of the range of protective actions developed for emergency workers for the plume exposure pathway emergency planning zone (EPZ), supporting the 10 CFR 50.47(b)(10) planning standard.
Conditions for when these protective measures are provided is further clarified in the licensees EOF operation procedures. EN-EP-609, Emergency Operations Facility (EOF)
Operations, revision 7, Attachment 5, Step 2.4.c.2.a directs actions for realignment of ventilation. Specifically, if there is a radiological release onsite, the Radiological Assessment Coordinator (RAC) is to notify the Administration and Logistics Coordinator to place EOF ventilation/isolation in service. Directions to be used by the Administration and Logistics Coordinator for placing EOF ventilation in Emergency Mode are described in procedure EIP-2-020, Emergency Operations Facility, revision 42, Attachment 3, Subsequent Action 14.
At 10:00am, exercise scenario events resulted in the start of a radiological release from containment above federal limits. An observation communicated among the EOF personnel was that this release was moving in the direction of the EOF itself (10:01am). Therefore, actions to realign EOF ventilation in Emergency Mode were required.
The inspectors reviewed their observations and exercise player records to ascertain what actions were taken to address EOF ventilation realignment and habitability monitoring.
Periodic radiological surveys were being performed in the EOF. Review of position logs and procedures used by both the RAC and Administration and Logistics Coordinator did not indicate that the realignment took place. The inspectors discussed this with the licensee following their end of critique management presentation, since the issue was not identified by them. Based on licensee review, it was confirmed that exercise player documentation didnt support that this was addressed. Licensee interview with the exercise players showed that although the RAC verbally directed the Administration and Logistics Coordinator to place ventilation in Emergency Mode, the action did not take place. Although surveys were being taken that could detect changes in radiation levels, this would identify changes after the workers had been exposed to them for some time. In a real radiological emergency, the radiological dose to the workers could have been reduced or avoided had the ventilation been properly aligned. Habitability would not be ensured consistent with the emergency plan.
The inspectors reviewed documentation describing the emergency preparedness critique process to gain insights on the identification of deficiencies and weaknesses.
Procedure EN-EP-308, Emergency Planning Critiques, revision 7, section 7.2, step 4, says potential deficiencies in personnel performance will be identified through the critique process. Further, step 9 says, in part, to document identified weaknesses, deficiencies, or significant areas for improvement using the corrective action process. The performance objective for this topic (Attachment 3, Objective K.5.3), which sets the evaluation criteria for notification review, states, Emergency ventilation systems were promptly started and operated properly for the emergency conditions. To ensure this objective was evaluated for another emergency response facility that would meet requirements to change ventilation operations (the TSC), the licensee developed Message 2.3 in the exercise scenario package.
This provided evaluators and controllers with the information to guide players in its performance, as well as providing the procedure content needed to evaluate if the actions taken addressed this objective. Based on discussion between the inspectors and the licensee, similar documentation ensuring that this objective was evaluated in the EOF was not developed. Therefore, the inspectors concluded that the licensee did not provide appropriate resources to their evaluators to make sure that this was assessed appropriately.
The inspectors concluded the failure to realign EOF ventilation providing radiological protection for its emergency workers in a manner described in the licensees emergency plan precluded the effective implementation of the said plan and constituted a weakness in emergency response organization performance.
Corrective Actions: The licensee entered these issues into the corrective action program.
Corrective Action References: CR-RBS-2024-04526
Performance Assessment:
Performance Deficiency: The licensees failure to correct weaknesses that occurred during an exercise was a performance deficiency. This was within the licensees ability to foresee and correct. A weakness is defined in Section 2.0(o) of Inspection Manual Chapter 0609, appendix B, Emergency Preparedness Significance Determination Process, (dated September 22, 2015) as emergency response organization performance that would have prevented the effective implementation of the licensees emergency plan had the circumstances occurred. The emergency response organizations failures to provide a range of protective actions to emergency workers in the Emergency Operations Facility was a weakness requiring correction.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the ERO Performance attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The licensees ability to ensure that adequate measures will be taken to protect the health and safety of the public is degraded when weak emergency response organization performance is not corrected.
Significance: The inspectors assessed the significance of the finding using IMC 0609, appendix B, Emergency Preparedness SDP. The performance deficiency was determined have very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded risk significant planning standard function. Although the weakness was associated with a risk significant planning standard (RSPS), aspects affecting worker protection are not treated as risk significant. The finding was not a loss of planning standard function because the licensee appropriately critiqued other weaknesses associated with risk-significant activities and the 10 CFR 50.47(b) planning standards.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. The finding had a cross-cutting aspect in the area of human performance associated with resources because the licensee failed to ensure resources were available and adequate to support nuclear safety. Specifically, the licensees exercise evaluation tools (prepared evaluator/controller documentation) were not developed to support appropriate evaluation of EOF ventilation alignment activities.
Enforcement:
Violation: Title 10 CFR 50.54(q)(2), requires, in part, that a power reactor licensee follow and maintain the effectiveness of an emergency plan which meets the requirements of appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b). Title 10 CFR 50.47(b)(14) requires, in part, that deficiencies identified as a result of exercises or drills are (will be) corrected. Title 10 CFR Part 50, appendix E, section IV.F.2.g requires in part that all exercises provide for formal critiques in order to identify weak or deficient areas that need correction. Any weaknesses or deficiencies that are identified in exercise critiques must be corrected.
Contrary to the above, on July 24, 2024, the licensee failed to correct deficiencies identified as a result of exercises or drills. Specifically, the licensee failed to identify an emergency response organization performance deficiency (weakness) occurring during the June 25, 2024, biennial exercise and did not ensure correction of the weaknesses. There was no actual or potential safety significance because the weak performance occurred during an exercise.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Inadequate Quality Assurance Practices 71152S The inspectors conducted a semiannual trend review of the licensee's work practices and quality records to ensure there was adequate objective quality evidence to either complete the work task or to tell the scope of the work and materials installed from records. The inspectors identified that the licensee is not consistent with differentiating work packages that require environmental quality controls from those that don't require the extra controls per 10 CFR 50.49. Specific examples of this include work packages that had no place to record what parts or materials were installed in SR systems such as what oil, gaskets, lubricants, tapes, or thread sealants are used for each application. A WO might have a parts list of several different types of tape or lubricant, but not record in the relevant step which piece part it was used on. There were several WOs identified by the residents where the licensee utilized lubricants and thread sealants that were not environmentally qualified causing the licensee to generate a CR and correct the issues. Other WOs did not contain specificity in steps for torque values. The step would state torque in accordance with and list a reference document and not state a specific torque value for the worker to sign off as quality record that the component was torqued to the required value.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On July 12, 2024, the inspectors presented the radiation protection program inspection results to Brad Wertz, General Manager Plant Operations, and other members of the licensee staff.
- On September 5, 2024, the inspectors presented the emergency preparedness exercise inspection results to Phil Hansett, Site Vice President, and other members of the licensee staff.
- On September 19, 2024, the inspectors presented the 71111.11B inspection - end of on-site portion debrief inspection results to Phil Hansett, Site Vice President, and other members of the licensee staff.
- On October 1, 2024, the inspectors presented the 71111.11B inspection exit debrief meeting inspection results to Phil Hansett, Site Vice President, and other members of the licensee staff.
- On October 16, 2024, the inspectors presented the integrated inspection results to Phil Hansett, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Severe Weather Operation
Procedures
R-STM-0203
High Pressure Core Spray System
Procedures
SOP-0030
High Pressure Core Spray System
Procedures
SOP-0053
Standby Diesel Generator and Auxiliaries SYS 309
347
Calculations
G13.18.12.2-022
River Bend Station Combustible Loading
Miscellaneous
Licensed operators NRC exam requalification results from
24
Corrective Action
Documents
CR-RBS-2022-
6099
CR-RBS-2023-
6634
CR-RBS-2023-
07756
CR-RBS-2023-
08569
CR-RBS-2023-
08578
CR-RBS-2023-
09058
Condition Reports pertaining to Licensed Operators
Corrective Action
Documents
CR-RBS-2024-
01469
CR-RBS-2024-
01473
CR-RBS-2024-
203
CR-RBS-2024-
2348
Condition reports pertaining to control room crew operations.
Corrective Action
Documents
DR 24-0035
DR 24-0027
DR 22-0043
DR 23-0016
DR 23-0098
Deficiency Reports pertaining to the plant simulator since the
last Biennial Requalification Inspection.
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
DR 22-0038
DR 23-0096
DR 23-0097
Miscellaneous
Licensed operator remedials from 2024 and 2023 for five
operators
Miscellaneous
Remedial for one control room crew
Miscellaneous
ESOMS record of personnel standing five control room
positions
Miscellaneous
ESOMS records showing number of hours on-shift in a
licensed position for one reactor operator
Miscellaneous
ESOMS records showing number of hours on-shift in a
licensed position for three senior reactor operators
Miscellaneous
History of requalification training attendance for one control
room crew
Miscellaneous
Requalification training and exam performance for one
control room crew since prior requalification inspection
Miscellaneous
Licensed operator scores for all weeks of the 2024 NRC
requalification exam
Miscellaneous
Post Event Simulator Test 23-03
11/17/2023
Miscellaneous
Post Event Simulator Test 23-05
2/13/2023
Miscellaneous
Medical Records of 4 licensed operators
Miscellaneous
EN-OE-100 R036
Operating Experience Bulletin
Miscellaneous
EN-OP-115-06
License reactivations for one reactor operator and two senior
reactor operators
Miscellaneous
R-DAD-TQ-016
RBS Annual Testing 2023-2024 Core Performance Test
Miscellaneous
RJPM-OPS -
P5.24
RJPM-OPS -
P6.24
Operator requalification week three operations exam job
performance measure
Miscellaneous
RJPM-OPS-S1
RJPM-OPS-S2
RJPM-OPS-S4
RJPM-OPS-P1
RJPM-OPS-A2
RBS Licensed Operator Biennial Requalification Job
Performance Measures
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
RJPM-OPS-P5
RJPM-OPS-P6
RJPM-OPS-S5
RJPM-OPS-S6
RJPM-OPS-A3
RJPM-OPS-A9
Miscellaneous
RSES-OPS-866
RSES-OPS-875
RSES-OPS-853
RSES-OPS-873
RBS Licensed Operator Biennial Requalification Simulator
Scenarios
Miscellaneous
RWEX-LOR-RO1
RWEX-LOR-
SRO1
RBS Licensed Operator Biennial Requalification Written
Exams for Week One of Cycle.
Miscellaneous
RWEX-LOR-
SRO2
RBS Licensed Senior Reactor Operator Biennial
Requalification Written Exams for Week Two of Cycle.
Procedures
Simulator Examination Security Checklist
Procedures
Conduct of Simulator Training
Procedures
Operations Training Program Description
Procedures
Simulator Configuration Control
Procedures
Licensed Operator Requalification Annual and Biennial
Exam Development
Procedures
TQF-210-IM05
Remedial Training Plan
Procedures
Maintenance Rule Scope and Basis
Procedures
Maintenance Rule Monitoring
Procedures
Maintenance Rule (a)(1) Process
Procedures
Maintenance Rule Periodic Assessment
Calculations
G13.18.2.1*061
Auxiliary Building Design Basis Heat Loads and Unit Cooler
Sizing Verification
Corrective Action
Documents
CR-RBS-
24-02624
Miscellaneous
Vendor Manual
N430-0109
Operations and Maintenance Manual for NUS CON2000-701
Module Basic Controller
Miscellaneous
Vendor Manual
VTD-B045-0101
Bailey Controls Service Manual Type 701 Basic Controller
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
TSP-0071
Backup SVV Compressor SVV-CT
Work Orders
WO 54037720, 54142462
Corrective Action
Documents
Condition Reports
(Corporate, CR-
HQN-)
24-00750
Corrective Action
Documents
Condition Reports
(CR-RBS-)
24-02277, 2024-03464, 2024-03493, 2024-03616, 2024-
03617, 2024-03620, 2024-03623, 2024-03628, 2024-03629
Corrective Action
Documents
Resulting from
Inspection
Condition Report
(CR-RBS-)
24-04526
Miscellaneous
Emergency Planning 2024 NRC Graded Exercise Senior
Management Presentation
7/24/2024
Procedures
EIP-2-020
Procedures
Emergency Planning Critiques
Procedures
Emergency Operations Facility (EOF) Operations
Calculations
23 Reg Guide Activity Report (Solid Waste)
2/31/2023
Calibration
Records
HCC-2021-Q3
21 Inter/Intra Lab Quality Control Report
11/30/2021
Calibration
Records
HCC-2022-Q2
22 Inter/Intra Lab Quality Control Report
06/14/2022
Corrective Action
Documents
Condition Reports
(CR-RBS-)
21-06689, 2021-07016, 2021-07105, 2022-01811, 2022-
01835, 2022-02543, 2022-03274, 2022-07151, 2022-07374
Miscellaneous
G-20230618-028-
B
Gas Permit Post-Release Data
03/08/2024
Miscellaneous
L-20210324-040-
B
Liquid Permit Pre & Post Release
03/25/2021
Miscellaneous
L-20221127-178-
B
Liquid Permit Pre & Post Release Data
11/29/2022
Miscellaneous
LCOTR # 1-
PTS1-23-RMS-
RE125
LCO Log entry for RMS-RE125
07/11/2024
Miscellaneous
RBG-48149
21 Annual Radioactive Effluent Release Report
04/22/2022
Miscellaneous
RBG-48220
22 Annual Radioactive Effluent Release Report
04/18/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
RBG-48276
23 Annual Radioactive Effluent Release Report
04/16/2024
Procedures
COP-0050
Grab Sampling Gaseous Streams
Procedures
COP-0307
Tritium Determination by Liquid Scintillation Analysis
Procedures
COP-0813
RADIOACTIVE LIQUID DISCHARGE PERMIT PROCESS
Procedures
CSP-0110
Radioactive Liquid Effluent Batch Discharge
Procedures
RSP-0008
Offsite Dose Calculation Manual
Procedures
STP-257-0201
Standby Gas Treatment System Filter Train A Monthly
Operability Test
Procedures
TSP-0030
TESTING OF RADWASTE BLDG. EXH. FILTRATION
SYSTEM Testing of Radwaste Building Exhaust Filtration
System
304
Procedures
TSP-0032
Testing of Turbine Building Iodine Filtration System
Radiation
Surveys
5B NG B6
Fuel Building Exhaust Duct Effluent Gamma Spectrum
Analysis
08/07/2024
Radiation
Surveys
RMS-RE-126
CHAR
Main Plant Exhaust Duct Effluent Gamma Spectrum Analysis 09/07/2024
Radiation
Surveys
RMS-RE-5B NG
Fuel Building Exhaust Duct Effluent Gamma Spectrum
Analysis
07/07/2024
Radiation
Surveys
RMS-RE-6A
CHAR
Radwaste Building Exhaust Duct Effluent Gamma Spectrum
Analysis
09/07/2024
Work Orders
HVW-FLT1A - Perform TSP-30 on Radwaste Bldg. Charcoal
Filter
06/07/2021
Calculations
RHP-0036 49 CFR 190 Dose Determination
05/15/2024
Calibration
Records
STP-554-4205 Meteorological Wind Direction
11/14/2023
Calibration
Records
STP-554-4210 Meteorological Wind Direction
11/14/2023
Calibration
Records
STP-554-4210 Meteorological Air Differential Temperature
11/25/2023
Calibration
Records
STP-554-4209 Meteorological Air Differential Temperature
11/13/2023
Calibration
Records
STP-554-4208 Meteorological Wind Direction
05/06/2024
Calibration
STP-554-4210 Meteorological Air Differential Temperature
05/08/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Records
Calibration
Records
STP-554-4209 Meteorological Air Differential Temperature
05/09/2024
Corrective Action
Documents
Condition Reports
(CR-RBS-)
22-00128, 2022-04115, 2022-04340, 2022-05892, 2023-
231, 2023-03927, 2023-05686, 2023-06774, 2023-07558,
23-07955, 2023-08105, 2024-00916, 2024-01463, 2024-
01661, 2024-01898, 2024-03358
Corrective Action
Documents
Resulting from
Inspection
Condition Report
(CR-RBS-)
24-03739, 2024-03747, 2024-03764, 2024-03765
Miscellaneous
MET Data Substitution Percentages 2021-2023
06/24/2024
Miscellaneous
River Bend Tritium Migration Project
01/31/2024
Miscellaneous
RBG-48148
River Bend Station 2021 Annual Radiological Environmental
Operating Report
04/27/2022
Miscellaneous
RBG-48221
River Bend Station 2022 Annual Radiological Environmental
Operating Report
04/25/2023
Miscellaneous
RBG-48277
River Bend Station 2023 Annual Radiological Environmental
Operating Report
04/10/2024
Miscellaneous
RBS-RPT-22-001
21 Area Monitoring Review
11/21/2022
Miscellaneous
RBS-RPT-23-001
22 Area Monitoring Review
2/01/2023
Miscellaneous
RBS-RPT-24-004
23 Area Monitoring Report
06/19/2024
Procedures
Monitoring of Nonradioactive Systems
Procedures
Radiological Groundwater Protection Program
Procedures
Land Use Census
Procedures
Radiological Environmental Monitoring Program
Procedures
EN-CY-130-03
Radiological Environmental Monitoring Program (REMP) -
River Bend Station
Procedures
Underground Piping and Tanks Inspection and Monitoring
Program
Procedures
Area Monitoring Program
Procedures
Qualification and Training of the RBS Environmental
Services Group
Procedures
Gamma Dose Estimation Environmental
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Thermoluminescence Dosimetry
Procedures
Routine Performance Checks of Meteorological Monitoring
Equipment
Procedures
Data Management for Meteorological Monitoring Program
Procedures
RHP-0036
CFR Dose Determination
303
Self-Assessments
Audit Report for the DTE Audit of Environmental Dosimetry
Company
07/10/2023
Self-Assessments AR-SA Number:
00439164
NRC Pre-Inspection Procedure 71124.07 Self-Assessment
01/11/2024
Self-Assessments NUPIC Audit
Report Number
265
Entergy Audit Report Number WT-WTHQN-2021-00564
03/08/2022