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{{Adams
#REDIRECT [[IR 05000458/2011006]]
| number = ML112430218
| issue date = 08/31/2011
| title = Redacted Version of Non-concurrence - River Bend Station - NRC Problem Identification and Resolution Inspection Report 05000458/2011006
| author name = Barrett A J
| author affiliation = NRC/RGN-IV
| addressee name =
| addressee affiliation =
| docket = 05000458
| license number =
| contact person =
| document report number = IR-11-006
| document type = Non-Concurrence Process
| page count = 5
}}
See also: [[followed by::IR 05000458/2011006]]
 
=Text=
{{#Wiki_filter:NON-CONCURRENCE PACKAGE RIVER BEND STATION -NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000458/2011006 August 31,2011 This NCP document is a redacted version to protect personal privacy within the deliberative process. NON-CONCURRENCE PACKAGE RIVER BEND STATION -NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000458/2011006 August 31,2011 This NCP document is a redacted version to protect personal privacy within the deliberative proces NRC FORM 757 U.S. NUCLEAR REGULATORY COMMISSION NRCMD101SC NON-CONC SECTION A -TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL -.. _--_... ... --------_. TlTLE OF DOCUMENT -)'lRC Pi&RREPORT 05000458/2011006 ACCESSION .. I ___ .. __ _ J I I"MUI'lt: I uv ...... UtV!r.::I'II I ..;>rV!'1,,::H . .Jr\ Michael Hay, Chief, TSB DRS I 817-276-6527 ., fJo. Andrew J. Barrett 225-635-3193 I ______________ . __________ ... ________ ..* ....l ____ * _____ ,---___ . 1-1 DOCUMENTAUTHOR TITLE !;l] DOCUMENT CONTRIBUTOR o DOCUMENT REVIEWER o ON CONCURRENCE Resident Inspector -River Bend Station ---'--... ... ---_ .... iORGANIZATION ---... -.. ------... ___ ,-I iV, of ____ _ FOR During the Biennial Problem Identification and Resolution inspection at River Bend Station, we identified that the licensee had found door sealing deficiencies in the control room envelope. The deficiencies were identified in consecutive performances of the surveillance procedure "Control Room Habitability Assessment," which is performed on an 18 month frequency. The surveillance test procedure satisfies the technical specification 5.5.14 requirements Iu lIluinlain the CRE Iboundary in its design condition including configuration control and preventive maintenance. During the performance orthe surveillance in 2008, the licensee documented the following deficiencies for doors cn 116-22 and CB 116-23: "Air Leaks Auj Iweather strip CR-RBS-2008-0531I WR-J 39913 WR 139914," During the second performance of the lest (note, assessment procedure performed by a different engineer) in 2010, the licensee documented the following deficiency for door cn 116-22: I "Gap is even, air leaks around door, but is negligible. Wrote CR-RBS-2010-1 148." The work requests and condition report documented in 2008 were closed to a work order, This work order was given a priority of 5 (the lowest priority level) and left unplanned. In 2010, CR-RBS-2010-1148 was closed to the same work order. The inspectors found that over one year later, the work order had yet to be planned, and the issue with the door seals on CB-116-22 had not been fully evaluated. To this day, the licensee has not fully evaluated or addressed the door sealing deficiency. NEI 99-03, "Control Room Habitability Assessment," contains the NRC endorsed standards for evaluating deficiencies in control room envelopes to meet the recommendations of Regulatory Guide 1.197. The following information provided in the appendices of NEI 99-03 detail the standards for detecting deficiencies in the control room envelope: Appendix H. System Assessment 3.4.4 (page H-7) Doors in Contra! Room Boundary Door Seals can be a potentiul significant source of in-leakage. Experience has indicated that the door to door frame (sides and top of door) and the noor (bottom of door) can be significant leak locations. The inspection should ensure not only the integrity of the seals, but verify that the door is properly compressing the seals. Table H-! Determination of Vulnerability Susceptibl!ity System Component Envelope Doors Determining lnleakage Vulnerabilities I). Determine that there are no in the doors. Use ADAMS Template NRC-006 ';jj CONTINUED IN SECTION D PRINTED 0'1 RECYCL::D PAPER NRC FORM 757 U.S. NUCLEAR REGULATORY COMMISSION NRCMD101SC NON-CONC SECTION A -TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL -.. _--_... ... --------_. TlTLE OF DOCUMENT -)'lRC Pi&RREPORT 05000458/2011006 ACCESSION .. I ___ .. __ _ J I I"MUI'lt: I uv ...... UtV!r.::I'II I ..;>rV!'1,,::H . .Jr\ Michael Hay, Chief, TSB DRS I 817-276-6527 ., fJo. Andrew J. Barrett 225-635-3193 I ______________ . __________ ... ________ ..* ....l ____ * _____ ,---___ . 1-1 DOCUMENTAUTHOR TITLE !;l] DOCUMENT CONTRIBUTOR o DOCUMENT REVIEWER o ON CONCURRENCE Resident Inspector -River Bend Station ---'--... ... ---_ .... iORGANIZATION ---... -.. ------... ___ ,-I iV, of ____ _ FOR During the Biennial Problem Identification and Resolution inspection at River Bend Station, we identified that the licensee had found door sealing deficiencies in the control room envelope. The deficiencies were identified in consecutive performances of the surveillance procedure "Control Room Habitability Assessment," which is performed on an 18 month frequency. The surveillance test procedure satisfies the technical specification 5.5.14 requirements Iu lIluinlain the CRE Iboundary in its design condition including configuration control and preventive maintenance. During the performance orthe surveillance in 2008, the licensee documented the following deficiencies for doors cn 116-22 and CB 116-23: "Air Leaks Auj Iweather strip CR-RBS-2008-0531I WR-J 39913 WR 139914," During the second performance of the lest (note, assessment procedure performed by a different engineer) in 2010, the licensee documented the following deficiency for door cn 116-22: I "Gap is even, air leaks around door, but is negligible. Wrote CR-RBS-2010-1 148." The work requests and condition report documented in 2008 were closed to a work order, This work order was given a priority of 5 (the lowest priority level) and left unplanned. In 2010, CR-RBS-2010-1148 was closed to the same work order. The inspectors found that over one year later, the work order had yet to be planned, and the issue with the door seals on CB-116-22 had not been fully evaluated. To this day, the licensee has not fully evaluated or addressed the door sealing deficiency. NEI 99-03, "Control Room Habitability Assessment," contains the NRC endorsed standards for evaluating deficiencies in control room envelopes to meet the recommendations of Regulatory Guide 1.197. The following information provided in the appendices of NEI 99-03 detail the standards for detecting deficiencies in the control room envelope: Appendix H. System Assessment 3.4.4 (page H-7) Doors in Contra! Room Boundary Door Seals can be a potentiul significant source of in-leakage. Experience has indicated that the door to door frame (sides and top of door) and the noor (bottom of door) can be significant leak locations. The inspection should ensure not only the integrity of the seals, but verify that the door is properly compressing the seals. Table H-! Determination of Vulnerability Susceptibl!ity System Component Envelope Doors Determining lnleakage Vulnerabilities I). Determine that there are no in the doors. Use ADAMS Template NRC-006 ';jj CONTINUED IN SECTION D PRINTED 0'1 RECYCL::D PAPER NRC FORM 757 U,S. NUCLEAR REGULATORY COMMISSION NRC MO 10.1se PROCESS OF DOCUMENT iA.DAMSACCESSION NO. BEND ST A nON -NRC PI&R REPORT 05000458/2011 : N/A I I B -TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL'S SUPERVISOR I (THIS SECTION SHOULD ONLY BE THAN __ Vince Gaddy fIT-L-E-"-" .---------.------.-I PHONE NO. Branch Chief I 817-860-8144 ORGANllATION---*----------------------------'---** -----Plant Branch C. Division of Reactor Proiects --_._------_. --'---"------------.. -----------1 COMMENTS FOR THE DOCUMENT SPONSOR TO CONSIDER ,......"., rJ I HAVE NO COMMENTS LJ I HAVE THE FOLLOWING COMMENTS ---------------i CONTiNUED iN SECTION 0 PRINTED ON RECYCLED PAPER NRC FORM 757 U,S. NUCLEAR REGULATORY COMMISSION NRC MO 10.1se PROCESS OF DOCUMENT iA.DAMSACCESSION NO. BEND ST A nON -NRC PI&R REPORT 05000458/2011 : N/A I I B -TO BE COMPLETED BY NON-CONCURRING INDIVIDUAL'S SUPERVISOR I (THIS SECTION SHOULD ONLY BE THAN __ Vince Gaddy fIT-L-E-"-" .---------.------.-I PHONE NO. Branch Chief I 817-860-8144 ORGANllATION---*----------------------------'---** -----Plant Branch C. Division of Reactor Proiects --_._------_. --'---"------------.. -----------1 COMMENTS FOR THE DOCUMENT SPONSOR TO CONSIDER ,......"., rJ I HAVE NO COMMENTS LJ I HAVE THE FOLLOWING COMMENTS ---------------i CONTiNUED iN SECTION 0 PRINTED ON RECYCLED PAPER NRC FORM 757 NRC MD 10 (3-2009) U.S. NUCLEAR REGULATORY COMMISSION I NON-CONCURRENCE PROCESS I TITLE OF DOCUMENT ... ?TAT10N -NRC Pl&R SECTION 0: CONTINUATION PAGE OF bll A 05000458120 Ii 006 :.---------------. nB L, ----------.'-' [J c I,ADAMS ,!.,CCESSION NO. i .. 1 .... -. __ . _________ --1 t). D,,,,ml,, th" Ih' dooc "", (Ineludlog "'''p') '" 0" ""k,d, '" oot missing "d hon pcop,'OI. 3). Determine that doors are properly compressed or fitting against the door seals. 4). Determine that door latches are functioning properly to maintain the door securely closed. 5). Determine that door frames are properly sealed. Appendix J. Control Room Envelope Sealing Program 3.1 Doors and Door Seals The deDI' should fit properly in the frame, with hinges securely attached. Door sweep should be in continuous contact with the Iloor or threshold for the entire width of the door. The gasket or seal should be an approved type, be [rce of cracks and shuuld form ;j contact seal 3round the entire perimeter uf the dour. The door nlld frnme should be free of breaks or open Conclusion: IhOles, With IThe nonconcurring inspector contends that an additional observation should be included in the report under Section 3, IAssessment. Effectiveness of Corrective Action Program documenting the untimely actions to fully address a deficient condition that could potentially impact tile integrity of the con[rol room envelope:. This is reinforced by the failure to ensure that the control room envelope was maintained to the standards as presented in NEI-99-03 .. NkC FORM "lS7 Use ADAMS Template NRC-OOo PRrr[fED ON PEGYCLED Pf.PER NRC FORM 757 NRC MD 10 (3-2009) U.S. NUCLEAR REGULATORY COMMISSION I NON-CONCURRENCE PROCESS I TITLE OF DOCUMENT ... ?TAT10N -NRC Pl&R SECTION 0: CONTINUATION PAGE OF bll A 05000458120 Ii 006 :.---------------. nB L, ----------.'-' [J c I,ADAMS ,!.,CCESSION NO. i .. 1 .... -. __ . _________ --1 t). D,,,,ml,, th" Ih' dooc "", (Ineludlog "'''p') '" 0" ""k,d, '" oot missing "d hon pcop,'OI. 3). Determine that doors are properly compressed or fitting against the door seals. 4). Determine that door latches are functioning properly to maintain the door securely closed. 5). Determine that door frames are properly sealed. Appendix J. Control Room Envelope Sealing Program 3.1 Doors and Door Seals The deDI' should fit properly in the frame, with hinges securely attached. Door sweep should be in continuous contact with the Iloor or threshold for the entire width of the door. The gasket or seal should be an approved type, be [rce of cracks and shuuld form ;j contact seal 3round the entire perimeter uf the dour. The door nlld frnme should be free of breaks or open Conclusion: IhOles, With IThe nonconcurring inspector contends that an additional observation should be included in the report under Section 3, IAssessment. Effectiveness of Corrective Action Program documenting the untimely actions to fully address a deficient condition that could potentially impact tile integrity of the con[rol room envelope:. This is reinforced by the failure to ensure that the control room envelope was maintained to the standards as presented in NEI-99-03 .. NkC FORM "lS7 Use ADAMS Template NRC-OOo PRrr[fED ON PEGYCLED Pf.PER NRC Y-ORM 757 NRC M[;J 10 ';::,R (3*2009) TITLE OF DOCUMENT NON-CONCURRENCE PROC River Bend Station -NRC PI&R REPORT 05000458/2011006 .--I?ECTION C -TO BE COMPLETED BY DOCUMENT SPONSOR NAME Michael TITLE Branch Chief ORGANIZATION Project Support Branch 1, Division of Reactor Safety u.s. NUCLEAR REGULATORY COMMISSiON ADAMS ACCESSION NO. PHONE NO. 8! 7-276-6527 ACTIONS TAKEN TO ADDRESS NON-CONCURRENCE (This section should be revised, as necessary, to reflect the final outcome of the non-concurrence process, including a complete discussion of how individual concerns were addressed.) Multiple meetings were conducted with myself, Andy Barrett, Harold Walker, and Bob Hagar to discuss the issue. Bob Hagar was the team lead for the PIR inspection, and Harold Walker, a technical expert in NRRJDivision of Safety Systems/Containment and Ventilation Branch provided technical support. These discussions focused on assessing the adequacy of the licensee's actions following their identi!1cation of control room envelope (eRE) door seals that had leakage. Based on our discussions I was not able to conclude that the licensee 'was inappropriately handling the issue or that a f safety concern existed. The licensee had evaluated the door sealleabge as "negligible," thereby implying that this condition was not a condition adverse to quality requiring prompt corrective actions. eRE leakage surveillance test results in 2008 and 2010 indicated that the overall leakage of the CRE was less than 4 percent of the allowable leakage. In addition, the I surveillance results in 2010 showed no decrease in safety margin, in fact the test results showed slightly better results. I agree the licensee could have handled the issue better. Their evaluation of door leakage could have been more thorough, the work requests could of been prioritized higher and performed sooner, or they could of concluded based on the negligible leakage no actions were currently needed. CONTINUED IN SECTION D -D#CUMENT SPONSOR 0(. fA r INON-CONCURRING (To be completed by document sponsorwh_n process is, mp!ete. ie., after documem CONCURS 'WANTS NCP FORM PUBLIC )t NON-CONCURS WANTS NCP FORM WITHDRAWS NOhi-COI\lCURRENCE (Ie., discontinues process) NRC FORM 757 13*2009) Use ADAMS Template NRC-006 PRINTED UN RECYCLED PAPER NRC Y-ORM 757 NRC M[;J 10 ';::,R (3*2009) TITLE OF DOCUMENT NON-CONCURRENCE PROC River Bend Station -NRC PI&R REPORT 05000458/2011006 .--I?ECTION C -TO BE COMPLETED BY DOCUMENT SPONSOR NAME Michael TITLE Branch Chief ORGANIZATION Project Support Branch 1, Division of Reactor Safety u.s. NUCLEAR REGULATORY COMMISSiON ADAMS ACCESSION NO. PHONE NO. 8! 7-276-6527 ACTIONS TAKEN TO ADDRESS NON-CONCURRENCE (This section should be revised, as necessary, to reflect the final outcome of the non-concurrence process, including a complete discussion of how individual concerns were addressed.) Multiple meetings were conducted with myself, Andy Barrett, Harold Walker, and Bob Hagar to discuss the issue. Bob Hagar was the team lead for the PIR inspection, and Harold Walker, a technical expert in NRRJDivision of Safety Systems/Containment and Ventilation Branch provided technical support. These discussions focused on assessing the adequacy of the licensee's actions following their identi!1cation of control room envelope (eRE) door seals that had leakage. Based on our discussions I was not able to conclude that the licensee 'was inappropriately handling the issue or that a f safety concern existed. The licensee had evaluated the door sealleabge as "negligible," thereby implying that this condition was not a condition adverse to quality requiring prompt corrective actions. eRE leakage surveillance test results in 2008 and 2010 indicated that the overall leakage of the CRE was less than 4 percent of the allowable leakage. In addition, the I surveillance results in 2010 showed no decrease in safety margin, in fact the test results showed slightly better results. I agree the licensee could have handled the issue better. Their evaluation of door leakage could have been more thorough, the work requests could of been prioritized higher and performed sooner, or they could of concluded based on the negligible leakage no actions were currently needed. CONTINUED IN SECTION D -D#CUMENT SPONSOR 0(. fA r INON-CONCURRING (To be completed by document sponsorwh_n process is, mp!ete. ie., after documem CONCURS 'WANTS NCP FORM PUBLIC )t NON-CONCURS WANTS NCP FORM WITHDRAWS NOhi-COI\lCURRENCE (Ie., discontinues process) NRC FORM 757 13*2009) Use ADAMS Template NRC-006 PRINTED UN RECYCLED PAPER
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