IR 05000458/2009004

IR 05000458-09-004; 07/01/2009 - 09/30/2009; Integrated Resident and Regional Report; Equipment Alignments; Operability Evaluations; Surveillance Testing

ML093160691
Person / Time
Site:	River Bend
Issue date:	11/12/2009
From:	Vincent Gaddy NRC/RGN-IV/DRP/RPB-C
To:	Mike Perito Entergy Operations
References
IR-09-004
Download: ML093160691 (44)

Text

UNITED STATES NUC LE AR RE G UL AT O RY C O M M I S S I O N R E GI ON I V 612 EAST LAMAR BLVD , SU I TE 400 AR LI N GTON , TEXAS 76011-4125 November 12, 2009 Michael Perito Vice President, Operations Entergy Operations, Inc.

River Bend Station 5485 US Highway 61N St. Francisville, LA 70775 Subject: RIVER BEND STATION - NRC INTEGRATED INSPECTION REPORT 05000458/2009004

Dear Mr. Perito:

On September 30, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your River Bend Station. The enclosed integrated inspection report documents the inspection findings, which were discussed on October 7, 2009, with you and other members of your staff.

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

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

This report documents four NRC-identified findings of very low safety significance (Green). All of these findings were determined to involve violations of NRC requirements. However, because of the very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as noncited violations, consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the violations or the significance of the noncited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 E. Lamar Blvd, Suite 400, Arlington, Texas, 76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the River Bend Station facility. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV, and the NRC Resident Inspector at River Bend Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

Entergy Operations, Inc. -2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, and its enclosure, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (ADAMS).

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

Sincerely,

/RA/

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

Enclosure:

NRC Inspection Report 05000458/2009004 w/Attachment: Supplemental Information

REGION IV==

Docket: 05000458 License: NPF-47 Report: 05000458/2009004 Licensee: Entergy Operations, Inc.

Facility: River Bend Station Location: 5485 U.S. Highway 61N St. Francisville, LA Dates: July 1 through September 30, 2009 Inspectors: G. Larkin, Senior Resident Inspector C. Norton, Resident Inspector L. Ricketson, P.E., Senior Health Physicist Approved By: Vince G. Gaddy, Chief, Project Branch C Division of Reactor Projects-1- Enclosure

SUMMARY OF FINDINGS

IR 05000458/2009004; 07/01/2009 - 09/30/2009; Integrated Resident and Regional Report;

Equipment Alignments; Operability Evaluations; Surveillance Testing The report covered a 3-month period of inspection by resident inspectors and an announced baseline inspection by a regional based inspector. Four Green noncited violations of significance were identified. The significance of most findings is indicated by their color (Green,

White, Yellow, or Red) using Inspection Manual Chapter 0609, Significance Determination Process. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green noncited violation of Technical Specification 5.4.1.a for the failure of maintenance personnel to control scaffold erection per procedure. This failure resulted in the licensee installing 31 scaffolds in safety-related areas that required either rework or an engineering evaluation to resolve as-built deviations from the minimum seismic separation requirements. As a result, the design function of the safety-related equipment was potentially adversely affected. The licensee entered this issue into their corrective action program as Condition Report CR-RBS-2009-3963.

The failure to erect scaffolds in accordance with procedures is a performance deficiency. This finding is more than minor because it is similar to Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, Section 4,

Example a, because Entergy had routinely failed to perform the requisite engineering evaluation and because it was associated with the protection against external events attribute of the mitigating systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events in order to prevent undesirable consequences. The finding was determined to be of very low risk significance (Green) because no actual loss of safety function occurred and the finding did not screen as potentially risk significant due to external events. This finding has a crosscutting aspect in the area of human performance, work practices, because the licensee failed to ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported

H.4(c)(Section 1R15).

Green.

The inspectors identified a Green noncited violation of 10 CFR Part 50,

Appendix B, Criterion III, Design Control, for failure to implement measures to ensure that the seismic design basis for the reactor core isolation cooling turbine governor hydraulic system was correctly translated into the specifications, drawings, procedures, or instructions. This resulted in work to reroute the piping and an engineering evaluation to resolve seismic concerns. The licensee entered this issue into their corrective action program as Condition Report CR-RBS-2009-3747.

The failure to implement design control features for the seismic design of the reactor core isolation cooling system is a performance deficiency. This finding was more than minor because it is similar to Inspection Manual Chapter 0612,

Appendix E, Examples of Minor Issues, Section 5, Example a, in that the reactor core isolation cooling turbine was returned to service without the seismic spacing required by the original design or completion of an evaluation for the as-left condition. This resulted in rework and additional engineering analysis to correctly resolve the seismic qualification concerns. The performance deficiency also affected the mitigating systems cornerstone attribute of external events and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events in order to prevent undesirable consequences. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Attachment A, Phase 1 - Initial Screening and Characterization of Findings, for the mitigating systems cornerstone. After answering no to all five questions in the mitigating systems cornerstone column of Table 4a, Characterization Worksheet for Initiating Events, Mitigating Systems, and Barrier Integrity Cornerstones, the inspectors concluded that the finding was of very low safety significance. This finding does not have a crosscutting aspect because the performance deficiency occurred in 1989 and is not reflective of current plant performance (Section 1R15).

Green.

The inspectors identified a Green noncited violation of Technical Specification 5.4.1.a for the failure of operations personnel to provide adequate procedural guidance to preclude water intrusion into the nonseismically qualified standby liquid control system test tank which resulted in the degradation of both trains of the standby liquid control system. The licensee entered this issue into their corrective action program as Condition Report CR-RBS-2009-3862.

The failure to provide appropriate procedures to keep the standby liquid control test tank drained is a performance deficiency. The finding is more than minor because it affects the protection against external events attribute of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems responding to initiating events to prevent undesirable consequences.

The inspectors determined that the finding was of very low safety significance because the finding was not a design or qualification deficiency, did not represent a loss of a system/train safety function, and did not screen as potentially risk significant due to external events. This finding has a crosscutting aspect in the area of problem identification and resolutions corrective action program because the licensee failed to take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity. Specifically, the licensee failed to address the cause of inadvertent water intrusion into the standby liquid control test tank in a timely manner to prevent the common mode failure of both trains of standby liquid control P.1(d)(Section 1R22).

Cornerstone: Barrier Integrity

Green.

The inspectors identified a Green noncited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure of operations personnel to fully implement a station procedure to control obstructions in primary containment openings in Modes 4 and 5. The failure to follow procedure challenged the licensees ability to establish containment closure. The licensee entered this issue into their corrective action program as Condition Report CR-RBS-2009-4296.

The failure to implement the containment closure procedure is a performance deficiency. This finding is more than minor because it affected the configuration control attribute of the barrier integrity objective to provide reasonable assurance that the physical design barriers (containment) will protect the public from radionuclide releases. Using Inspection Manual Chapter 0609, Appendix H,

Containment Integrity Significance Determination Process, the finding was assessed as a Type B finding because it is related to a degraded condition that has potentially important implications for the integrity of the containment without affecting the likelihood of core damage and was of very low significance because the licensee did not lose the capability to close containment when planned. The finding has a crosscutting aspect in the area of human performance, work control, because the licensee failed to appropriately coordinate work activities (identifying cables, quick disconnects, removing unidentified cables) to address the operational impact of those work activities on containment operability

H.3(b)(Section 1R04).

Licensee-Identified Violations

None.

REPORT DETAILS

Summary of Plant Status

River Bend Station began the inspection period at 100 percent core thermal power and remained at that power level except during the following periods and as noted below:

• On July 2, 2009, power was reduced to 85 percent for a control rod line adjustment and returned to 100 percent within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />;

• On July 25, 2009, power was reduced to 77 percent power for a control rod line adjustment and returned to 100 percent within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />;

• On August 6, 2009, power was reduced to 74 percent power for a control rod sequence exchange and returned to 100 percent within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; From August 17, 2009, to September 2, 2009, power was allowed to coastdown from 100 percent to 95 percent for Refueling Outage 15. On September 2, power was first reduced to 83 percent to allow removing moisture-separator reheaters from service and then increased within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 99 percent. Resuming on September 3, power coastdown continued until the licensee scrammed the reactor on September 20, 2009, in response to a loss of forced circulation while shutting down for the refueling outage. The station remained in an outage condition for the remainder of the quarter.

REACTOR SAFETY

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

1R01 Adverse Weather Protection

Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors performed a review of the adverse weather procedures for seasonal extremes (e.g., extreme high temperatures, extreme low temperatures, or hurricane season preparations). The inspectors verified that weather-related equipment deficiencies identified during the previous year were corrected prior to the onset of seasonal extremes, and evaluated the implementation of the adverse weather preparation procedures and compensatory measures for the affected conditions before the onset of, and during, the adverse weather conditions.

During the inspection, the inspectors focused on plant-specific design features and the procedures used by plant personnel to mitigate or respond to adverse weather conditions. Additionally, the inspectors reviewed the Updated Safety Analysis Report and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant-specific procedures. Specific documents reviewed during this inspection are listed in the attachment. The inspectors also reviewed corrective action program items to verify that plant personnel were

identifying adverse weather issues at an appropriate threshold and entering them into their corrective action program in accordance with station corrective action procedures.

The inspectors reviews focused specifically on the following plant systems:

• Fancy Point 500 KVac and 230 KVac substation

• River Bend transformer yard

• 13.8 KVac normal switchgear

• Reactor core isolation cooling These activities constitute completion of one sample of readiness for seasonal adverse as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignments

.1 Partial Walkdowns

a. Inspection Scope

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

• Standby service water

• Division 1 diesel generator

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

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

b. Findings

Introduction.

The inspectors identified a Green noncited violation of Technical Specification 5.4.1.a, for the failure of operations personnel to fully implement a station procedure to control obstructions in primary containment openings in Modes 4 and 5.

The failure to follow procedure challenged the licensees ability to establish containment closure

Description.

The inspectors reviewed Operations Section Procedure OSP-0034, Control of Obstructions for Primary Containment/Fuel Building Operability, Revision 5.

This procedure directs operators to control containment penetration obstructions in Modes 4 and 5 and allows opening of the containment airlock doors during core alterations and operations with the potential to drain the vessel. On September 24 and 25, 2009, during Refueling Outage 15, the resident inspectors determined that Entergy failed to follow Procedure OSP-0034 requirements. Specifically, at the containment 171-foot airlock door, the inspectors identified that several containment cables routed through the airlock door were not properly identified, that multiple communication cables did not have quick disconnects, that tools to rapidly and safely disconnect and remove the communication cables were not appropriately staged, and that operators did not report or remove unidentified cables. Equipment routed through the door could potentially delay timely closure of the airlock, if required. Entergy conducted a human performance error review to identify the gap between station expectations and individual performance. The review identified several gaps such as worker knowledge and training, supervisor roles and responsibilities, and ineffective use by management of communicated plans to inform the station of Procedure OSP-0034 requirements.

Analysis.

The failure to implement the containment closure procedure to ensure timely closure is a performance deficiency. Adherence to this procedure allows opening of the containment airlock doors during core alteration within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of shutdown and operations with a potential to drain the vessel. This finding is more than minor because it affected the configuration control attribute of the barrier integrity objective to provide reasonable assurance that the physical design barriers (containment) will protect the public from radionuclide releases. Using Inspection Manual Chapter 0609, Appendix H, Containment Integrity Significance Determination Process, the inspectors determined that this finding was a Type B finding of very low safety significance (Green) because it is related to a degraded condition that has potentially important implications for the integrity of the containment without affecting the likelihood of core damage, and because Entergy did not lose the capability to close containment when planned, and the finding did not involve hydrogen igniters. This finding has a crosscutting aspect in the area of human performance, work control, because Entergy failed to appropriately coordinate work activities (identifying cables, quick disconnects, removing unidentified cables) to address the operational impact of those work activities on containment operability

H.3(b).

Enforcement.

Technical Specification 5.4.1.a requires that written procedures shall be implemented as recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. RG 1.33, Section 4.j, specifies procedures during shutdown for maintaining containment integrity. Operations Section Procedure OSP-0034, Control of Obstructions for Primary Containment/Fuel Building Operability, Revision 5 directs

operators to control containment penetration obstructions in Modes 4 and 5 and allows opening of the containment airlock doors during core alterations and operations with the potential to drain the vessel. Procedure OSP-0034, Revision 5, paragraphs 6.3.3, 6.3.4, 6.3.5 and 6.3.7, requires in part, that obstructions routed through containment airlock doors shall be tracked in the Obstruction Log Book, should have connectors at the hatch or door areas, shall be labeled at each end of the airlock and if not labeled or labeled improperly will be removed by operations personnel. Contrary to the instructions contained in OSP 0034, on September 24 and September 25, coaxial communication cables and telephone cables were routed through the 171 foot elevation air lock and were not tracked in the Obstruction Log Book, did not have connectors at the hatch or door areas, were not labeled at each end of the airlock, and were not identified and removed operations personnel. Because the finding is of very low safety significance and has been entered into the licensees corrective action program as Condition Report CR-RBS-2009-04296, this violation is being treated as a noncited violation consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000458/2009004-01, Failure to Implement Containment Closure Procedure.

.2 Complete Walkdown

a. Inspection Scope

On August 28, 2009, the inspectors performed a complete system alignment inspection of the standby liquid control system to verify the functional capability of the system. The inspectors selected this system because it was considered both safety significant and risk significant in the licensees probabilistic risk assessment. The inspectors inspected the system to review mechanical and electrical equipment line ups, electrical power availability, system pressure and temperature indications, as appropriate, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. The inspectors reviewed a sample of past and outstanding work orders to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program database to ensure that system equipment-alignment problems were being identified and appropriately resolved. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one complete system walkdown sample as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

.1 Quarterly Fire Inspection Tours

a. Inspection Scope

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

• August 5, 2009, tunnels E and G, fuel building all levels

• August 6, 2009, fire pump house and the circulating water pump structure switchgear

• August 10, 2009, standby cooling tower all levels

• August 13, 2009, transformers D and F yard

• August 13, 2009, main transformer yard The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensees fire plan.

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

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

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

b. Findings

No findings of significance were identified.

.2 Annual Fire Protection Drill Observation

a. Inspection Scope

On August 27, 2009, the inspectors observed a fire brigade activation for a simulated fire in the Control Building 116-foot level RPS B distribution panel. The observation evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies, openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions. Specific attributes evaluated were

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

(2) proper use and layout of fire hoses;

(3) employment of appropriate fire fighting techniques;

(4) sufficient firefighting equipment brought to the scene;

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

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

(7) smoke removal operations;

(8) utilization of preplanned strategies;

(9) adherence to the preplanned drill scenario; and

(10) drill objectives.

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

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

a. Inspection Scope

On July 21, 2009, and August 13, 2009, the inspectors observed a crew of licensed operators in the plants simulator to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• Licensed operator performance

• Crews clarity and formality of communications

• Crews ability to take timely actions in the conservative direction

• Crews prioritization, interpretation, and verification of annunciator alarms

• Crews correct use and implementation of abnormal and emergency procedures

• Control board manipulations

• Oversight and direction from supervisors

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

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

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

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the digital radiation monitoring system.

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

• Implementing appropriate work practices

• Identifying and addressing common cause failures

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

• Characterizing system reliability issues for performance

• Charging unavailability for performance

• Trending key parameters for condition monitoring

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

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

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance

effectiveness issues were entered into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

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

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

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

• Reactor building polar crane heavy lift during power operations, August 8, 2009

• Recovery of Regulatory Guide 1.47 control room annunciation emergent maintenance, August 11, 2009

• Preferred station Transformer F planned maintenance, August 14, 2009

• Division 2 offsite ac transfer test planned maintenance, September 27, 2009 The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.

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

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• CR-RBS-2009-03519, nonconservative technical specification specific gravity values for safety-related batteries, reviewed on August 12, 2009

• CR-RBS-2009-03635, D tunnel sump irregularities, reviewed on August 18, 2009

• CR-RBS-2009-03597, Gai-Tronics plant paging system deficiencies, reviewed on September 1, 2009

• CR-RBS-2009-03907, adjacent tubes on RCIC pump/turbine are touching, reviewed on September 2, 2009

• CR-RBS-2009-03963, scaffold nonconformances identified in safety-related buildings, reviewed on September 6, 2009

• CR-RBS-2009-03771, emergency diesel loading calculation inconsistencies, reviewed on September 14, 2009 The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and Updated Safety Analysis Report to the licensee personnels evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

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

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

b. Findings

===.1

Introduction.

The inspectors identified a Green noncited violation of Technical===

Specification 5.4.1.a for the failure of maintenance personnel to control scaffold erection per procedure. This failure resulted in the licensee installing 31 scaffolds built in safety-

related areas that required either rework or an engineering evaluation to resolve as-built deviations from the minimum seismic separation requirements. As a result, the design function of the safety-related equipment was potentially adversely affected.

Description.

On September 2, 2009, the inspectors performed a walkdown of the auxiliary building. On the 70-foot elevation crescent area, the inspectors observed that apre-outage scaffold was in direct contact with the high pressure core spray pump discharge relief vent line. Later that day, the inspectors identified two additional pre-outage scaffold structures in the auxiliary building 95-foot level that also failed to comply with the minimum separation from safety-related equipment requirements of Procedure EN-MA-133, Control of Scaffolding, Revision 5. The licensee subsequently walked down all scaffolding in safety-related areas and determined that 31 installed scaffolds required either rework to comply with the minimum separation requirements of Procedure EN-MA-133 or an engineering evaluation to resolve as-built deviations from the minimum separation requirements of Procedure EN-MA-133. All scaffolds in question were corrected by September 6.

Procedure EN-MA-133 was a corporate procedure issued on July 1, 2009, and superseded the previous site Procedure GMP-0101, Scaffold Installation and Removal, Revision 12. The licensee developed training for scaffold workers on the differences between the two procedures, but did not ensure that all of the scaffold builders completed the new training. Instead, the licensee relied on the scaffold supervisors, who received the training, to ensure that the scaffolds were constructed appropriately.

However, following scaffold construction, supervisors performed inadequate inspections of the completed scaffolds and failed to properly recognize that the seismic construction criteria were not met.

Analysis.

The inspectors determined that the failure to follow the scaffolding control procedure was a performance deficiency. This finding is more than minor because it is similar to Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, Section 4, Example a, because Entergy had routinely failed to perform the requisite engineering evaluation and because it was associated with the protection against external factors attribute of the mitigating systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events in order to prevent undesirable consequences. The finding was determined to be of very low risk significance (Green) because no actual loss of safety function occurred and the finding did not screen as potentially risk significant due to external events. Specifically, the inspectors determined that the as-found position of the scaffolding did not adversely affect the seismic qualification of safety-related components. This finding has a crosscutting aspect in the area of human performance, work practices, in that the licensee failed to ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported H.4(c).

Enforcement.

Technical Specification 5.4.1.a requires that the licensee establish, implement and maintain the applicable procedures recommended in Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, dated February 1978.

Regulatory Guide 1.33, Appendix A, stated, Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed

in accordance with written procedures appropriate to the circumstances. Procedure EN-MA-133, Control of Scaffolding, Revision 5, Section 3.0 [6], Horizontal and Vertical Separation from Safety-Related Equipment, partially implemented this requirement and stated, All braced scaffold members shall maintain a minimum horizontal and vertical separation of 2 inches or greater from safety-related equipment (3 inches from expanding system components). Contrary to this requirement, sometime before September 2, 2009, licensee personnel placed scaffolding in configurations that did not assure the minimum separation from safety-related equipment. Specifically, the licensee allowed scaffolding to be in direct contact with the high pressure core spray pump discharge relief vent line. In addition, 31 installed scaffolds required either rework to comply with the requirements of Procedure EN-MA-133 or an engineering evaluation to resolve as-built deviations from the separation requirements of Procedure EN-MA-133.

Because the finding is of very low safety significance and has been entered into the licensees corrective action program as Condition Report CR-RBS-2009-03963, this violation is being treated as a noncited violation consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000458/2009004-02, Failure to Control Scaffold Construction.

===.2

Introduction.

The inspectors identified a Green noncited violation of 10 CFR Part 50,===

Appendix B, Criterion III, Design Control, for failure to implement measures to ensure that the seismic design basis for the reactor core isolation cooling turbine governor hydraulic system was correctly translated into the specifications, drawings, procedures, or instructions. This resulted in work to reroute the piping and an engineering evaluation to resolve seismic concerns.

Description.

On August 21, 2009, the inspectors observed that two of four reactor core isolation cooling turbine governor hydraulic pipes, between the actuator and its remote servo, had slipped out of the pipe clip guides and were touching in some places. The licensee placed the pipes back into the clip guides and established a minimum spacing of 0.008 inches between the pipes. In 1989, the licensee had replaced the four reactor core isolation cooling pipes connecting the governor actuator to the servo to correct improper pipe size, pipe slope, and pipe connection points. This modification invoked River Bend Station Specification 247.000, Installation of Instruments and Instrument Lines, which required that modifications to safety-related vendor supplied equipment piping installations be performed in accordance with the vendors requirements.

On August 22, following restoration of the pipes to their design configuration, the licensee initiated a calculation to evaluate whether or not the pipes maintained their seismic qualifications in the as-found condition.

Follow completion of the calculation on September 3, 2009, Entergy determined the as-found configuration, although a deviation from the seismic requirements of Specification 247.000, was seismically acceptable because the pipes were not over-stressed, the relative contact area between pipes was very large, the movement of the pipes due to thermal and seismic events was very small, and a visual inspection revealed no pipe wear at the points of contact. Therefore, as found, the reactor core isolation cooling system would have performed its design function without failure during a seismic event.

Analysis.

The failure to implement measures to ensure the seismic design basis for the reactor core isolation cooling turbine governor hydraulic system was correctly translated into the specifications, drawings, procedures, or instructions was a performance deficiency. This finding was more than minor because it is similar to Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, Section 5, Example a, in that the reactor core isolation cooling turbine was returned to service without the seismic spacing required by the original design or completion of an evaluation for the as-left condition. This resulted in rework and additional engineering analysis to correctly resolve the seismic qualification concerns. The performance deficiency also affected the mitigating systems cornerstone attribute of external events and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events in order to prevent undesirable consequences. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Attachment 4, Phase 1 -

Initial Screening and Characterization of Findings, for the mitigating systems cornerstone. After answering no to all five questions in the mitigating systems cornerstone column of Table 4a, Characterization Worksheet for Initiating Events, Mitigating Systems, and Barrier Integrity Cornerstones, the inspectors concluded that the finding was of very low safety significance. This finding does not have a crosscutting aspect because the performance deficiency occurred in 1989 and is not reflective of current performance.

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that design control measures be established and implemented to assure that applicable regulatory requirements and the design basis for structures, systems, and components are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, the licensee did not implement measures to ensure that the design seismic basis for the reactor core isolation cooling turbine governor hydraulic system was correctly translated into the specifications, drawings, procedures, or instructions. Because this finding is of very low safety significance and has been entered into the licensee's corrective action program as Condition Report CR-RBS-2009-03747, this violation is being treated as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000458/2009004-03, Failure to Maintain Reactor Core Isolation Cooling System Seismic Design."

1R19 Postmaintenance Testing

a. Inspection Scope

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

• WO 00189111, HVK-CHL-1A Did Not Start When Alternating Divisions, reviewed on July 8, 2009

• WO 51566487, F15-PLATE005 - Perform the Pre-Operational Inspection and Maintenance of the Auxiliary Refuel Platform, reviewed on August 27, 2009

• WR 00172670, Polar Crane Electro-torque Control, reviewed on August 27, 2009

• STP-201-6310, Standby Liquid Control Quarterly Pump and Valve in Service Operability Test, reviewed on August 29, 2009 The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following (as applicable):

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

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

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

b. Findings

No findings of significance were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

The inspectors reviewed the outage safety plan and contingency plans for the Unit 1 refueling outage, that began on September 20, 2009, to confirm that licensee personnel had appropriately considered risk, industry experience, and previous site-specific problems in developing and implementing a plan that assured maintenance of defense in depth. During the refueling outage, the inspectors observed portions of the shutdown and cooldown processes and monitored licensee controls over the outage activities listed below.

• Configuration management, including maintenance of defense in depth, is commensurate with the outage safety plan for key safety functions and compliance with the applicable technical specifications when taking equipment out of service.

• Clearance activities, including confirmation that tags were properly hung and equipment appropriately configured to safely support the work or testing.

• Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication, accounting for instrument error.

• Status and configuration of electrical systems to ensure that technical specifications and outage safety-plan requirements were met, and controls over switchyard activities.

• Monitoring of decay heat removal processes, systems, and components.

• Verification that outage work was not impacting the ability of the operators to operate the spent fuel pool cooling system.

• Reactor water inventory controls, including flow paths, configurations, and alternative means for inventory addition, and controls to prevent inventory loss.

• Controls over activities that could affect reactivity.

• Maintenance of secondary containment as required by the technical specifications.

• Refueling activities, including fuel handling and sipping to detect fuel assembly leakage.

• Startup and ascension to full power operation, tracking of startup prerequisites, walkdown of the drywell (primary containment) to verify that debris had not been left which could block emergency core cooling system suction strainers, and reactor physics testing.

• Licensee identification and resolution of problems related to refueling outage activities.

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

These activities constitute completion of one refueling outage inspection sample as defined in Inspection Procedure 71111.20-05.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the Updated Safety Analysis Report, procedure requirements, and technical specifications to ensure that the surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the following:

• Evaluation of testing impact on the plant

• Acceptance criteria

• Test equipment

• Procedures

• Test data

• Testing frequency and method demonstrated technical specification operability

• Restoration of plant systems

• Fulfillment of ASME Code requirements

• Updating of performance indicator data

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

• Reference setting data

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

• STP-201-6310, Standby Liquid Control Quarterly Pump and Valve in Service Operability Test, reviewed on August 29, 2009

• CSP-0006, Chemistry Surveillance and Scheduling System, performed on September 14, 2009

• STP-302-0602, Div II Off Site AC Sources Transfer Test, performed on September 28, 2009

• STP-302-1601, ENS-SWG1B Loss of Voltage Channel Calibration, performed on September 29, 2009 Specific documents reviewed during this inspection are listed in the attachment.

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

b. Findings

Introduction.

The inspectors identified a Green noncited violation of Technical Specification 5.4.1.a for the failure of operations personnel to provide adequate procedural guidance to preclude water intrusion into the nonseismically qualified standby liquid control system test tank which resulted in the degradation of both trains of the standby liquid control system.

Description.

On August 27, 2009, following maintenance on standby liquid control Pump B, the licensee filled the standby liquid control test tank to perform a standby liquid control Pump B operability test. The test was aborted when the standby liquid control Pump B failed to start. The test tank was drained and a normal system lineup was restored. On August 28, 2009, the inspectors observed 3 to 5 inches of water in the standby liquid control test tank, and informed the licensee. The licensee declared both trains of standby liquid control inoperable. The licensee determined that the two valves used to fill the test tank for the standby liquid control pump operability test were not tightly closed. The licensee closed the two valves and drained the test tank to exit the 8-hour limiting condition for operation action statement. The test tank is classified as a seismic Class 2 component meaning that the tank is supported such that its failure can not damage equipment important to safety as a result of a seismic event. However, when the tank contained water, the test tank was not analyzed to meet seismic requirements and had the potential to render both trains of standby liquid control inoperable to meet a seismic event.

In October 2008, Condition Report CR-RBS-2008-05973 identified that the standby liquid control test tank inlet valve was not tightly closed and resulted in over filling the test tank. However, the licensee did not adequately address the condition and put in place procedural barriers to ensure that isolation valves associated with the tank were properly secured, thereby preventing common mode failures of both trains of standby liquid control. On September 29, 2009, the licensee revised Procedure SOP-0028, Standby Liquid Control, and Procedure OSP-0029, Log Report - Auxiliary, Reactor, and Fuel Buildings, to provide procedural guidance to preclude water intrusion into the nonseismically qualified standby liquid control system test tank.

Analysis.

The failure to provide adequate procedural guidance to preclude water intrusion into the nonseismically qualified standby liquid control system test tank was a performance deficiency. The finding is more than minor because it affects the protection against external events attribute of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems responding to initiating events to prevent undesirable consequences. The inspectors determined that the finding was of very low safety significance because the finding was not a design or

qualification deficiency, did not represent a loss of a system/train safety function, and did not screen as potentially risk significant due to external events. This finding has a crosscutting aspect in the area of problem identification and resolutions corrective action program, because the licensee failed to take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity. Specifically, the licensee failed to address the cause of inadvertent water intrusion into the standby liquid control system test tank in a timely manner to prevent the common mode failure of both trains of standby liquid control

P.1(d).

Enforcement.

Technical Specification 5.4.1.a requires the licensee to establish, implement, and maintain the applicable procedures recommended in Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, dated February 1978.

Contrary to the above, on August 28, 2009, the inspectors identified that the licensee failed to establish appropriate procedural guidance to preclude water intrusion into the nonseismically qualified standby liquid control system test tank. Because this finding is of very low safety significance and has been entered into the licensees corrective action program as Condition Report CR-RBS-2009-03862, this violation is being treated as a noncited violation consistent with Section VI.A.1 of the NRC Enforcement Policy:

NCV 05000458/2009004-04, Failure to Ensure Standby Liquid Control System Test Tank Remained Drained."

1EP6 Drill Evaluation

Training Observations

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on July 21, 2009, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the postevolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that the licensee evaluators noted the same issues and entered them into the corrective action program. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the attachment.

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

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational and Public Radiation Safety

2OS1 Access Control to Radiologically Significant Areas (71121.01)

a. Inspection Scope

This area was inspected to assess licensee personnels performance in implementing physical and administrative controls for airborne radioactivity areas, radiation areas, high radiation areas, and worker adherence to these controls. The inspector used the requirements in 10 CFR Part 20, the technical specifications, and the licensees procedures required by technical specifications as criteria for determining compliance.

During the inspection, the inspector interviewed the radiation protection manager, radiation protection supervisors, and radiation workers. The inspector performed independent radiation dose rate measurements and reviewed the following items:

• Performance indicator events and associated documentation packages reported by the licensee in the Occupational Radiation Safety Cornerstone

• Controls (surveys, posting, and barricades) of radiation, high radiation, or airborne radioactivity areas

• Radiation work permits, procedures, engineering controls, and air sampler locations

• Conformity of electronic personal dosimeter alarm set points with survey indications and plant policy; workers knowledge of required actions when their electronic personnel dosimeter noticeably malfunctions or alarms

• Barrier integrity and performance of engineering controls in airborne radioactivity areas

• Physical and programmatic controls for highly activated or contaminated materials (non-fuel) stored within spent fuel and other storage pools

• Self-assessments, audits, licensee event reports, and special reports related to the access control program since the last inspection

• Corrective action documents related to access controls

• Licensee actions in cases of repetitive deficiencies or significant individual deficiencies

• Radiation work permit briefings and worker instructions

• Adequacy of radiological controls, such as required surveys, radiation protection job coverage, and contamination control during job performance

• Dosimetry placement in high radiation work areas with significant dose rate gradients

• Changes in licensee procedural controls of high dose rate - high radiation areas and very high radiation areas

• Controls for special areas that have the potential to become very high radiation areas during certain plant operations

• Posting and locking of entrances to all accessible high dose rate - high radiation areas and very high radiation areas

• Radiation worker and radiation protection technician performance with respect to radiation protection work requirements Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Adequacy of the licensees internal dose assessment for any actual internal exposure greater than 50 millirem committed effective dose equivalent Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of 21 of samples of access control to radiologically significant areas as defined in Inspection Procedure 71121.01-05.

b. Findings

No findings of significance were identified.

2OS2 ALARA Planning and Controls (71121.02)

a. Inspection Scope

The inspector assessed licensee personnels performance with respect to maintaining individual and collective radiation exposures as low as is reasonably achievable. The inspector used the requirements in 10 CFR Part 20 and the licensees procedures required by technical specifications as criteria for determining compliance. The inspectors interviewed licensee personnel and reviewed the following:

• Interfaces between operations, radiation protection, maintenance, maintenance planning, scheduling and engineering groups

• Integration of ALARA requirements into work procedure and radiation work permit (or radiation exposure permit) documents

• Shielding requests and dose/benefit analyses

• Use of engineering controls to achieve dose reductions and dose reduction benefits afforded by shielding

• Workers use of the low dose waiting areas

• First-line job supervisors contribution to ensuring work activities are conducted in a dose efficient manner

• Radiation worker and radiation protection technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas

• Corrective action documents related to the ALARA program and follow-up activities, such as initial problem identification, characterization, and tracking Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the required fifteen samples and six of the optional samples as defined in Inspection Procedure 71121.02-05.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator Verification

.1 Data Submission Review

a. Inspection Scope

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

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

b. Findings

No findings of significance were identified.

.2 Mitigating Systems Performance Index - Heat Removal System (MS08)

a. Inspection Scope

The inspectors sampled licensee submittals for the mitigating systems performance index - heat removal system performance indicator for the period from the fourth quarter

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

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

b. Findings

No findings of significance were identified.

.3 Mitigating Systems Performance Index - Residual Heat Removal System (MS09)

a. Inspection Scope

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

These activities constitute completion of one mitigating systems performance index residual heat removal system sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.4 Mitigating Systems Performance Index - Cooling Water Systems (MS10)

a. Inspection Scope

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

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

b. Findings

No findings of significance were identified.

.5 Occupational Exposure Control Effectiveness (OR01)

a. Inspection Scope

The inspectors sampled licensee submittals for the Occupational Radiological Occurrences performance indicator for the period from the fourth quarter 2008 through the second quarter 2009. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, was used. The inspectors reviewed the licensees assessment of the performance indicator for occupational radiation safety to determine if indicator related data was adequately assessed and reported. To assess the adequacy of the licensees performance indicator data collection and analyses, the inspectors discussed with radiation protection staff, the scope and breadth of its data review, and the results of those reviews. The inspectors independently reviewed electronic dosimetry dose rate and accumulated dose alarm and dose reports and the dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized occurrences. The inspectors also conducted walkdowns of numerous locked high and very high radiation area entrances to determine the adequacy of the controls in place for these areas.

These activities constitute completion of the occupational radiological occurrences sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.6 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual

Radiological Effluent Occurrences (PR01)

a. Inspection Scope

The inspectors sampled licensee submittals for the Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences performance indicator for the period from the fourth quarter 2008 through the second quarter 2009. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5, was used. The inspectors reviewed the licensees issue report database and selected individual reports generated since this indicator was last reviewed to identify any potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose.

These activities constitute completion of the radiological effluent technical specifications/offsite dose calculation manual radiological effluent occurrences sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

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

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

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

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

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

b. Findings

No findings of significance were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

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

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

b. Findings

No findings of significance were identified.

4OA5 Other Activities

Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

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

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

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

b. Findings

No findings of significance were identified.

4OA6 Meetings

Exit Meeting Summary

On September 25, 2009, the inspector presented the radiation safety inspection results to Mr. M. Perito, Site Vice President, Operations, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On October 7, 2009, the inspectors presented the integrated baseline inspection results to Mr. M. Perito, Site Vice President, Operations, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Baccus, Supervisor, Radiation Protection

T. Bolke, Licensing Specialist

G. Bush, Manager, Plant Maintenance

M. Chase, Manager, Training and Development

J. Clark, Assistant Operations Manager - Shift

L. Coats, Senior Specialist, Radiation Protection

F. Corley, Electrical Design Engineering Supervisor

B. Cox, Manager, Operations

M. Feltner, Manager, Outage

C. Forpahl, Manager, Engineering Programs & Components

D. Heath, Radiation Protection Supervisor

R. Heath, Superintendent, Chemistry

G. Hendl, Senior Engineer, Engineering

W. Holland, Supervisor, Radiation Protection

B. Houston, Manager, Radiation Protection

K. Huffstatler, Senior Licensing Specialist

A. James, Manager, Plant Security

L. Kitchen, Manager, Planning and Scheduling

R. Kowaleski, Manager, Corrective Actions & Assessments

J. Leavines, Manager, Emergency Preparedness

D. Lorfing, Manager, Licensing

W. Mashburn, Manager, Design Engineering

R. McAdams, Manager, System Engineering

J. McElwain, Manager, Human Resources

L. Meyer, Senior Specialist, Radiation Protection

E. Olson, General Manager, Plant Operations

M. Perito, Site Vice President, Operations

R. Persons, Superintendent, Training

J. Roberts, Director, Nuclear Safety Assurance

J. Schlesinger, Supervisor, Engineering

J. Schroeder, Assistant Operations Manager - Training

D. Wiles, Director, Engineering

L. Woods, Manager (Acting), Quality Assurance

NRC Personnel

G. Larkin, Senior Resident Inspector

C. Norton, Resident Inspector

L. Ricketson, P.E., Senior Health Physicist

Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000458/2009004-01 NCV Failure to Implement Containment Closure Procedure (Section 1R04)

05000458/2009004-02 NCV Failure to Control Scaffold Construction (Section 1R15.1)

Failure to Maintain Reactor Core Isolation Cooling System

05000458/2009004-03 NCV Seismic Design (Section 1R15.2)

Failure to Ensure Standby Liquid Control System Test Tank

05000458/2009004-04 NCV Remained Drained (Section 1R22)