ML17160A401
ML17160A401 | |
Person / Time | |
---|---|
Site: | River Bend ![]() |
Issue date: | 06/09/2017 |
From: | Thomas Hipschman Division of Reactor Safety IV |
To: | Maguire W Entergy Operations |
Hipschman T | |
References | |
IR 2017009 | |
Download: ML17160A401 (28) | |
See also: IR 05000458/2017009
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 E. LAMAR BLVD.
ARLINGTON, TX 76011-4511
June 9, 2017
Mr. William F. Maguire
Site Vice President
Entergy Operations, Inc.
River Bend Station
5485 US Highway 61N
St. Francisville, LA 70775
SUBJECT: RIVER BEND STATION - NRC PROBLEM IDENTIFICATION AND
RESOLUTION INSPECTION REPORT 05000458/2017009 AND NOTICE OF
VIOLATION
Dear Mr. Maguire:
On April 28, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a problem
identification and resolution inspection at your River Bend Station. The NRC inspection team
discussed the results of this inspection with Mr. Marvin Chase, Director, Regulatory &
Performance Improvement, and other members of your staff. The results of this inspection are
documented in Enclosure 2.
The NRC inspection team reviewed the stations corrective action program and the stations
implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating
and correcting problems, and to confirm that the station was complying with NRC regulations
and licensee standards for corrective action programs. Based on the samples reviewed, the
team determined that your staffs performance in each of these areas adequately supported
nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating
experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of
these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious
work environment, and interviewed station personnel to evaluate the effectiveness of these
programs. Based on the teams observations and the results of these interviews the team found
no evidence of challenges to your organizations safety-conscious work environment. Your
employees appeared willing to raise nuclear safety concerns through at least one of the several
means available.
The enclosed report discusses a Severity Level IV violation associated with a finding of
very low safety significance (Green). The NRC evaluated this violation in accordance
Section 2.3.2.a of the NRC Enforcement Policy, which can be located at
http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in
W. Maguire 2
the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in
detail in the subject inspection report. The violation is being cited because the licensee
failed to restore compliance with a Title 10 of the Code of Federal Regulations (10 CFR) 50.59
violation associated with the failure to obtain a license amendment that resulted in a more than
minimal increase in the frequency of occurrence of an accident previously evaluated in the final
safety analysis report when implementing a design change to the reactor core isolation cooling
injection location. The NRC previously identified this violation as non-cited violation
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. The NRCs review of your response will also
determine whether further enforcement action is necessary to ensure your compliance with
regulatory requirements.
If you contest the violation or significance of the violation, 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 the River Bend Station.
If you disagree with the 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 the 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for
Withholding.
Sincerely,
/RA Jeffrey Clark for/
Thomas R. Hipschman, Team Leader
Inspection Program and Assessment Team
Division of Reactor Safety
Docket No. 50-458
License No. NPF-47
Enclosure 1: Notice of Violation
Enclosure 2: Inspection Report 05000458/2017009
w/ Attachments: Supplemental Information &
Information Request
cc w/ encl: Electronic Distribution
NOTICE OF VIOLATION
Entergy Operations, Inc. Docket No. 50-458
River Bend Station License No. NPF-47
During an NRC inspection conducted April 10 - 28, 2017, a violation of NRC requirements was
identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
10 CFR 50.59(c)(2) requires, in part, that a licensee shall obtain a license amendment
pursuant to 10 CFR 50.90 prior to implementing a proposed change, test, or experiment
if the change, test, or experiment would result in more than a minimal increase in the
frequency of occurrence of an accident previously evaluated in the final safety analysis
report (as updated).
Contrary to the above, as of April 28, 2017, the licensee failed to obtain a license
amendment pursuant to 10 CFR 50.90 prior to implementing a change, test, or
experiment that resulted in a more than minimal increase in the frequency of occurrence
of an accident previously evaluated in the final safety analysis report (as updated).
Specifically, on July 3, 1999, the licensee implemented a design change to the reactor
core isolation cooling injection location from the reactor vessel head to a feedwater line,
but failed to correctly evaluate that a spurious reactor core isolation cooling actuation
into the feedwater line resulted in a more than minimal increase in the frequency of
occurrence of the loss of feedwater heating accident previously evaluated in the updated
final safety analysis report.
This is a Severity Level IV violation (NRC Enforcement Policy Section 6.1.d.2).
Pursuant to the provisions of 10 CFR 2.201 Entergy Operations, Inc. is hereby required to
submit a written statement or explanation to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional
Administrator, Region IV, 1600 E. Lamar Blvd, Arlington, Texas 76011, and a copy to the NRC
resident inspector at the River Bend Station, within 30 days of the date of the letter transmitting
this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of
Violation, and should include for each violation: (1) the reason for the violation, or, if contested,
the basis for disputing the violation or severity level; (2) the corrective steps that have been
taken and the results achieved; (3) the corrective steps that will be taken; and (4) the date when
full compliance will be achieved. Your response may reference or include previous docketed
correspondence, if the correspondence adequately addresses the required response.
If an adequate reply is not received within the time specified in this Notice, an order or a
Demand for Information may be issued as to why the license should not be modified,
suspended, or revoked, or why such other action as may be proper should not be taken. Where
good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
Enclosure 1
Your response will be made available electronically for public inspection in the NRC Public
Document Room or from the NRCs document system (ADAMS), accessible from the NRC Web
site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, it should not include
any personal privacy, proprietary, or safeguards information so that it can be made available to
the public without redaction. If personal privacy or proprietary information is necessary to
provide an acceptable response, then please provide a bracketed copy of your response that
identifies the information that should be protected, and a redacted copy of your response that
deletes such information. If you request withholding of such material, you must specifically
identify the portions of your response that you seek to have withheld and provide in detail the
bases for your claim of withholding (e.g., explain why the disclosure of information will create an
unwarranted invasion of personal privacy or provide the information required by
10 CFR 2.390(b), to support a request for withholding confidential commercial or financial
information).
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days of receipt.
Dated this 9th day of June 2017
2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Dockets: 05000458
License: NPF-47
Report: 05000458/2017009
Licensee: Entergy Operations, Inc.
Facility: River Bend Station
Location: 5485 U.S. Highway 61N
St. Francisville, LA 70775
Dates: April 10 through April 28, 2017
Team Lead: R. Azua, Senior Reactor Inspector
Inspectors: H. Freeman, Senior Reactor Inspector
P. Jayroe, Project Engineer
B. Parks, Resident Inspector
Approved By: T. Hipschman, Team Leader
Inspection Program and Assessment Team
Division of Reactor Safety
Enclosure 2
SUMMARY
IR 05000458/2017009; 04/10/2017 - 04/28/2017; River Bend Station; Problem Identification
and Resolution (Biennial)
The inspection activities described in this report were performed between April 10 and April 28,
2017, by three inspectors from the NRCs Region IV office and the resident inspector at the
River Bend Station. The report documents one finding of very low safety significance (Green).
This finding involved a violation of NRC requirements; this violation was determined to be
Severity Level IV under the traditional enforcement process. The significance of inspection
findings is indicated by their color (Green, White, Yellow, or Red), which is determined using
Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting
aspects are determined using Inspection Manual Chapter 0310, Aspects Within the Cross-
Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRC
Enforcement Policy. The NRC's program for overseeing the safe operation of commercial
nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.
Assessment of Problem Identification and Resolution
Based on its inspection sample the team concluded that the licensee maintained a corrective
action program in which individuals generally identified issues at an appropriately low threshold.
Once entered into the corrective action program, the licensee generally evaluated and
addressed these issues appropriately and timely, commensurate with their safety significance.
The licensees corrective actions were generally effective, addressing the causes and extents of
condition of problems.
The licensee appropriately evaluated industry operating experience for relevance to the facility
and entered applicable items in the corrective action program. The licensee incorporated
industry and internal operating experience in its root cause and apparent cause evaluations.
The licensee performed effective and self-critical nuclear oversight audits and self-assessments.
The licensee maintained an effective process to ensure significant findings from these audits
and self-assessments were addressed. However, the team identified a potential weakness in
the stations timeliness for processing certain 10 CFR Part 21 notifications through the operating
experience and corrective action programs. The licensee acknowledged this potential
weakness and indicated their plan to address this through the Entergy fleet.
The licensee maintained a safety-conscious work environment in which personnel were willing
to raise nuclear safety concerns without fear of retaliation.
Cornerstone: Initiating Events
- Green. The NRC identified a Severity Level IV violation for the licensees failure to restore
compliance for a non-cited violation (NCV) associated with failure to obtain NRC approval
prior to making a change to the reactor core isolation cooling injection point. Specifically, as
of April 28, 2017, the licensee had not restored compliance with a violation the NRC
identified on October 8, 2015. This violation described a previously made change to the
facility without prior NRC approval in violation of 10 CFR 50.59, Changes, Tests, and
Experiments. The team determined that the licensees failure to restore compliance within
a reasonable amount of time was a performance deficiency. Title 10 CFR 50, Appendix B,
Criterion XVI, requires in part that, measures shall be established to assure that conditions
2
adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material
and equipment, and nonconformances are promptly identified and corrected. The
licensee entered this issue into their corrective action program as Condition Report
The finding was more than minor because it is associated with the initiating events aspect of
the reactor safety cornerstone and affected the cornerstone objective to limit the likelihood
of events that upset plant stability and challenge critical safety functions during power
operations. The finding is of very low safety significance (Green) because it did not cause a
reactor trip and the loss of mitigation equipment relied upon to transition the plant from the
onset of the trip to a stable shutdown condition. The finding has a human performance
cross-cutting aspect associated with procedural adherence because individuals failed to
follow the procedures delineated by the corrective action program [H.8]. Originally, the
licensee met the criteria for dispositioning the issue (50.59) as a NCV. However, based
upon the fact that the condition report, which documented the NCV, was closed without
restoring compliance, the licensee no longer met the criteria for a NCV and therefore, this
violation is being cited in a notice of violation (4OA2.5).
3
REPORT DETAILS
4. OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution (71152)
The team based the following conclusions on a sample of corrective action documents that were
open during the assessment period, which ranged from July 12, 2015, to the end of the on-site
portion of this inspection on April 27, 2017.
.1 Assessment of the Corrective Action Program Effectiveness
a. Inspection Scope
The team reviewed approximately 200 condition reports (CRs), including associated root
cause analyses and apparent cause evaluations, from approximately 20,000 that the
licensee had initiated or closed between July 12, 2015, and April 27, 2017. The majority
of these (approximately 20,000) were lower-level condition reports that did not require
cause evaluations. The inspection sample focused on higher-significance condition
reports for which the licensee evaluated and took actions to address the cause of the
condition. In performing its review, the team evaluated whether the licensee had
properly identified, characterized, and entered issues into the corrective action program,
and whether the licensee had appropriately evaluated and resolved the issues in
accordance with established programs, processes, and procedures. The team also
reviewed these programs, processes, and procedures to determine if any issues existed
that may impair their effectiveness.
The team reviewed a sample of performance metrics, system health reports, operability
determinations, self-assessments, trending reports and metrics, and various other
documents related to the licensees corrective action program. The team evaluated the
licensees efforts in determining the scope of problems by reviewing selected logs, work
orders, self-assessment results, audits, system health reports, action plans, and results
from surveillance tests and preventive maintenance tasks. The team reviewed daily
CRs and attended the licensees CR screening meetings and Plant Review Group
(PRG) meetings to assess the reporting threshold and prioritization efforts, and to
observe the corrective action programs interfaces with the operability assessment and
work control processes. The teams review included an evaluation of whether the
licensee considered the full extent of cause and extent of condition for problems, as well
as a review of how the licensee assessed generic implications and previous occurrences
of issues. The team assessed the timeliness and effectiveness of corrective actions,
completed or planned, and looked for additional examples of problems similar to those
the licensee had previously addressed. The team conducted interviews with plant
personnel to identify other processes that may exist, where problems may be identified
and addressed outside the corrective action program.
The team reviewed corrective action documents that addressed past NRC-identified
violations to evaluate whether corrective actions addressed the issues described in the
inspection reports. The team reviewed a sample of corrective actions closed to other
corrective action documents to ensure that the ultimate corrective actions remained
appropriate and timely. The team reviewed a sample of condition reports where the
4
licensee had changed the significance level after initial classification to determine
whether the level changes were in accordance with station procedures and that the
conditions were appropriately addressed.
The team considered risk insights from both the NRCs and the River Bend Stations risk
models to focus the sample selection and plant tours on risk-significant systems and
components. The team focused a portion of its sample on the control building heating
and ventilation (HVK) system and automatic depressurization system, which the team
selected for a five-year in-depth review. The team conducted walk-downs of the HVK
system and other plant areas to assess whether licensee personnel identified problems
at a low threshold and entered them into the corrective action program. In addition, the
team also reviewed the licensees use of operational experience and the 10 CFR Part 21
(Part 21) process with respect to these systems.
b. Assessments
1. Effectiveness of Problem Identification
During the 22-month inspection period, licensee staff generated approximately
20,000 condition reports. The team determined that most conditions that required
generation of a condition report per Procedure EN-LI-102, Corrective Action
Program, were entered appropriately into the corrective action program. However,
the Team identified a few errors in the development and processing of CRs:
- These errors included assigning the wrong priority to a CR, and/or closing CRs to
a lesser CR, contrary to plant procedures. In most of these instances, the
subsequent actions taken to correct these issues were appropriate to the higher
priority designation. One instance was noted where actions taken were not
commensurate with the required actions for a condition adverse to quality.
Specifically, Condition Report CR-RBS-2015-7259, which was issued in
response to a 10 CFR 50.59 NCV. The licensee closed the CR to a Licensing
Action Request process, which was not an approved process in the corrective
action program. This failure by the licensee to follow their process contributed to
the failure to address the issue in a timely manner, which resulted in a cited
violation. (Section 4OA2.5)
Overall, the team concluded that the licensee generally maintained a low threshold
for the formal identification of problems and entry into the corrective action program
for evaluation. Licensee personnel initiated over 760 CRs per month during the
inspection period. Most of the personnel interviewed by the team understood the
requirements for condition report initiation; most expressed a willingness to enter
newly identified issues into the corrective action program at a very low threshold.
2. Effectiveness of Prioritization and Evaluation of Issues
The sample of CRs reviewed by the team focused primarily on issues screened by
the licensee as having higher-level significance, including those that received cause
evaluations, those classified as significant conditions adverse to quality, and those
that required engineering evaluations. The team also reviewed a number of
condition reports that included or should have included immediate operability
5
determinations to assess the quality, timeliness, and prioritization of these
determinations.
Based on the walk-down of the risk-significant systems selected for the five-year in-
depth review, the team observed that the material condition of these systems
appeared to be adequate. With regard to the HVK system, the team noted that the
plant had experienced a number of recurring issues with this system, over several
years, where corrective actions appeared to have been previously ineffective. This
was one of the reasons the team selected this system for review.
The teams focused review of the licensees more recent actions, with regard to the
HVK system, indicated a more rigorous effort was being applied by the licensee to
get this issue under control. One such action was the licensees placement of this
system in their Top Ten Equipment Reliability Action Plan, which focuses more plant
resources to listed systems in an effort to correct identified problems. Interviews with
licensee staff also indicate that a more concerted effort was being made by plant
management to address identified problems with the HVK system with more
permanent solutions. Having said that, this effort is in its nascent stage. The NRC
will continue to monitor these systems to ascertain the effectiveness of the licensees
corrective actions over time.
Overall, the team determined that the licensees process for screening and
prioritizing issues that had been entered into the corrective action program,
supported nuclear safety. The licensees operability determinations were consistent,
accurately documented, and completed in accordance with procedures.
3. Effectiveness of Corrective Actions
Overall, the team concluded that the licensee generally identified effective corrective
actions for the problems evaluated in the corrective action program. The licensee
generally implemented these corrective actions in a timely manner, commensurate
with their safety significance, and reviewed the effectiveness of the corrective actions
appropriately.
The team identified that since early 2016, there has been a reduction in the number
of adverse events caused by human performance errors and work management
deficiencies on the part of River Bend Station employees. However, this positive
data point was tempered by the team having noticed that a potential area of
vulnerability may still exist in the area of supplemental (contract) employees, for
example transmission and distribution personnel. The licensee stated that they were
aware of this vulnerability and indicated were working to address it.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The team examined the licensees program for reviewing industry operating experience,
including reviewing the governing procedures. The team reviewed a sample of eight
industry operating experience communications and the associated site evaluations to
assess whether the licensee had appropriately assessed the communications for
6
relevance to the facility. The team also reviewed assigned actions to determine whether
they were appropriate.
b. Assessment
Overall, the team determined that the licensee appropriately evaluated industry
operating experience for its relevance to the facility. Operating experience information
was incorporated into plant procedures and processes as appropriate. The licensee was
effective in implementing lessons learned through operating experience. They took full
advantage of being part of the Entergy fleet, to give a thorough review of the operational
experience from a variety of sources. Licensee personnel ensured that significant
issues were dealt with in a thorough and timely manner. This was also true for the
Part 21 process that is within the licensees operational experience program.
The team further determined that the licensee appropriately evaluated industry operating
experience when performing root cause analysis and apparent cause evaluations. The
licensee appropriately incorporated both internal and external operating experience into
lessons learned for training and pre-job briefs.
The team identified one potential weakness with respect to the timeliness of review of
Part 21 notices. Specifically, with regard to Part 21s received where the River Bend
Station was not identified as being affected. In these instances, the notices would be
sent to Entergys Corporate Supply office to be researched. If during this research the
Part 21 was determined to apply to the River Bend Station, the information would be
returned to the site. However, there were no further timeliness goals regarding when
this item should be entered into the corrective action program. The team identified four
examples where the time that lapsed between the publication of a Part 21 notice and
entry into the corrective action program was excessive (80 days to 105 days). None of
the examples identified had an adverse impact on the safety of the plant. Following
discussions with the licensee staff, they acknowledged this insight and indicated that
they plan to address it through the Entergy fleet. The licensee entered this issue into
their corrective action program (Condition Reports CR-RBS-2017-03549 and
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The team reviewed a sample of licensee self-assessments and audits to assess whether
the licensee was regularly identifying performance trends and effectively addressing
them. The team also reviewed audit reports to assess the effectiveness of assessments
in specific areas. The specific self-assessment documents and audits reviewed are
listed in Attachment 1.
b. Assessment
Overall, the team concluded that the licensee had an effective self-assessment and audit
process. The team determined that self-assessments were self-critical and thorough
enough to identify deficiencies.
7
.4 Assessment of Safety-Conscious Work Environment
1. Inspection Scope
The team interviewed 26 individuals in five focus groups. The purpose of these
interviews was: (1) to evaluate the willingness of licensee staff to raise nuclear safety
issues, either by initiating a condition report or by another method, (2) to evaluate the
perceived effectiveness of the corrective action program at resolving identified problems,
and (3) to evaluate the licensees safety-conscious work environment (SCWE). The
focus group participants included personnel from Engineering, Maintenance
(Mechanical, Electrical, and Instrumentation and Controls), Security and Supplemental
(Contract) Engineering personnel. At the teams request, the licensees regulatory
affairs staff selected the participants blindly from these work groups, based partially on
availability. To supplement these focus group discussions, the team interviewed the
Employee Concerns Program manager to assess her perception of the site employees
willingness to raise nuclear safety concerns. The team reviewed the Employee
Concerns Program case log and select case files. The team also reviewed the minutes
from the licensees most recent safety culture monitoring panel meetings.
2. Assessment
1. Willingness to Raise Nuclear Safety Issues
All individuals interviewed indicated that they would raise nuclear safety concerns.
All felt that their management was receptive to nuclear safety concerns and was
willing to address them promptly. All of the interviewees further stated that if they
were not satisfied with the response from their immediate supervisor, they had the
ability to escalate the concern to a higher organizational level. Most expressed
positive experiences after raising issues to their supervisors. All expressed positive
experiences documenting most issues in condition reports.
The team questioned focus group participants whether they were able to submit a
condition report anonymously. Most individuals were aware that they could submit
condition reports anonymously, and were knowledgeable of the process. The team
noted that the number of anonymous CRs has dropped over the last year. This, in
conjunction with the positive staff comments during interviews, was considered an
indicator of improving personnel confidence in the plant and plant management.
2. Employee Concerns Program
All interviewees were aware of the Employee Concerns Program. Most explained
that they had heard about the program through various means, such as posters,
training, presentations, and discussion by supervisors or management at meetings.
All interviewees stated that they would use Employee Concerns if they felt it was
necessary. All expressed confidence that their confidentiality would be maintained if
they brought issues to Employee Concerns.
8
4. Preventing or Mitigating Perceptions of Retaliation
When asked if there have been any instances where individuals experienced
retaliation or other negative reaction for raising issues, all individuals interviewed
stated that they had neither experienced nor heard of an instance of retaliation,
harassment, intimidation or discrimination at the site. The team determined that
processes in place to mitigate these issues were being successfully implemented.
Responses from the focus group interviewees indicate that they believe that
management has established and promoted a safety-conscious work environment
where individuals feel free to raise safety concerns without fear of retaliation.
Overall, employees indicated that they have noticed an improved culture on-site. As
described, there was a sense that management is more interested now in addressing
issues in a manner that will result in more lasting solutions. They indicated that there
is more management support for their efforts.
.5 Findings
Failure to restore compliance for a 10 CFR 50.59 Violation
Introduction. The team identified a Green, Severity Level IV, violation for the licensees
failure to restore compliance for a NCV associated with the licensees failure to obtain
NRC approval prior to making a change to the reactor core isolation cooling injection
point. Specifically, as of April 28, 2017, the licensee had not restored compliance with
the NCV the NRC identified on October 8, 2015. This violation described a change,
which was previously made to the facility without prior NRC approval in violation
of 10 CFR 50.59, Changes, Tests, and Experiments, because the evaluation did not
provide adequate justification as to why the change did not result in a more than minimal
increase in the frequency of occurrence of an accident previously evaluated in the final
safety analysis report.
Description. In 1998, the licensee modified the reactor core isolation cooling injection
point from the reactor head spray nozzle to the 'A' feedwater line via the 'A' residual heat
removal shutdown cooling return line. At that time, the licensees evaluation stated that
the modification did not increase the probability of occurrence of an accident evaluated
previously in the Safety Analysis Report (SAR) and, as a result, did not represent an
unreviewed safety question which would have required NRC approval.
In October 2015 the NRC reviewed the licensees modification to the reactor core
isolation cooling injection point as one of the samples during an inspection on
evaluations of changes, tests, and experiments and permanent plant modifications
(Inspection Procedure 71111.17T). The NRC determined that the licensees evaluation
for this modification was inadequate because the licensee had failed to correctly
evaluate that a spurious reactor core isolation cooling actuation injecting through the
feedwater line would also result in the same characteristics, (and therefore increase the
probability of occurrence) of another accident previously evaluated (loss of feedwater
heating) and that this would be more than a minimal increase in frequency.
The requirements governing the authority of production and utilization facility licensees
to make changes to their facilities without prior NRC approval are contained in
9
10 CFR 50.59. At the time of implementation of this modification, the regulation
provided that licensees may make changes to the facility or procedures as described in
the safety analysis report (SAR), without prior Commission approval, unless the
proposed change, test, or experiment involved a change to the Technical Specifications
incorporated in the license or an unreviewed safety question. Section 50.59(a)(2),
stated the following:
A proposed change, test, or experiment shall be deemed to involve an unreviewed
safety question: (i) if the probability of occurrence or the consequences of an accident
or malfunction of equipment important to safety previously evaluated in the safety
analysis report may be increased; (ii) if a possibility for an accident or malfunction of a
different type than any evaluated previously in the safety analysis report may be created;
or (iii) if the margin of safety as defined in the basis for any technical specification is
reduced.
At the time of the modification, any increase in probability of occurrence or consequence
was considered an unreviewed safety question. On October 4, 1999, the NRC issued a
revision to 10 CFR 50.59 in the Federal Register (64 FR 53582), effective 90 days after
approval of Regulatory Guide 1.187 (issued in November 2000). Among the changes
implemented to the revised rule, the NRC eliminated the term unreviewed safety
question, and clarified the requirements to allow changes, which involved only minimal
increases in probability or consequences to be made without prior NRC approval.
Because this performance deficiency did not meet the requirements of the revised rule
(which allowed for a minimal increase in frequency), it did not meet the criteria for
enforcement discretion, and therefore, was documented as a Severity Level IV, NCV,
consistent with the Enforcement Policy. On October 29, 2015, the NRC documented
this issue in NRC Inspection Report 05000458/2015007. The licensee entered the
performance deficiency into their corrective action program as Condition Report
CR-RBS-2015-7259 and did not deny the violation.
During the current inspection, the NRC team selected Condition Report
CR-RBS-2015-7259 as one of the samples reviewed to assess the adequacy of
the licensees problem identification and resolution program. The team found that
the licensee had not restored compliance with the rule and found several aspects
associated with how the licensee addressed the NCV that deviated from their corrective
action program as specified in Procedure EN-LI-102, Revision 25. These aspects
include:
- The licensee initiated the condition report as significance C and directed it be
upgraded to a significance B ACE CARB [apparent cause evaluation, corrective
action review board] when the finding was issued as a NCV. The NRC documented
the finding on October 29, 2015, and yet the licensee did not upgrade the condition
report until December 17, 2015. This delayed initiation of the apparent cause
evaluation.
- The licensee initially characterized the condition report as a significance C even
though it met two of the criteria listed in Attachment 9.1, Condition Report
Classification Guidance, of Procedure EN-LI-102 to be classified as significance B.
These examples included inadequate 10 CFR 50.59 review, evaluation or screening,
and Green NCV, Green finding violation, or traditional enforcement from the NRC.
10
- The licensee closed the significance B condition report without having corrected the
condition adverse to quality (namely the 10 CFR 50.59 violation for failure to obtain
NRC approval prior to making a change to the facility). In order to restore
compliance, the licensee had three choices: (1) restore the facility to a condition that
did not require NRC approval (restore original design); (2) perform an adequate
evaluation that provided justification as to why the change did not increase the
probability or consequences of an accident by more than a minimal amount [based
upon the current standard] and deny the violation; or (3) submit a license
amendment request requesting NRC approval [after the fact] for a change to the
facility as described in the safety analysis report.
- The licensee closed the condition report to a process that was not allowed by the
corrective action program. Section 5.5[5] CR [condition report] Disposition
Requirements of Procedure EN-LI-102 allows a condition report to be closed to
another condition report as long as the condition report being closed is the same as
or lower category level than the remaining condition report. Attachment 9.6 CR and
CA [corrective action] Closure to WMS [Work Management System] and Tracking,
also allows a condition report/corrective action to be closed to the work management
system if they have Condition Review Group approval. In this case, the licensee
closed the condition report to a licensing action request system, which was neither
another condition report nor part of the work management system, and therefore, not
allowed by the corrective action program. The licensees license action request
system did not have comparable controls or requirements for due date extensions as
specified by the corrective action program.
- The corrective actions did not meet the guidance of Section 5.6[2] Corrective Action
Initiation of Procedure EN-LI-102 for crafting corrective actions, which states that
corrective action content should be specific, measurable, achievable, realistic, and
timely. The licensee did not initiate a corrective action to specifically address the
adverse condition. The action that was initiated was an indirect action that was
assigned to the Design Engineering department to provide technical input to the
Licensing department to support generation of a license amendment request for
submission to the NRC. Once the technical input was provided, the corrective action
and the condition report were closed. An adequate corrective action should have
required the Licensing department to obtain a license amendment accepting the
design change prior to closing the condition report. The failure to restore compliance
continues to exist up until the licensee receives a license amendment.
- The closure review performed by the assigned manager failed to identify that the
condition adverse to quality had not been corrected and that the condition report was
not ready to close. Specific questions contained in Attachment 9.2, Checklist for
Level B CR Closure of Procedure EN-LI-102 that could have identified that the
condition report was not ready for closure include:
o Question 13 stated, verify the corrective actions corrected the condition
identified was checked SAT even though no corrective actions had been
generated to restore compliance.
11
o Question 14 stated, verify that each corrective action identified in the evaluation
and that was otherwise issued to address the condition was completed as
intended. Recommendations and enhancements may be tracked by other
processes, was checked SAT even though a sub question (also marked SAT)
stated, Verify the action item was not closed to a promise of a future action
item. In this case, the future action was implied that the Licensing department
would submit and obtain approval from the NRC for a license amendment.
o Questions 15 through 17 were left unchecked even though they were required to
be checked SAT, including Question 16 which states, verify the corrective
action is not closed to another process other than WO [work order] approved by
the CRG [Condition Review Group]. In this case the implied corrective action
(obtaining NRC approval) was closed to another process, which was not a work
order approved by the Condition Review Group.
o Question 19 (left blank) states, if this quality closure review identifies an
unsatisfactory closure of a checklist item annotated SAT, issue a corrective
action using the UNSAT RESPONSE PI" action type, with specific
recommendations or identified discrepancies that need further review. As noted
above, three questions that should have been annotated SAT, were left blank
and a corrective action was not generated using the UNSAT RESPONSE PI, as
required.
o Question 20 (left blank) states: When all items in the checklist are satisfactorily
completed, the CR is ready to close.
- Corrective Action 14 was closed on October 6, 2016, even though the attached
closure checklist was not completed.
On April 12, 2017, the team determined that the licensee had not restored
compliance with this ongoing violation within a reasonable amount of time for
NCV 05000458/2015007-02, and that any future corrective actions could not be
considered timely and commensurate with the significance. The team concluded that
while the licensee originally met the criteria for dispositioning the 10 CFR 50.59 issue as
a NCV, based upon the fact that the condition report that documented the violation was
closed and the licensee had not restored compliance within a reasonable time (nearly
18 months), the team determined that the licensee no longer met the criteria for a NCV,
and therefore, this violation would be cited in a notice of violation.
Analysis. The team determined that the licensees failure to restore compliance within a
reasonable amount of time for a violation of regulatory requirements associated with a
design modification was a performance deficiency. Specifically, on October 29, 2015,
the NRC notified the licensee that a plant design change, which was implemented in
1999, had increased the probability of a loss-of-feedwater accident by more than a
minimal amount and was made without requesting prior NRC approval, was a violation
of 10 CFR 50.59 requirements. Title 10 CFR 50, Appendix B, Criterion XVI, requires in
part that, measures shall be established to assure that conditions adverse to quality,
such as failures, malfunctions, deficiencies, deviations, defective material and
equipment, and nonconformances are promptly identified and corrected. As of April 28,
2017, the licensee failed to correct a condition adverse to quality by restoring
compliance with 10 CFR 50.59.
12
The finding was more than minor because it is associated with the initiating events
aspect of the reactor safety cornerstone and affected the cornerstone objective to limit
the likelihood of events that upset plant stability and challenge critical safety functions
during power operations. Using Inspection Manual Chapter 0609, Appendix A, The
Significance Determination Process (SDP) for Findings At-Power, Exhibit 1, Initiating
Events Screening Questions, dated June 19, 2012, the team determined that the
finding is of very low safety significance (Green). This was because the finding did not
cause a reactor trip and the loss of mitigation equipment relied upon to transition the
plant from the onset of the trip to a stable shutdown condition. The finding has a
human performance cross-cutting aspect associated with procedural adherence
because individuals failed to follow the procedures delineated by the corrective action
program [H.8].
The reactor oversight process (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 deter non-compliance. Since
the violation is associated with a Green reactor oversight process violation, the
traditional enforcement violation was determined to be a Severity Level IV violation,
consistent with the example in paragraph 6.1.d(2) of the NRC Enforcement Policy.
The NRCs Enforcement Policy dictates that severity level IV violations and violations
associated with green ROP findings are normally dispositioned as NCVs if they meet all
of the following: (1) the violation is placed into a corrective action program to restore
compliance and address recurrence; (2) the licensee must restore compliance within a
reasonable period of time (commensurate with the significance); (3) the violation must
either not be repetitive as a result of inadequate corrective action, or if repetitive, the
repetitive violation must not have been identified by the NRC (does not apply to green
ROP findings); and (4) the violation must not be willful. For the purposes of Criterion 2,
this includes actions taken to stop an ongoing violation from continuing (which should be
as soon as possible). The team concluded that while the licensee originally met the
criteria for dispositioning the issue 10 CFR 50.59 as a NCV; based upon the fact that the
licensee closed the condition report without restoring compliance, the licensee no longer
met the criteria for a NCV, and therefore, this violation will be cited in a notice of
violation.
Enforcement. The team identified a Severity Level IV, Green violation of 10 CFR 50.59,
Changes, Tests, and Experiments, Section (c)(2) which states in part that, a licensee
shall obtain a license amendment pursuant to Section 50.90 prior to implementing a
proposed change, test, or experiment if the change, test, or experiment would result in
more than a minimal increase in the frequency of occurrence of an accident previously
evaluated in the final safety analysis report (as updated). Contrary to the above, as of
April 28, 2017, the licensee failed to obtain a license amendment pursuant to
Section 50.90, prior to implementing a change, test, or experiment that resulted in a
more than minimal increase in the frequency of occurrence of an accident previously
evaluated in the final safety analysis report (as updated). Specifically, on July 3, 1999,
the licensee implemented a design change to the reactor core isolation cooling injection
location from the reactor vessel head to a feedwater line. However, the licensee failed
to correctly evaluate that a spurious reactor core isolation cooling actuation into the
feedwater line resulted in a more than minimal increase in the frequency of occurrence
13
of the loss of feedwater heating accident, previously evaluated in the updated final safety
analysis report. This performance deficiency was previously identified by the NRC and
documented as NCV 05000458/2015007-02. In accordance with Section 2.3.2.a of the
NRC Enforcement Policy, this finding is being cited because the licensee failed to
restore compliance within a reasonable amount of time after the violation was initially
identified. This finding was entered into the licensees corrective action program as
Condition Report CR-RBS-2017-03505, (VIO 05000458/2017009-01, Failure to Obtain
Prior NRC Approval for a Change in Reactor Core Isolation Cooling Injection Point.)
4OA6 Meetings, Including Exit
Exit Meeting Summary
On April 28, 2017, the inspectors presented the inspection results to Mr. Marvin Chase, Director,
Regulatory & Performance Improvement, and other members of the licensee staff. The licensee
acknowledged the issues presented. The licensee confirmed that any proprietary information
reviewed by the inspectors had been returned or destroyed.
14
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
M. Chase, Director, Regulatory & Performance Improvement
A. Coates, Sr. Engineer, Regulatory Assurance
R. Crawford, Supervisor, Engineering
K. Huffstatler, Sr. Licensing Specialist, Regulatory Assurance
J. Lea, HVK System Engineer
P. Lucky, Manager, Performance Improvement
B. Maguire, Vice President, Operations
J. Reynolds, Sr. Manager, Operations
T. Schenk, Manager, Regulatory Assurance
K. Stupak, Manager, Training
T. Trask, Director, Recovery
S. Vazquez, Director, Engineering
NRC Personnel
J. Sowa, Senior Resident, River Bend Station
A. Vegel, Director, Division of Reactor Safety
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
Failure to Obtain Prior NRC Approval for a Change in Reactor
05000458/2017-009-01 NOV
Core Isolation Cooling Injection Point (Section 4OA2.5)
Discussed
Failure to Obtain Prior NRC Approval for a Change in Reactor
05000458/2015-007-02 NCV
Core Isolation Cooling Injection Point
LIST OF DOCUMENTS REVIEWED
Procedures
Number Title Revision
ADM-0073 Temporary Services and Equipment 307
AOP-0029 Severe Weather Operation 38
CSP-0006 Chemistry Surveillance and Scheduling System 41
Attachment 1
Procedures
Number Title Revision
CSP-0109 Chemistry Surveillance for Non-Routing Samples 0
EN-LI-102 Corrective Action Program 24
EN-LI-102 Corrective Action Program 25
EN-LI-102 Corrective Action Program 26
EN-LI-102 Corrective Action Program 27
EN-LI-102 Corrective Action Program 28
EN-LI-102 Corrective Action Program 29
EN-LI-104 Self-Assessment and Benchmark Process 13
EN-LI-118 Cause Evaluation Process 21
EN-LI-118 Cause Evaluation Process 22
EN-LI-118 Cause Evaluation Process 23
EN-LI-118 Cause Evaluation Process 24
EN-LI-121 Trending and Performance Review Process 18
EN-LI-121 Trending and Performance Review Process 19
EN-LI-121 Trending and Performance Review Process 20
EN-LI-121 Trending and Performance Review Process 21
EN-LI-121 Trending and Performance Review Process 22
EN-OE-100 Operating Experience Program 27
EN-OP-104 Operability Determination Process 11
EN-QV-109 Audit Process 32
EN-RP-110-004 Radiation Protection Risk Assessment Process 7
EN-TQ-201 Systematic Approach to Training Process 22
GOP-001 Plant Startup 84
GOP-001 Plant Startup 85
GOP-001 Plant Startup 97
GOP-002 Power Decrease/Plant Shutdown 70
GOP-002 Power Decrease/Plant Shutdown 71
GOP-002 Power Decrease/Plant Shutdown 72
GOP-002 Power Decrease/Plant Shutdown 77
GOP-005 Power Maneuvering 321
A1-2
Procedures
Number Title Revision
GOP-005 Power Maneuvering 322
GOP-005 Power Maneuvering 323
GOP-005 Power Maneuvering 328
OSP-0014 Administrative control of Equipment and/or Devices 306
OSP-0022 Operations General Administration Guidelines 103
OSP-0043 Freeze Protection and Temperature Maintenance 30
SOP-0093 Condensate Demineralizer System 40
STP-000-0201 Monthly Operating Log 310
STP-000-0201 Monthly Operating Log 311
STP-251-3700 Fire System Yard Water Loop Flow Test 10
STP-251-3700 Fire System Yard Water Loop Flow Test 11
Other Documents Title Revision/Date
EC-000001578 B33-MOV067 A/B Stem to Upper Wedge Torque Value 0
Evaluation of the Shear Capability of the Wedge Pin for
Double Disc Gate Valves B-33-MOVF023 A/B
QA-9-2016- March 24,
Fire Protection Audit
RBS-1 2016
QA-14/15-2015- October 19,
Radiation Protection / Radwaste Audit
RBS-1 2015
RLO-2016-00049 Special Nuclear Material Pre-NRC Assessment July 2, 2016
Pre-NRC Radiological Hazard Assessment and Exposure January 17,
RLO-2016-00145
Control Performance Indicator Verification 2017
Corrective Action Documents
Condition Reports
CR-RBS-1994-00830 CR-RBS-2013-2054 CR-RBS-2013-04083 CR-RBS-2013-05180
CR-RBS-2013-07316 CR-RBS-2014-00321 CR-RBS-2014-00711 CR-RBS-2014-03089
CR-RBS-2014-03150 CR-RBS-2014-03408 CR-RBS-2014-03413 CR-RBS-2014-04049
CR-RBS-2014-04802 CR-RBS-2014-05022 CR-RBS-2014-05209 CR-RBS-2014-06233
CR-RBS-2014-06284 CR-RBS-2014-06357 CR-RBS-2014-06581 CR-RBS-2015-00153
CR-RBS-2015-00626 CR-RBS-2015-01783 CR-RBS-2015-02245 CR-RBS-2015-02354
A1-3
Condition Reports
CR-RBS-2015-02668 CR-RBS-2015-02855 CR-RBS-2015-03360 CR-RBS-2015-03373
CR-RBS-2015-03374 CR-RBS-2015-03437 CR-RBS-2015-03622 CR-RBS-2015-03829
CR-RBS-2015-03877 CR-RBS-2015-03951 CR-RBS-2015-03952 CR-RBS-2015-03974
CR-RBS-2015-04071 CR-RBS-2015-04259 CR-RBS-2015-04265 CR-RBS-2015-04298
CR-RBS-2015-04375 CR-RBS-2015-04413 CR-RBS-2015-04725 CR-RBS-2015-04790
CR-RBS-2015-04791 CR-RBS-2015-04794 CR-RBS-2015-04818 CR-RBS-2015-04937
CR-RBS-2015-05008 CR-RBS-2015-05038 CR-RBS-2015-05306 CR-RBS-2015-05469
CR-RBS-2015-05473 CR-RBS-2015-05474 CR-RBS-2015-05530 CR-RBS-2015-05549
CR-RBS-2015-05601 CR-RBS-2015-05644 CR-RBS-2015-06164 CR-RBS-2015-06369
CR-RBS-2015-06370 CR-RBS-2015-06371 CR-RBS-2015-06704 CR-RBS-2015-06891
CR-RBS-2015-06943 CR-RBS-2015-06952 CR-RBS-2015-06961 CR-RBS-2015-07011
CR-RBS-2015-07012 CR-RBS-2015-07013 CR-RBS-2015-07028 CR-RBS-2015-07142
CR-RBS-2015-07147 CR-RBS-2015-07259 CR-RBS-2015-07264 CR-RBS-2015-07331
CR-RBS-2015-07399 CR-RBS-2015-07532 CR-RBS-2015-07838 CR-RBS-2015-08332
CR-RBS-2015-08463 CR-RBS-2015-08508 CR-RBS-2015-08831 CR-RBS-2015-08892
CR-RBS-2015-08992 CR-RBS-2015-09052 CR-RBS-2016-00033 CR-RBS-2016-00095
CR-RBS-2016-00134 CR-RBS-2016-00150 CR-RBS-2016-00180 CR-RBS-2016-00210
CR-RBS-2016-00211 CR-RBS-2016-00251 CR-RBS-2016-00294 CR-RBS-2016-00310
CR-RBS-2016-00370 CR-RBS-2017-00513 CR-RBS-2016-00573 CR-RBS-2016-00608
CR-RBS-2016-00765 CR-RBS-2016-00887 CR-RBS-2016-00890 CR-RBS-2016-00893
CR-RBS-2016-01027 CR-RBS-2016-01031 CR-RBS-2016-01069 CR-RBS-2016-01152
CR-RBS-2016-01157 CR-RBS-2016-01226 CR-RBS-2016-01232 CR-RBS-2016-01971
CR-RBS-2016-02178 CR-RBS-2016-02200 CR-RBS-2016-02335 CR-RBS-2016-02355
CR-RBS-2016-02392 CR-RBS-2016-02398 CR-RBS-2016-02632 CR-RBS-2016-02645
CR-RBS-2016-02811 CR-RBS-2016-02813 CR-RBS-2016-02953 CR-RBS-2016-03152
CR-RBS-2016-03177 CR-RBS-2016-03212 CR-RBS-2016-03264 CR-RBS-2016-03344
CR-RBS-2016-03375 CR-RBS-2016-03533 CR-RBS-2016-03580 CR-RBS-2016-04010
CR-RBS-2016-04092 CR-RBS-2016-04095 CR-RBS-2016-04368 CR-RBS-2016-04385
CR-RBS-2016-04886 CR-RBS-2016-05016 CR-RBS-2016-05263 CR-RBS-2016-05478
CR-RBS-2016-05490 CR-RBS-2016-05539 CR-RBS-2016-05596 CR-RBS-2016-05600
CR-RBS-2016-05866 CR-RBS-2016-06055 CR-RBS-2016-06103 CR-RBS-2016-06108
CR-RBS-2016-06296 CR-RBS-2016-06393 CR-RBS-2016-06564 CR-RBS-2016-06619
CR-RBS-2016-06652 CR-RBS-2016-06694 CR-RBS-2016-06701 CR-RBS-2016-06807
CR-RBS-2016-06808 CR-RBS-2016-06809 CR-RBS-2016-06879 CR-RBS-2016-06880
CR-RBS-2016-06926 CR-RBS-2016-07098 CR-RBS-2016-07298 CR-RBS-2016-07753
A1-4
Condition Reports
CR-RBS-2016-07796 CR-RBS-2016-08195 CR-RBS-2016-08577 CR-RBS-2017-00781
CR-RBS-2017-00836 CR-RBS-2017-00996 CR-RBS-2017-01658 CR-RBS-2017-02075
CR-RBS-2017-02113 CR-RBS-2017-02291 CR-RBS-2017-02314 CR-RBS-2017-02395
CR-RBS-2017-02403 CR-RBS-2017-02405 CR-RBS-2017-02529 CR-RBS-2017-02579
CR-RBS-2017-02828 CR-RBS-2017-02865 CR-RBS-2017-03549 CR-HQN-2017- 0617
Work Orders
174865 174866 316468 346576 346577 350485
419997 419999 438116
A1-5
Info Request
Biennial Problem Identification and Resolution
Inspection River Bend Station
January 23, 2017
Inspection Report: 50-458/2017009
On-site Inspection Dates: April 10-14 & 24-28, 2017
This inspection will cover the period from July 12, 2013, through April 28, 2017. All requested
information is limited to this period or to the date of this request unless otherwise specified. To
the extent possible, the requested information should be provided electronically in word-
searchable Adobe PDF (preferred) or Microsoft Office format. Any sensitive information
should be provided in hard copy during the teams first week on site; do not provide any
sensitive or proprietary information electronically.
Lists of documents (summary lists) should be provided in Microsoft Excel or a similar sortable
format. Please be prepared to provide any significant updates to this information during the
teams first week of on-site inspection. As used in this request, corrective action documents
refers to condition reports, notifications, action requests, cause evaluations, and/or other
similar documents, as applicable to the River Bend Station.
Please provide the following information no later than March 20, 2017:
1. Document Lists
Note: For these summary lists, please include the document/reference number, the
document title, initiation date, current status, and long-text description of the issue.
a. Summary list of all corrective action documents related to significant
conditions adverse to quality that were opened, closed, or evaluated during
the period
b. Summary list of all corrective action documents related to conditions adverse
to quality that were opened or closed during the period
c. Summary lists of all corrective action documents that were upgraded or
downgraded in priority/significance during the period (these may be limited
to those downgraded from, or upgraded to, apparent-cause level or higher)
d. Summary list of all corrective action documents initiated during the period
that roll up multiple similar or related issues, or that identify a trend
e. Summary lists of operator workarounds, operator burdens, temporary
modifications, and control room deficiencies (1) currently open and (2) that
were evaluated and/or closed during the period
f. Summary list of safety system deficiencies that required prompt
operability determinations (or other engineering evaluations) to provide
reasonable assurance of operability
Attachment 2
g. Summary list of plant safety issues raised or addressed by the Employee
Concerns Program (or equivalent) (sensitive information should be made
available during the teams first week on sitedo not provide
electronically)
h. Summary list of all Apparent Cause Evaluations completed during the
period
2. Full Documents with Attachments
a. Root Cause Evaluations completed during the period; include a list of
any planned or in progress
b. Quality Assurance audits performed during the period
c. Audits/surveillances performed during the period on the Corrective
Action Program, of individual corrective actions, or of cause
evaluations
d. Functional area self-assessments and non-NRC third-party assessments (e.g.,
peer assessments performed as part of routine or focused station self- and
independent assessment activities; do not include INPO assessments) that
were performed or completed during the period; include a list of those that are
currently in progress
e. Any assessments of the safety-conscious work environment at the River
Bend Station
f. Corrective action documents generated during the period associated with
the following:
i. NRC findings and/or violations issued to the River Bend Station
ii. Licensee Event Reports issued by the River Bend Station
g. Corrective action documents generated for the following, if they were
determined to be applicable to the River Bend Station (for those that were
evaluated but determined not to be applicable, provide a summary list):
i. NRC Information Notices, Bulletins, and Generic Letters
issued or evaluated during the period
ii. Part 21 reports issued or evaluated during the period
iii. Vendor safety information letters (or equivalent) issued or
evaluated during the period
iv. Other external events and/or Operating Experience evaluated
for applicability during the period
h. Corrective action documents generated for the following:
A2-2
i. Emergency planning drills and tabletop exercises performed during
the period
ii. Maintenance preventable functional failures which occurred or
were evaluated during the period
iii. Adverse trends in equipment, processes, procedures, or
programs that were evaluated during the period
iv. Action items generated or addressed by offsite review committees
during the period
3. Logs and Reports
a. Corrective action performance trending/tracking information generated during
the period and broken down by functional organization (if this information is
fully included in item 3.c, it need not be provided separately)
b. Corrective action effectiveness review reports generated during the period
c. Current system health reports, Management Review Meeting package, or
similar information; provide past reports as necessary to include 12 months of
metric/trending data
d. Radiation protection event logs during the period
e. Security event logs and security incidents during the period (sensitive
information should be made available during the teams first week on sitedo
not provide electronically)
f. Employee Concern Program (or equivalent) logs (sensitive information should
be made available during the teams first week on sitedo not provide
electronically)
g. List of training deficiencies, requests for training improvements, and
simulator deficiencies for the period
Note: For items 3.d-3.g, if there is no log or report maintained separate from the
corrective action program, please provide a summary list of corrective action
program items for the category described.
4. Procedures
Note: For these procedures, please include all revisions that were in effect at any time
during the period.
a. Corrective action program procedures, to include initiation and evaluation
procedures, operability determination procedures, apparent and root cause
evaluation/determination procedures, and any other procedures that
implement the corrective action program at the River Bend Station
A2-3
b. Quality Assurance program procedures (specific audit procedures are
not necessary)
c. Employee Concerns Program (or equivalent) procedures
d. Procedures which implement/maintain a Safety Conscious Work Environment
5. Other
a. List of risk-significant components and systems, ranked by risk worth
b. Organization charts for plant staff and long-term/permanent contractors
c. Electronic copies of the UFSAR (or equivalent), technical specifications,
and technical specification bases, if available
d. Table showing the number of corrective action documents (or equivalent)
initiated during each month of the inspection period, by screened
significance
e. For each day the team is on site,
i. Planned work/maintenance schedule for the station
ii. Schedule of management or corrective action review meetings (e.g.,
operations focus meetings, condition report screening meetings,
CARBs, MRMs, challenge meetings for cause evaluations, etc.)
iii. Agendas for these meetings
Note: The items listed in 5.d may be provided on a weekly or daily basis after
the team arrives on site.
All requested documents should be provided electronically where possible. Regardless of
whether they are uploaded to an internet-based file library (e.g., Certrecs IMS), please provide
copies on CD or DVD. One copy of the CD or DVD should be provided to the resident
inspector office at the River Bend Station; three additional copies should be provided to the
team lead, to arrive no later than March 20, 2017:
U.S. NRC Senior Reactor Inspector
Division of Reactor Safety, Region IV
1600 E. Lamar Blvd, Arlington, TX 76011
Office: (817) 200-1445
Cell: (817) 319-4376
A2-4
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword: NRC-002
By: RVA Yes No Publicly Available Sensitive
OFFICE SRI:DRS/IPAT SRI:DRS/IPAT PE:DRS/IP RI:DRP/PBC C:DRS/IPAT C:DRP/PBC
AT
NAME RAzua HFreeman PJayroe BParks THipschman JKozal
DATE 05/10/2017 05/22/2017 05/15/2017 05/23/2017 05/23/2017 06/08/2017
OFFICE SEP:ORA/ACES C:DRS/IPAT
NAME JKramer THipschman
SIGNATURE /RA/ /RA/JClark for
DATE 06/02/2017 06/09/2017