IR 05000458/2006003

Errata for River Bend Station - NRC Integrated Inspection Report 05000458-06-003

ML062560077
Person / Time
Site:	River Bend
Issue date:	09/12/2006
From:	Kennedy K NRC/RGN-IV/DRP/RPB-C
To:	Hinnenkamp P Entergy Operations
References
IR-06-003
Download: ML062560077 (10)

Text

September 12, 2006Paul D. HinnenkampVice President - Operations Entergy Operations, Inc.

River Bend Station 5485 US Highway 61N St. Francisville, LA 70775SUBJECT:ERRATA FOR RIVER BEND STATION - NRC INTEGRATED INSPECTIONREPORT 05000458/2006003

Dear Mr. Hinnenkamp:

Please remove pages 22 to 27 from NRC Integrated Inspection Report 05000458/2006003 andreplace with the pages enclosed with this letter. The purpose of the change is to correct an error made in the analysis section of Section 1R22.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure will be made available electronically for public inspection in the NRC PublicDocument Room or from the Publicly Available Records (PARS) component of NRC'sdocument system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).Should you have any questions concerning this inspection, we will be pleased to discuss themwith you.

Sincerely,

/RA/ Russell L. Bywater acting forKriss M. Kennedy, ChiefProject Branch C Division of Reactor ProjectsDocket: 50-458License: NPF-47Enclosure: Replacement pages to NRC Inspection Report 05000458/2006003 Entergy Operations, Inc.- 2 -cc w/enclosure:Senior Vice President and Chief Operating Officer Entergy Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995Vice President Operations Support Entergy Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995General ManagerPlant Operations Entergy Operations, Inc.

River Bend Station 5485 US Highway 61N St. Francisville, LA 70775Director - Nuclear SafetyEntergy Operations, Inc.

River Bend Station 5485 US Highway 61N St. Francisville, LA 70775Wise, Carter, Child & Caraway P.O. Box 651 Jackson, MS 39205Winston & Strawn LLP1700 K Street, N.W.

Washington, DC 20006-3817Manager - LicensingEntergy Operations, Inc.

River Bend Station 5485 US Highway 61N St. Francisville, LA 70775The Honorable Charles C. Foti, Jr.Attorney General Department of Justice State of Louisiana P.O. Box 94005 Baton Rouge, LA 70804-9005 Entergy Operations, Inc.- 3 -H. Anne Plettinger 3456 Villa Rose DriveBaton Rouge, LA 70806Bert Babers, PresidentWest Feliciana Parish Police Jury P.O. Box 1921 St. Francisville, LA 70775Richard Penrod, Senior Environmental Scientist Office of Environmental Services Northwestern State University Russell Hall, Room 201 Natchitoches, LA 71497Brian AlmonPublic Utility Commission William B. Travis Building P.O. Box 13326 1701 North Congress Avenue Austin, TX 78711-3326ChairpersonDenton Field Office Chemical and Nuclear Preparedness and Protection Division Office of Infrastructure Protection Preparedness Directorate Dept. of Homeland Security 800 North Loop 288 Federal Regional Center Denton, TX 76201-3698 Entergy Operations, Inc.- 4 -Electronic distribution by RIV:Regional Administrator (BSM1)DRP Director (ATH)DRS Director (DDC)DRS Deputy Director (RJC1)Senior Resident Inspector (PJA)Branch Chief, DRP/C (KMK)Senior Project Engineer, DRP/C (WCW)Team Leader, DRP/TSS (RLN1)RITS Coordinator (KEG)DRS STA (DAP)J. Lamb, OEDO RIV Coordinator (JGL1)ROPreports RBS Site Secretary (LGD)W. A. Maier, RSLO (WAM)SUNSI Review Completed: __wcw_ ADAMS: Yes G No Initials: __wcw_ Publicly Available G Non-Publicly Available G Sensitive Non-SensitiveR:\_REACTORS\_RBS\2006\RB2006-03RP Errata.wpdRIV:SPE:DRP/CC:DRP/CWCWalker;dfKMKennedy /RA/ RLBywater for8/16/069/12/06OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax Enclosure-22-NNS-ACB23 is one of the circuit breakers between preferred station serviceTransformer RTX-XSR1C and the Division III 4.16 kV ESF bus.Analysis: The performance deficiency associated with this finding involved thelicensee's failure to provide operators with an adequate STP to meet the requirements of TS SR 3.8.1.1 to verify correct breaker alignment and indicated power availability tothe Division III ESF bus for each required offsite circuit. A review of previous revisionsof STP-000-0102 showed that the procedure has never verified the required offsite power circuits for the Division III 4.16 kV ESF bus in Modes 1, 2, and 3. Although thisperformance deficiency caused the failure to verify the offsite power circuit for an extended period of time, the risk impact was limited to the 10 days from May 12-22, 2006. Therefore, the risk characterization of this finding is the same as that described in Section 1R15 of this inspection report. Enforcement: TS 5.4.1.a requires that written procedures be established, implemented,and maintained covering the activities specified in Appendix A, "Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors," of Regulatory Guide 1.33,"Quality Assurance Program Requirements (Operation)," dated February 1978.

Regulatory Guide 1.33, Appendix A, Section 8.a, requires procedures for all TS SRs. Procedure STP-000-0102 states that it verified the correct breaker alignment and power availability for each required offsite circuit in accordance with TS SR 3.8.1.1 in Modes 1,2, and 3. Contrary to this, Procedure STP-000-0102, Revision 4, did not require verification of the correct breaker alignment for the offsite power circuits to the Division III 4.16 kV ESF bus in Modes 1, 2, and 3. The root cause involved the incorrectinterpretation of the Division III 4.16 kV bus SRs as they apply to the unique River BendStation ESF electrical distribution system. The corrective actions to restore complianceincluded as an interim measure entering in the control room logs the breaker alignment for and the bus voltage available to the Division III 4.16 kV ESF bus, until STP-000-0102could be revised. Because the finding was of very low safety significance and has been entered into the licensee's CAP as CR-RBS-2006-02675 and -02402, this violation is being treated as an NCV consistent with Section VI.A of the Enforcement Policy: NCV 05000458/2006003-03, "Inadequate procedure to verify required offsite power breaker alignment."1R23Temporary Plant Modifications a.Inspection ScopeThe inspectors reviewed the USAR, plant drawings, procedure requirements, and TS toensure that Temporary Alteration 2006-0011, Off Gas Pretreatment Radiation MonitorSample Chamber Drain Line Modification, was properly implemented. The inspectors:

(1) verified that the modification did not have an affe ct on system operability/availability;(2) verified that the installation was consistent with modification documents; (3) ensured that the postinstallation test results were satisfactory and that the impact of the temporary modification on the operation of the pretreatment radiation monitor weresupported by the test; (4) verified that the modification was identified on control roomdrawings and that appropriate identification tags were placed on the affected drawings; Enclosure-23-and (5) verified that appropriate safety evaluations were completed. The inspectorsverified that the licensee identified and implemented any needed corrective actions associated with temporary modifications.The inspectors completed one inspection sample. b.FindingsNo findings of significance were identified.

Cornerstone: Emergency Preparedness1EP6Drill Evaluation a.Inspection ScopeOn June 20, 2006, the inspectors observed the full scope exercise dress rehearsal,which was used to contribute to "Drill/Exercise Performance" and "Emergency ResponseOrganization Drill Performance" PI. The inspectors: (1) observed the training evolutionto identify any weaknesses and deficiencies in classification, notification, and protective action requirements development activities; (2) compared the identified weaknesses and deficiencies against licensee identified findings to determine whether the licensee was properly identifying failures; and (3) determined whether licensee performance was in accordance with the guidance of the NEI 99-02, "Voluntary Submission of Performance Indicator Data," Revision 2, acceptance criteria. The scenario used was RDRL-EP-0602, Tornado/Loss of Offsite Power/Main Steam Line Break, dated June 16, 2006.Emergency [plan] implementing procedures reviewed by the inspectors included:

• EIP-2-001, "Classification of Emergencies," Revision 13*EIP-2-006, "Notifications," Revision 32

• EIP-2-007, "Protective Action Guidelines Recommendations," Revision 21The inspectors completed one inspection sample. b.FindingsNo findings of significance were identified.

Enclosure-24-2.RADIATION SAFETYCornerstone: Occupational Radiation Safety2OS1Access Control to Radiologically Significant Areas a.Inspection ScopeThis area was inspected to assess the licensee's performance in implementing physicaland 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, TS, and the licensee's procedures required by TS 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:*PI events and associated documentation packages reported by the licensee in theoccupational radiation safety cornerstone*Controls (surveys, posting, and barricades) of three radiation, high radiation, orairborne radioactivity areas*Radiation work permits, procedures, engineering controls, and air samplerlocations *Conformation of electronic personal dosimeter alarm setpoints with surveyindications 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 radioactivityareas*Adequacy of the licensee's internal dose assessment for any actual internalexposure greater than 50 millirem committed effective dose equivalent*Physical and programmatic controls for highly activated or contaminated materials(nonfuel) stored within spent fuel and other storage pools. *Self-assessments, audits, licensee event reports (LER), and special reportsrelated 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 individualdeficiencies *Radiation work permit briefings and worker instructions Enclosure-25-*Adequacy of radiological controls, such as required surveys, radiation protectionjob coverage, and contamination controls during job performance *Dosimetry placement in high radiation work areas with significant dose rategradients *Changes in licensee procedural controls of high dose rate - high radiation areasand very high radiation areas*Controls for special areas that have the potential to become very high radiationareas during certain plant operations*Posting and locking of entrances to all accessible high dose rate - high radiationareas and very high radiation areas *Radiation worker and radiation protection technician performance with respect toradiation protection work requirements The inspector completed 21 of the required 21 samples. b.Findings 1.Unguarded High Radiation Area BoundaryIntroduction: The inspector reviewed a self-revealing NCV of TS 5.7.1, resulting fromthe licensee's failure to control access to a high radiation area. The finding had very low safety significance.Description: On April 6, 2006, the licensee transferred reverse osmosis system filtersfrom one elevation of the radwaste building to another. Because dose rates on the filter barrels were as high as 600 millirem per hour, the licensee assigned personnel to guardthe elevator entrances to prevent workers from entering high radiation areas. On this occasion, the guards were not using radios, as was a common practice. Because of the lack of good communication, a guard prematurely left his post in front of the 123-foot elevation elevator door. Coincidently, two workers attempted to board the elevator on the 123-foot elevation after the guard had left. The elevator carrying the barrels ofradioactive filters stopped at the 123-foot elevation, the doors opened, and theelectronic dosimeters of the workers alarmed because of the high dose rates. The guard returned and evacuated the workers before they accrued additional radiation dose. The highest dose rate recorded by an electronic alarming dosimeter was 164 millirem per hour. Planned corrective action was still being evaluated by the licensee atthe conclusion of the inspection.Analysis: The failure to control access to a high radiation area was a performancedeficiency. The significance of the finding was greater than minor because it was associated with the occupational radiation safety attribute of exposure control and affected the cornerstone objective, in that not controlling access to a high radiation area Enclosure-26-could increase personal exposure. Using the Occupational Radiation SafetySignificance Determination Process, the inspector determined that the finding was ofvery low safety significance because it did not involve: (1) an as low as is reasonably achievable (ALARA) finding, (2) an overexposure, (3) a substantial potential foroverexposure, or (4) an impaired ability to assess dose. Additionally, this finding hadcrosscutting aspects associated with human performance in that the failure of the individual to guard the elevator door directly contributed to the violation.Enforcement: TS 5.7.1 requires each high radiation area, as defined in 10 CFR Part 20,in which the intensity of radiation is greater than 100 millirems per hour but less than1000 millirems per hour, be barricaded and conspicuously posted as a high radiationarea and entrance thereto shall be controlled by requiring issuance of a radiation work permit. The licensee violated TS 5.7.1 when it failed to barricade and conspicuously post the elevator housing the radioactive filter barrels or maintain a guard to ensure workers did not enter a high radiation area. Because this failure to control a high radiation area was of very low safety significance and has been entered into the licensee's CAP as CR-RBS-2006-01294, this violation is being treated as an NCV, consistent with Section VI.A of the NRC Enforcement Policy:

NCV 05000458/2006003-04, "Failure to control access to a high radiation area." 2.Unanalyzed Airborne Radioactivity SurveyIntroduction: The inspector identified an NCV of 10 CFR 20.1501(a) because thelicensee failed to survey airborne radioactivity. The finding had very low significance.Description: On May 2, 2006, during the removal of local power range monitors, thelicensee started collecting an air sample of the work area. The air sample spanned two shifts. A health physics technician on the second shift discarded the sample because the first shift had not documented a start time. Therefore, the sample was never analyzed. However, all workers successfully passed through the portal monitors at the exit of the controlled access area without alarm, confirming that no worker experienced an uptake of radioactive material. Planned corrective action is still being evaluated.Analysis: The failure to survey airborne radioactivity was a performance deficiency. This finding was greater than minor because it was associated with the occupational radiation safety program attribute of exposure control and affected the cornerstone objective in that the lack of knowledge of radiological conditions could increase personnel dose. Using the Occupational Radiation Safety Significance Determination Process, the inspector determined that the finding was of very low safety significance because it did not involve: (1) an ALARA finding, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. Additionally, thisfinding had crosscutting aspects associated with human performance in that the failureto maintain the sample for analysis directly contributed to the violation.Enforcement: 10 CFR 20.1501(a) requires that each licensee make or cause to bemade surveys that may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 and that are reasonable under the circumstances to evaluate the extentof radiation levels, concentrations or quantities of radioactive materials, and the potential Enclosure-27-radiological hazards that could be present. Pursuant to 10 CFR 20.1003, a "survey"means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation. In part, 10 CFR 20.1201(a) states that the licensee shall controlthe occupational dose to individual adults. The licensee violated 10 CFR 20.1501(a)

when it failed to perform an evaluation of airborne radioactivity to ensure compliance with 10 CFR 20.1201(a). Because this failure to perform a radiological survey was of very low safety significance and has been entered into the licensee's CAP as CR-RBS-2006-01994, this violation is being treated as an NCV, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000458/2006003-05, "Failure toperform airborne radiation survey."2OS2ALARA Planning and Controls a.Inspection ScopeThe inspector assessed licensee performance with respect to maintaining individual andcollective radiation exposures ALARA. The inspector used the requirements in 10 CFR Part 20 and the licensee's procedures required by TS as criteria for determining compliance. The inspector interviewed licensee personnel and reviewed:*Current 3-year rolling average collective exposure

• Three outage or on-line maintenance work activities scheduled during theinspection period and associated work activity exposure estimates which were likely to result in the highest personnel collective exposures *ALARA work activity evaluations, exposure estimates, and exposure mitigationrequirements*Intended versus actual work activity doses and the reasons for any inconsistencies*Shielding requests and dose/benefit analyses*Dose rate reduction activities in work planning

• Use of engineering controls to achieve dose reductions and dose reductionbenefits afforded by shielding *Workers use of the low dose waiting areas

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