IR 05000458/2018001

NRC Integrated Inspection Report 05000458/2018001

ML18128A246
Person / Time
Site:	River Bend
Issue date:	05/08/2018
From:	Jason Kozal NRC/RGN-IV/DRP/RPB-C
To:	Maguire W Entergy Operations
Kozal J
References
IR 2018001
Download: ML18128A246 (33)

Text

SUBJECT:

RIVER BEND STATION - NRC INTEGRATED INSPECTION REPORT 05000458/2018001

Dear Mr. Maguire:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your River Bend Station, Unit 1. On April 25, 2018, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented two findings of very low safety significance (Green) in this report.

One of these findings involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.

If you contest the violation or significance of the NCV, 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 a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at 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/

Jason W. Kozal, Chief Project Branch C Division of Reactor Projects Docket No. 50-458 License No. NPF-47

Enclosure:

Inspection Report 05000458/2018001 w/ Attachments:

1. Documents Reviewed 2. O

Inspection Report

Docket Number: 05000458 License Number: NPF-47 Report Number: 05000458/2018001 Enterprise Identifier: I-2018-001-0009 Licensee: Entergy Operations, Inc.

Facility: River Bend Station Location: Saint Francisville, Louisiana Inspection Dates: January 1, 2018 to March 31, 2018.

Inspectors: J. Sowa, Senior Resident Inspector B. Parks, Resident Inspector M. OBanion, Acting Resident Inspector J. Drake, Senior Reactor Inspector C. Young, Senior Project Engineer L. Carson II, Senior Health Physicist Approved By: J. Kozal, Chief, Branch C Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at River Bend Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. Findings and violations being considered in the NRCs assessment are summarized in the table below.

List of Findings and Violations Failure to Implement Procedure for Storage of Material in the Pools Cornerstone Significance Cross-cutting Report Aspect Section Occupational Green [H.4] - 71124.02 -

Radiation NCV 05000458/2018001-01 Human Occupational Safety Closed Performance, As Low As Teamwork Reasonably Achievable (ALARA)

Planning and Controls The inspectors identified a non-cited violation of Technical Specification 5.4.1.a for the licensees failure to implement written procedures for activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978. Specifically, the licensee failed to implement radioactive material control Procedure ADM-0071, Fuel Pools Material Control,

Revision 8, for the storage and movement of spent Tri-Nuke filters.

Installation of an Incorrectly Specified Relay Causes Plant Transient and Reactor Scram Cornerstone Significance Cross-cutting Report Aspect Section Initiating Green [H.5] - 71152 -

Events FIN 05000458/2018001-02 Human Problem Closed Performance, Identification Work and Management Resolution The inspectors reviewed two examples of a self-revealed finding for the licensees installation of an incorrectly specified relay in 1) the control circuitry for the feedwater level control system and 2) the turbine generator voltage regulator circuitry. In each instance, the incorrectly specified relay failed in service, causing a plant transient and automatic reactor scram.

Additional Tracking Items Type Issue number Title Report Status Section LER 05000458/2017-007-00 Automatic Reactor Scram 71153 Closed Due to Failure of Main Generator Voltage Regulator Mode Transfer Relay LER 05000458/2017-008-00 Automatic Reactor Scram 71153 Closed Due to Failure of Main Feedwater Regulator Transfer Relay

PLANT STATUS

River Bend Station began the inspection period at rated thermal power. On January 8, 2018, the unit was shut down for a planned maintenance outage. A reactor startup was performed on January 30, 2018. The unit was shut down to conduct a forced outage on February 1, 2018, due to an unexpected trip of the B reactor recirculation pump. A reactor startup was performed on February 9, 2018. The unit was shut down to conduct a forced outage on March 1, 2018, due to a pipe leak associated with the main condenser. A reactor startup was performed on March 6, 2018. The unit was returned to rated thermal power on March 20, 2018. The unit remained at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.04Equipment Alignment Partial Walkdown

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Division I residual heat removal system on January 25, 2018

(2) Division II residual heat removal system on January 25, 2018

(3) Control building heating, ventilation, and air conditioning (HVAC) system on

March 15, 2018 Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the standby service water system on March 8, 2018.

71111.05AQFire Protection Annual/Quarterly Quarterly Inspection

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Residual heat removal pump A room, fire area AB-5 on January 25, 2018

(2) Residual heat removal pump B room, fire area AB-3 on January 25, 2018

(3) Standby service water pump A room, fire area PH-1/Z-1on March 12, 2018

(4) Standby service water pump B room, fire area PH-2/Z-1 on March 12, 2018

71111.06Flood Protection Measures Internal Flooding

The inspectors evaluated internal flooding mitigation protections in the standby service water pump rooms, SW-01 on January 12, 2018.

Cables (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Electrical manhole 1EMH607 on January 16, 2018

(2) Electrical manhole 1EMH613 on January 16, 2018

71111.11Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed and evaluated licensed operator requalification training on

===February 6, 2018.

Operator Performance (1 Sample)===

The inspectors observed and evaluated the operators performance during a plant shutdown for a planned maintenance outage on January 7, 2018.

71111.12Maintenance Effectiveness Routine Maintenance Effectiveness

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Functional failure review of standby service water on January 16, 2018

(2) Functional failure review of the 120 VAC system on February 19, 2018

(3) Functional failure review of the reactor recirculation system associated with the failure of the B recirculation pump to upshift to fast speed on March 1, 2018

71111.13Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Yellow shutdown risk condition with containment access hatch open on January 8, 2018

(2) Yellow risk condition due to fuel movement and Division III emergency diesel generator inoperability while in Mode 5 on January 24, 2018

(3) Yellow risk condition due to high pressure core spray pump inoperability during remote shutdown panel surveillance testing on February 23, 2018

(4) Yellow risk condition due to residual heat removal pump B discharge flow inoperability during maintenance and testing on March 15, 2018

71111.15Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) E31-N604F main steam line tunnel temperature exceeded allowable values per surveillance test requirements on January 3, 2018

(2) Jacket water leaks associated with Division I emergency diesel generator on January 5, 2018

(3) Unexpected system response during Division II standby service water surveillance testing on January 15, 2018

(4) Residual heat removal shutdown cooling outboard isolation valve E12-MOVF008 over-torqued on February 19, 2018

(5) Division I inverter DNB-INV01A1 system output voltage exceeded max allowable voltage on March 20, 2018

71111.18Plant Modifications

The inspectors evaluated the following permanent modification:

(1) Division I standby diesel generator exhaust manifold piping to eliminate a vulnerability to flaw formation and leakage after Division I emergency diesel generator shroud replacement on January 19, 2018

71111.19Post Maintenance Testing

The inspectors evaluated the following post maintenance tests:

(1) STP-209-6310, Revision 39, RCIC Pump and Valve Quarterly Operability and Flow Test, following maintenance on the reactor core isolation cooling governor valve on January 5, 2018

(2) STP-504-4504, Revision 18, RPS/Control Rod Block - IRM D Channel Functional Test and LSFT, following replacement of intermediate range monitor D control relay H13-P672-Z2K18 on January 13, 2018

(3) STP-309-0206, Revision 29, Division I Diesel Generator 184 Day Operability Test, following maintenance on Division I emergency diesel generator on January 22, 2018

(4) STP-309-0203, Revision 329, Division III Diesel Generator Operability Test, following replacement of the Division III emergency diesel generator voltage regulator on January 24, 2018

(5) STP-504-4503, Revision 20, RPS/Control Rod Block - IRM C Channel Functional Test and LSFT, following maintenance on intermediate range monitor C on January 30, 2018

(6) SOP-0030, Revision 33, High Pressure Core Spray System (Sys 203), following maintenance on high pressure core spray motor supply breaker on February 22, 2018

(7) STP-256-6603, Revision 21, Division I Standby Service Water Quarterly Valve Operability Test, following maintenance and repairs to standby service water valve SWP-MOV96A on March 5, 2018

71111.20Refueling and Other Outage Activities

(1) The inspectors evaluated a planned maintenance outage implemented to remove damaged fuel assemblies. Inspection activities occurred from January 8, 2018, to January 31, 2018.

(2) The inspectors evaluated forced outage activities from February 1, 2018, to February 9, 2018. The forced outage occurred due to a failure of the B reactor recirculation pump to shift to fast speed. Station personnel conducted a forced outage and replaced the 13.8 kV transformer associated with the B reactor recirculation pump.

(3) The inspectors evaluated forced outage activities from March 1, 2018, to March 7, 2018. The forced outage occurred due to a leak from a crack on piping associated with the main condenser. Station personnel conducted a forced outage and repaired the leak.

71111.22Surveillance Testing The inspectors evaluated the following surveillance tests: Routine

(1) STP-203-1302, Revision 25, E22-S001BAT Quarterly Surveillance, on January 18, 2018

(2) STP-057-3801, Revision 012, Containment Equipment Hatch Leak Rate Test, on January 27, 2018

(3) OSP-0604, Revision 2, Remote Shutdown System Control Circuit Operability Test, on

February 26, 2018 In-service (2 Samples)

(1) STP-204-1300, Revision 18, LPCI Pump A Start Time Delay Channel Calibration and Channel Functional Test, on January 2, 2018

(2) STP-256-6301, Revision 23, Division I Standby Service Water Quarterly Valve Operability Test, on January 6, 2018

Reactor Coolant System Leak Detection (1 Sample)

(1) STP-000-0001, Revision 082, Daily Operating Logs, on January 4, 2018

Containment Isolation Valve (1 Sample)

(1) STP-057-7705, Revision 012, Primary Containment Airlocks Seal Leakage Rate Test, on January 28, 2018

71114.06Drill Evaluation Drill/Training Evolution

The inspectors evaluated a simulator-based emergency preparedness drill on March 13,

RADIATION SAFETY

71124.02Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls Radiological Work Planning

The inspectors evaluated the licensees radiological work planning by reviewing the following activities:

(1) RWP 2017-1220, Pre/Post Outage Prep Including Support

(2) RWP 2017-1296, RWCU Pump Replacement and Support Activities

(3) RWP 2017-1426, Motor Operated Valve and In-Vessel Testing

(4) RWP 2017-1436, Installation/Removal of Temporary Installation Main Steam Tunnel

(5) RWP 2017-1753, RWCU Hx Room Flow Accelerated Corrosion (FAC) Piping Replacement

(6) RWP 2017-1800, RF-19 Refuel Floor Outage Activities

(7) RWP 2018-1327, Separator Repair Following SHZAM Bolt Disengagement Verification of Dose Estimates and Exposure Tracking Systems (1 Sample)

The inspectors evaluated dose estimates and exposure tracking.

Implementation of ALARA and Radiological Work Controls (1 Sample)

The inspectors reviewed ALARA practices and radiological work controls by reviewing the following activities:

(1) RWP 2017-1220, Pre/Post Outage Prep Including Support

(2) RWP 2017-1296, RWCU Pump Replacement and Support Activities

(3) RWP 2017-1426, Motor Operated Valve and In-Vessel Testing

(4) RWP 2017-1436, Installation/Removal of Temporary Installation Main Steam Tunnel

(5) RWP 2017-1753, RWCU HX Room FAC Piping Replacement

(6) RWP 2017-1800, RF-19 Refuel Floor Outage Activities

(7) RWP 2018-1327, Separator Repair Following SHZAM Bolt Disengagement

Radiation Worker Performance (1 Sample)

The inspectors evaluated radiation worker and radiation protection technician performance.

71124.04 - Occupational Dose Assessment Source Term Characterization

===The inspectors evaluated the licensees source term characterization.

External Dosimetry===

The inspectors evaluated the licensees external dosimetry program.

Internal Dosimetry (1 Sample)

The inspectors evaluated the licensees internal dosimetry program.

Special Dosimetric Situations (1 Sample)

The inspectors evaluated the licensees performance for special dosimetric situations.

OTHER ACTIVITIES - BASELINE

71151Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (01/01/2017 - 12/31/2017)

(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (01/01/2017 -

12/31/2017)

(3) IE04: Unplanned Scrams with Complications (USwC) Sample (01/01/2017 -

12/31/2017)

71152Problem Identification and Resolution Annual Follow-up of Selected Issues

The inspectors reviewed the licensees implementation of its corrective action program related to the following issue:

(1) Relay failures in the feedwater level control system and the turbine generator voltage regulator control system resulted in reactor scrams

71153Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports

The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report 05000458/2017-007-00, Automatic Reactor Scram Due to Failure of Main Generator Voltage Regulator Mode Transfer Relay on August 21, 2017

(2) Licensee Event Report 05000458/2017-008-00, Automatic Reactor Scram Due to Failure of Main Feedwater Regulator Transfer Relay on October 12,

INSPECTION RESULTS

Failure to Implement Procedure for Storage of Material in the Pools Cornerstone Significance Cross-cutting Report Section Aspect Occupational Green [H.4] - Human

==71124.02 - Radiation Safety NCV 05000458/2018001-01 Performance, Occupational

==

Closed Teamwork As Low As Reasonably Achievable (ALARA)

Planning and Controls The inspector identified a non-cited violation of Technical Specification 5.4.1.a, for the licensees failure to implement written procedures for activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978. Specifically, the licensee failed to implement radioactive material control Procedure ADM-0071, Fuel Pools Material Control, Revision 8, for the storage and movement of spent Tri-Nuke filters.

Description:

The inspector reviewed condition reports (CRs) that documented incidents associated with the movement and storage of highly radioactive materials in the various pools at River Bend Station (RBS) in 2017. Four radiological occurrences involved unplanned and unanticipated movements of spent Tri-Nuke filters around the separator and upper inclined fuel transfer storage (IFTS) pools.

• January 5, 2017, CR-RBS-2017-0100: Radiation Protection (RP) was notified that a spent Tri-Nuke filter was found floating on the surface of the separator pool.

Surveys of the filter and surrounding area were performed by RP technicians.

Dose rates on the filter measured 2.2 Roentgen/hour (R/hr) on contact and 0.85 R/hr at 30 centimeters (cm).

• April 3, 2017, CR-RBS-2017-03011: A used Tri-Nuke filter measuring 1.3 R/hr and 0.350 R/hr at 30 cm was discovered floating in the reactor building (RB)-186 separator pool.

• April 24, 2017, CR-RBS-2017-03424: While performing video surveillance of the refueling pool on RB-186, a Tri-Nuke filter was discovered floating on the surface of the separator pool. The filter had a dose rate of 11 R/hr on contact and 6 R/hr at 30 cm.

• During the week of April 27, 2017, the licensee transferred the 30 Tri-Nuke filters from the separator pool to the IFTS. However, one of the Tri-Nuke filters (0.300 R/hr) had been damaged when falling into the bottom of the IFTS pool. It was eventually recovered and stored.

The inspector examined the circumstances that caused the Tri-Nuke filters to become buoyant and float around the separator pool resulting in unintended radiological hazards. Two CRs from 2015 (CR-RBS-2015-07893 and CR-RBS-2015-08050) identified concerns with air intrusion from a leaky spent fuel cooling system valve. Also, two CRs from 2017 (CR-RBS-2017-01881 and CR-RBS-2017-03424) identified that the leaky valve caused spent Tri-Nuke filters to float. The licensee eventually determined the solution to the problem was to transfer the spent Tri-Nuke filters to the upper IFTS pool. However, the inspector determined that the licensee was not supposed to leave the spent Tri-Nukes in the separator and upper IFTS pools unless designed storage racks were in place or an engineering change request (ECR) evaluation allowed the practice.

The movement and storage of radioactive material in and around the pools at RBS are implemented through the following procedures:

• EN-RP-121, Revision 13, Radioactive Material Control

• EN-RP-123, Revision 1, Radiological Controls of Highly Radioactive Objects

• ADM-0071, Revision 8, Fuel Pools Material Control The inspector determined that the purpose of Entergy Corporate Procedures EN-RP-121 and EN-RP-123 was to prevent the unauthorized movement and removal of radioactive materials around the site and from pools. These procedures required that licensee personnel receive proper authorization from reactor engineering and radiation protection management for movement and storage of radioactive materials in pools and the around pools. Based on the documents and procedures reviewed by the inspector, the licensee did not specify storage requirements or equipment for these filters to prevent them from floating to the top of the pools and becoming radiological hazards.

The inspector reviewed RBS site-specific Procedure ADM-0071, Revision 8, which described the requirements established for the control of miscellaneous material stored in fuel pools. At RBS, radioactive materials are stored in the following seven pools: spent fuel pool, cask pool, lower IFTS, upper IFTS, upper containment pool, dryer storage pool, and separator pool.

ECR RBS-ER-97-504, Fuel Pool Inventory Identification, Justification, and Evaluation, dated September 30, 1997, stated that the purpose of ADM-0071 was to provide a means to adequately control, regulate, and inventory non-special nuclear material stored in the spent fuel pool and upper containment pools. Items may not be stored in the spent fuel storage upper containment pools, which includes the separator pool, without design engineering approval. Additionally, items that are not stainless steel or in a stainless steel container are not to be stored without being verified radiation resistant and not detrimental to the fuel pool water quality.

Section 7.3 of Procedure ADM-0071 provided instructions for storing or moving material within the same pool or to another pool location. Section 7.3.7 required that the pool material inventory POOL MATERIAL CONTROL FORM be completed and updated after approval of the material storage/move by the reactor engineering manager and radiation protection superintendent. The form required specific information about proposed items to be stored, such as the radiation surveys taken, work order used, storage container location, special requirements, radiation exposure duration, and applicable ECR evaluations. At the time of this inspection, the licensee did not have any pool material control forms completed for the 30 Tri-Nuke filters that were placed into the separator pool and subsequently transferred to the IFTS in 2017. In particular, there was no pool material control forms signed by the reactor engineering manager and radiation protection superintendent approving the proper storage and movement of these Tri-Nuke filters for either location.

Procedure ADM-0071 allowed miscellaneous items such as Tri-Nuke filters to be stored in the separator and IFTS pools if an ECR evaluation and engineering approval on the storage method were done. The inspector queried whether any ECRs had been performed for storage of the Tri-Nuke filters. Only two were available for the inspectors review. The two ECRs (ECR RBS-ER-97-504 and ECR 33163) revealed that the licensee had not made specific provisions or performed evaluations for the storage of Tri-Nuke filters in the separator or upper IFTS pools.

The inspector determined that licensees procedures did not adequately address securing highly radioactive material in pools such as Tri-Nuke filters to prevent radioactive material from floating to the pool surface and thereby becoming radiation hazards to personnel, as had occurred three times in early 2017. Further, the failure to follow the requirements of Procedure ADM-0071 resulted in bypassing the performance of an evaluation to ensure proper movement and storage of the filters.

Corrective Actions: Immediate safety concerns with filters becoming buoyant due to the air intrusion in the separator pool were addressed when the licensee transferred the 30 Tri-Nuke filters to the IFTS pool in late April 2017. Procedure compliance issues are being addressed through an action item in CR-RBS-2018-00523.

Corrective Action References: CR-RBS-2018-00523

Performance Assessment:

Performance Deficiency: The licensees failure to implement written procedures for activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978, as required by Technical Specification 5.4.1.a, was a performance deficiency. Specifically, the licensee failed to implement radioactive material control Procedure ADM-0071, Fuel Pools Material Control, Revision 8, for the storage and movement of spent Tri-Nuke filters.

Screening: The performance deficiency was more than minor because it adversely affected the programs and process (exposure control) attribute of the Occupational Radiation Safety Cornerstone and its objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material. Specifically, allowing highly radioactive material (Tri-Nuke filters) to be moved and stored in an unsafe, unevaluated, unapproved manner resulted in unanticipated dose rates and unplanned worker exposures to radiation.

Significance: The inspectors assessed the significance of the finding using NRC Inspection Manual Chapter 0609, Appendix, C, Occupational Radiation Safety Significance Determination Process, and determined that the finding was of very low safety significance (Green) because it did not:

(1) involve ALARA planning or work controls,

(2) did not involve an overexposure,

(3) did not have a substantial potential to be an overexposure, and

(4) the ability to assess dose was not compromised.

Cross-cutting Aspect: The finding has a cross-cutting aspect in the area of human performance, associated with teamwork, because individuals and work groups failed to communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety was maintained. Specifically, the communication and coordination of activities between construction projects, health physics, and nuclear engineering failed to prevent radiological issues associated with the storage and movement of Tri-Nuke filters.

Enforcement:

Violation: Technical Specification 5.4.1.a requires, in part, that procedures be written, implemented, and established for those areas recommended in Regulatory Guide 1.33, Appendix A, Revision 2, 1978. Section 7(b) of Regulatory Guide 1.33, Appendix A, requires procedures for control of radioactive materials to minimize potential releases to the environment and control personnel exposure associated with solid radioactive waste.

Licensee Procedure ADM-0071, Fuel Pools Material Control, Revision 8, Section 7.1, requires that if material must be stored in a pool or previously stored material must be moved from one pool to a different pool or to a different area in the same pool, Section 7.3 must be completed. Section 7.3.7 requires that the pool material inventory POOL MATERIAL CONTROL FORM be updated after approval of the material storage/move by the reactor engineering manager and radiation protection superintendent.

Contrary to the above, beginning in 2017 and to present, the licensee stored material in a pool and moved previously stored material from one pool to a separate pool without completing Section 7.3 of Procedure ADM-0071. Specifically, the licensee stored 30 Tri-Nuke filters in the separator pool without completing the pool material Inventory form and, in April 2017, moved the filters to the incline fuel transfer storage pool without completing/

updating a pool material Inventory POOL MATERIAL CONTROL FORM and obtaining the required approvals.

As of January 26, 2018, the licensee had not fully implemented Section 7.3 of Procedure ADM-0071 by updating the form and obtaining written approval from the radiation protection superintendent and reactor engineering manager for the movement and safe storage of the 30 Tri-Nuke filters in the incline fuel transfer storage pool.

Disposition: This violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy.

Installation of an Incorrectly Specified Relay Causes Plant Transient and Reactor Scram Cornerstone Significance Cross-cutting Report Aspect Section Initiating Events Green [H.5] - Human

71152 - FIN 05000458/2018001-02 Performance, Problem

Closed Work Identification Management and Resolution The inspectors reviewed two examples of a self-revealed finding for the licensees installation of an incorrectly specified relay in 1) the control circuitry for the feedwater level control system and 2) the turbine generator voltage regulator circuitry. In each instance, the incorrectly specified relay failed in service, causing a plant transient and automatic reactor scram.

Description:

Example 1: On August 18, 2017, with the plant operating at 100 percent power, an automatic scram occurred. At the time of the scram, operators were performing a scheduled surveillance test that called for a planned shift of the controlling channel of the feedwater level control system from channel B to channel A. Immediately after the shift, feedwater regulating valves went full open and recirculation pumps downshifted to slow speed. The combination of these events caused an automatic scram to occur on high flow-biased thermal power.

The cause of the scram was a failure of the feedwater level select relay, C33A-K12. The failure of this relay caused the interpreted level in the feedwater level control system to go to zero, which in turn caused a full open demand on the feedwater regulating valves and a downshift of recirculation pumps from fast to slow speed on a perceived low level condition in the reactor vessel.

A subsequent investigation determined that the feedwater level select relay failed due to a degradation in the electrical contacts on the relay. The degradation caused a sharp increase in resistance across the contacts, which in turn led to a substantial reduction in the current passing through these contacts to the rest of the feedwater level control circuit. With the current substantially reduced, the circuit incorrectly perceived a low vessel level condition.

The failed relay was a General Electric Agastat GPI type relay. Operating experience at River Bend Station and at other sites in the industry has established that this type of relay is prone to intermittent failure. When used in low current applications such as those associated with the feedwater level control circuit, there is a potential for oxidation to build up on the contacts of the relay, which will create resistance across the relay and impair its ability to pass current. In light of this operating experience, the licensee issued part interchangeability evaluation (PIE) 411 in March 1993. PIE 411 called for a GPIA type relay with gold-plated contacts to be used for C33A-K12 in lieu of the silver-plated GPI type relay that had traditionally been used.

The inspectors determined that PIE-411 was a self-imposed licensee standard. The licensee complied with this standard until February 2017, when the gold-plated relay installed in the system was incorrectly replaced with a silver-plated relay. Given that the silver-plated relay was being used in a low current application, it built up resistance over time and eventually failed, causing the scram.

Example 2: On June 23, 2017, with the plant operating at 100 percent power, an automatic scram occurred. At the time of the scram, operators were performing a scheduled surveillance test that called for a planned shift of the turbine generator voltage regulator control from automatic to manual. Immediately after the shift, the main generator tripped which caused a subsequent reactor scram.

The cause of the scram was a failure of the voltage regulator transfer circuit relay, EXS-PNL1-43A. The failure of this relay caused an open circuit in both the manual and automatic voltage regulators and complete loss of control of the Alterrex Excitation System.

When neither the manual nor the automatic voltage regulator is connected to the Alterrex Excitation System, there is no excitation field applied. The result is a turbine trip on loss of excitation.

A subsequent investigation determined that the main generator voltage regulator mode transfer relay failed due to a degradation in the electrical contacts on the relay. The degradation caused a sharp increase in resistance across the contacts, which in turn led to a substantial reduction in the current passing through these contacts to the rest of the voltage regulator control circuit. With the current substantially reduced, the circuit could not be completed for either the manual or automatic control system of the turbine voltage regulator.

The failed relay was a General Electric DC operated 4-pole double throw miniature 43A relay provided as part of the turbine generator package and is part of the Alterrex exciter transfer panel assembly. Operating experience at River Bend Station and at other sites in the industry has established that this type of relay is prone to intermittent failure. The station generated engineering change 40442 in 2012 to replace the 43A relay with a different model documenting obsolescence of this relay as well as operating experience related to intermittent failures of this type of relay. In light of this operating experience, the licensee cancelled engineering change 40442 for unknown reasons and did not replace the 43A relay with a different style.

Corrective Actions: The licensee installed the correctly specified relay in the feedwater level control system and an upgraded vendor recommended relay in the turbine voltage regulator control system. The licensee also completed an extent of condition review on similar relays.

Corrective Action References: Condition Reports CR-RBS-2017-06118 and CR-RBS-2017-04961

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees installation of an incorrectly specified relay in 1) the control circuitry for the feedwater level control system and 2) the control circuitry for the main generator voltage regulator were two examples of a performance deficiency.

Screening: The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power. The finding was determined to be of very low safety significance (Green) because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigating equipment would not be available.

Cross-cutting Aspect: The finding has a cross-cutting aspect in the area of human performance associated with work management because the licensee failed to implement a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On January 26, 2018, the inspectors presented the radiation safety inspection results to Mr. W. Maguire, Site Vice President, and other members of the licensee staff.

On April 25, 2018, the inspectors presented the quarterly resident inspector inspection results to Mr. W. Maguire, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

71111.04 - Equipment Alignment

Condition Reports (CR-RBS-)

2017-05292 2017-07460 2017-07880 2018-00615

2018-00992

Drawings

Number Title Revision

PID-09-10E Engineering P&I Diagram, System 256, Service 24

Water - Standby

PID-22-09A Engineering P&I Diagram, System 402, HVAC - 21

Control Building

Procedures

Number Title Revision

R-STM-0118 Service Water Systems 26

R-STM-0402 HVAC - Control Building and Diesel Generator 9

Building

SOP-0031 Residual Heat Removal 338

SOP-0042 Standby Service Water System (Sys #256) 46

SOP-0058 Control Building HVAC System (Sys #402) 24

71111.05 - Fire Protection

Procedures

Number Title Revision

AB-070-502 RHR Pump A Room, Fire Area AB-5 4

AB-070-505 RHR Pump B Room, Fire Area AB-3 3

EN-DC-161 Control of Combustibles 17

SP-118-450 Standby Cooling Pump A Room, Fire Area PH-1/Z-1 3

SP-118-451 Standby Cooling Pump B Room, Fire Area PH-2/Z-1 3

STP-250-4533 FPM-PNL6 Fire Detection Channel Functional and 1

Operational Tests for Zone SD72, SD73, and SD89

(A&B)

71111.06 - Flood Protection Measures

Condition Reports (CR-RBS-)

2018-00200 2018-00367 2018-00369

Procedure

Number Title Revision

PN-317 Max Flood Elevations for Moderate Energy Line 01

Cracks in Cat I Structures

Work Orders

0052802383 0052802384

71111.11 - Licensed Operator Requalification Program and Licensed Operator

Performance

Procedures

Number Title Revision

GOP-0002 Power Decrease/Plant Shutdown 078

RSMS-OPS-HIT1 Licensed Operator Requalification 0

71111.12 - Maintenance Effectiveness

Condition Reports (CR-RBS-)

2017-00629 2017-01579 2017-01668 2017-01703

2017-01739 2017-01748 2017-01749 2017-03871

2017-04048 2017-04514 2017-05273 2017-05939

2017-06767 2017-06977 2017-06998 2017-07017

2017-07200 2017-07410 2017-07454 2017-07820

2017-07880 2017-07950 2018-00825 2018-01363

Procedures

Number Title Revision

EN-DC-203 Maintenance Rule Program 3

EN-DC-204 Maintenance Rule Scope and Basis 4

EN-DC-205 Maintenance Rule Monitoring 6

EN-DC-206 Maintenance Rule (A)(1) Process 3

Procedures

Number Title Revision

SOP-0042 Standby Service Water System (Sys #256) 45

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Condition Report (CR-RBS-)

2018-00505

Procedures

Number Title Revision

ADM-0096 Risk Management Program Implementation and 326

On-Line Maintenance Risk Assessment

EN-WM-104 On Line Risk Assessment 16

OSP-0037 Shutdown Operations Protection Plan (SOPP) 036

71111.15 - Operability Determinations and Functionality Assessments

Condition Reports (CR-RBS-)

2016-05866 2017-04048 2017-04097 2017-04302

2017-05033 2017-07111 2017-07162 2017-07199

2017-07219 2017-07532 2017-08048 2018-00194

2018-00402

Miscellaneous

Number Title Revision

EC 66261 SWP-SOV523B Reasonable Expectation of 0

Operability Input for CR-RBS-2016-05866

Procedures

Number Title Revision

OSP-0028 Log Report - Normal Switchgear, Control, and 108

Diesel Generator Buildings

STP-000-0001 Daily Operating Logs 82

STP-256-6608 Division II Standby Service Water 2 Year Position 4

Indication Verification Test

STP-309-0201 Division I Diesel Generator Operability Test 59

Work Orders

00469400 00476322 00479296

71111.18 - Plant Modifications

Calculation

Number Title Revision

G13.18.2.4-108 LPI, Inc. Evaluation of Standby Diesel Generator 1

Exhaust Manifold Stiffeners

Condition Reports (CR-RBS-)

2015-04817 2016-06841 2016-07753 2017-07111

2017-07532 2017-08048

Drawing

Number Title Revision

PID-08-09B Engineering P&I Diagram System 309 Diesel 23

Generator

Procedure

Number Title Revision

SOP-0053 Standby Diesel Generator and Auxiliaries 057

(Sys #309)

Work Order 228397

71111.19 - Post-Maintenance Testing

Condition Reports (CR-RBS-)

2017-07237 2017-07728

Miscellaneous

Number Title Revision/Date

E22-S004 ACB2 Vendor Overhaul Breaker 0

Procedures

Number Title Revision

CMP-EM-203-1001 Inspection and Maintenance of 4.16 KV 1

Magne-Blast Circuit Breakers

STP-209-0201 RCIC Discharge Piping Fill and Valve Lineup 13

Verification

Work Orders

228397 00478865 00492550 00493155 00493741

2650988 52769345 52779858

71111.20 - Refueling and Other Outage Activities

Procedures

Number Title Revision

GOP-0001 Plant Startup 099

GOP-0002 Power Decrease/Plant Shutdown 078

71111.22 - Surveillance Testing

Condition Reports (CR-RBS-)

2015-02736 2018-00290

Drawing

Number Title Revision

GE-828E534AA Elementary Diagram Residual Heat Removal 28

Sheet 8

Procedures

Number Title Revision

SOP-0018 Normal Service Water System 67

SOP-0042 Standby Service Water System 45

Work Orders

00492725 52785880 52787021

71114.06 - Drill Evaluation

Miscellaneous

Number Title Revision

RDRL-EP-1201 Site Drill Scenario 01

71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and

Controls

Audits and Self-Assessments

Number Title Date

LO-RLO-2017-0055 Pre-NRC Self-Assessment Radiation Safety - December 4, 2017

IP 71124.02

LO-RLO-2016-0145 Pre-NRC Self-Assessment Radiation Safety - January 17, 2017

IP 71124.02

Condition Reports (CR-RBS-)

2015-07893 2015-08050 2017-00100 2017-00707

2017-00868 2017-01250 2017-01355 2017-01731

2017-01881 2017-01927 2017-03011 2017-03237

2017-03266 2017-03424 2017-03598 2017-03788

2017-04856 2017-04941 2017-05499 2017-01372

2017-01422

Miscellaneous

Number Title Date

RF-19 Water Movement Plan January 2017

CFR Part 20.1101(c) Report for 2016 June 2017

ADM-0071 Post Material Inventory Report Post RF-19 May 31, 2017

WO 473593 Relocate Tri-Nuke filters from the Separator Pool April 11, 2017

the IFTS

Procedures

Number Title Revision

ADM-0071 Fuel Pools Material Control 08

EN-RP-100 Radiation Worker Expectations 12

EN-RP-101 Access Control for Radiologically Controlled Areas 13

Procedures

Number Title Revision

EN-RP-102 Radiological Control 05

EN-RP-105 Radiological Work Permits 18

EN-RP-106 Radiological Survey Documentation 07

EN-RP-108 Radiation Protection Posting 19

EN-RP-109 Hot Spot Program 05

EN-RP-110 ALARA Program 14

EN-RP-110-03 Collective Radiation Exposure (CRE) Guidelines 04

EN-RP-110-04 Radiation Protection Risk Assessment Process 07

EN-RP-110-06 Outage Dose Estimating and Tracking 01

EN-RP-115-01 BRAC Survey Instructions 00

EN-RP-121 Radioactive Material Control 13

EN-RP-123 Radiological Controls for Highly Radioactive 01

Objects

EN-RP-143 Source Control 13

EN-RP-151 Radiological Diving 03

GMP-0111 Tri-Nuclear Filter Operations 01

Radiation Surveys

Number Title Date

RBS-1701-0042 RB +186 Upper Pool HCA Handrail January 5, 2017

RBS-1703-0124 RB +186 Upper Pool and Carousel Area March 5, 2017

RBS-1704-0059 RB +186 Upper Pool 354 R/hr. Tri-Nuke Filter April 5, 2017

RBS-1704-0248 RB +186 Upper Pool 11 R/hr. Tri-Nuke Filter April 21, 2017

RBS-1704-0303 RB +186 Upper Pool 24 Tri-Nuke Filters April 21, 2017

Radiation Work Permits/ALARA Reviews

Number Title Revision

2017-1220 Pre/Post Outage Prep Including Support 01

2017-1296 RWCU Pump Replacement and Support Activities 01

2017-1426 Motor Operated Valve and In-Vessel Testing 01

Radiation Work Permits/ALARA Reviews

Number Title Revision

2017-1436 Installation/Removal of Temporary Installation Main 01

Steam Tunnel

2017-1753 RWCU HX Room FAC Piping Replacement 01

2017-1800 RF-19 Refuel Floor Outage Activities 01

2018-1327 Separator Repair Following SHZAM Bolt 00

Disengagement

71124.04 - Occupational Dose Assessment

Audits and Self-Assessments

Number Title Date

LO-RBS-2017-00055 Pre-NRC Assessment IP71124.04 October 27, 2017

Occupational Dose

Condition Reports (CR-RBS-)

2016-05858 2017-08105 2017-00707 2017-00868

2017-00910 2017-03788 2017-05176 2017-05489

Miscellaneous

Number Title Date

2017 Multi-Pack TLD Results 2017

2018 NVLAP Accreditation Report 2018

Procedures

Number Title Revision

EN-RP-131 Air Sampling 15

EN-RP-201 Dosimetry Administration 05

EN-RP-202 Personnel Monitoring 13

EN-RP-203 Dose Assessment 10

EN-RP-204 Special Monitoring Requirements 11

EN-RP-205 Prenatal Monitoring 04

EN-RP-206 Dosimeter of Legal Record QA 07

EN-RP-208 Whole Body Counting / In-Vitro Bioassay 07

Procedures

Number Title Revision

EN-RP-311 Electronic Alarming Dosimeter 02

EN-RP-317-09 Electronic Alarming Dosimeter Calibration 02

Self-Reading Dosimeter Calibration Records

Number Title Date

2017-B2-28- Self-Reading Dosimeter September 18, 2017

CALDAT-05667

2017-B2-28- Self-Reading Dosimeter September 30, 2017

CALDAT-05713

2017-B2-28- Self-Reading Dosimeter September 30, 2017

CALDAT-05736

2017-B2-28- Self-Reading Dosimeter September 26, 2017

CALDAT-05836

2017-B2-28- Self-Reading Dosimeter December 15, 2017

CALDAT-06692

71151 - Performance Indicator Verification

Procedures

Number Title Revision

EN-LI-114 Performance Indicator Process 11

NEI 99-02 Regulatory Assessment Performance Indicator 7

Guideline

71152 - Problem Identification and Resolution

Condition Reports (CR-RBS-)

2017-06118 2017-04961

71153 - Follow-up of Events and Notices of Enforcement Discretion

Condition Report (CR-RBS-)

2017-06118

Miscellaneous

Number Title Revision

PIE-411 Part Interchangeability Evaluation 411 0

Procedure

Number Title Revision

EN-MA-101 Conduct of Maintenance 22

Work Order 00441196

The following items are requested for the

Occupational Radiation Safety Inspection

at River Bend Station

January 22-25, 2018

Integrated Report 2018001

Inspection areas are listed in the attachments below.

Please provide the requested information on or before January 12, 2018.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

1- A, applicable organization charts in file/folder 1- B, etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Louis Carson at (817) 200-1221 or

Louis.Carson@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.

2. Occupational ALARA Planning and Controls (71124.02)

Date of last inspection: January 21, 2016

A. List of contacts and telephone numbers for ALARA program personnel

B. Applicable organization charts

C. Copies of audits, self-assessments, and LERs, written since date of last inspection,

focusing on ALARA

D. Procedure index for ALARA Program

E. Please provide specific procedures related to the following areas noted below.

Additional specific procedures may be requested by number after the inspector reviews

the procedure indexes.

1. ALARA Program

2. ALARA Committee

3. Radiation Work Permit (RWP) Preparation

F. A summary list of corrective action documents (including corporate and sub-tiered

systems) written since date of last inspection, related to the ALARA program. In addition

to ALARA, the summary should also address RWP violations, electronic dosimeter

alarms, and RWP dose estimates

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G. List of work activities greater than 1 rem, since date of last inspection,

Include original dose estimate and actual dose.

H. Site dose totals and 3-year rolling averages for the past 3 years (based on dose of

record)

I. Outline of source term reduction strategy

J. If available, provide a copy of the ALARA outage report for the most recently completed

outages for each unit

K. Please provide your most recent Annual ALARA Report.

4. Occupational Dose Assessment (Inspection Procedure 71124.04)

Date of Last Inspection: January 21, 2016

A. List of contacts and telephone numbers for the following areas:

1. Dose Assessment personnel

B. Applicable organization charts

C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs

written since date of last inspection, related to:

1. Occupational Dose Assessment

D. Procedure indexes for the following areas:

1. Occupational Dose Assessment

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Radiation Protection Program

2. Radiation Protection Conduct of Operations

3. Personnel Dosimetry Program

4. Radiological Posting and Warning Devices

5. Air Sample Analysis

6. Performance of High Exposure Work

7. Declared Pregnant Worker

8. Bioassay Program

F. List of corrective action documents (including corporate and sub-tiered systems) written

since date of last inspection, associated with:

1. National Voluntary Laboratory Accreditation Program (NVLAP)

2. Dosimetry (TLD/OSL, etc.) problems

3. Electronic alarming dosimeters

4. Bioassays or internally deposited radionuclides or internal dose

5. Neutron dose

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G. List of positive whole body counts since date of last inspection, names redacted if

desired

H. Part 61 analyses/scaling factors

I. The most recent National Voluntary Laboratory Accreditation Program (NVLAP)

accreditation report or, if dosimetry is provided by a vendor, the vendors most recent

results

ML18128A246

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: CHY/rdr Yes No Publicly Available Sensitive NRC-002

OFFICE SRI:DRP/C RI:DRP/C ARI:DRP/C SPE:DRP/C C:DRS/EB1 C:DRS/EB2

NAME JSowa BParks MOBanion CYoung TFarnholtz JDrake

SIGNATURE /RA/ /RA/ /RA-E/ /RA/ /RA/ /RA/

DATE 4/23/18 4/30/18 4/24/18 4/27/18 4/23/18 4/23/18

OFFICE C:DRS/OB C:DRS/PSB2 TL:IPAT BC:DRP/C

NAME VGaddy HGepford GGeorge JKozal

SIGNATURE /RA/ /RA/ /RA/ /RA/

DATE 4/14/18 4/23/18 4/24/18 5/08/18

May 8, 2018

Mr. William

F. Maguire, Site Vice President

Entergy Operations, Inc.

River Bend Station

5485 U.S. Highway 61N

St. Francisville, LA 70775

SUBJECT: RIVER BEND STATION - NRC INTEGRATED INSPECTION

REPORT 05000458/2018001

Dear Mr. Maguire:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your River Bend Station, Unit 1. On April 25, 2018, the NRC inspectors discussed the results

of this inspection with you and other members of your staff. The results of this inspection are

documented in the enclosed report.

NRC inspectors documented two findings of very low safety significance (Green) in this report.

One of these findings involved a violation of NRC requirements. The NRC is treating this

violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement

Policy.

If you contest the violation or significance of the NCV, you should provide a response within

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 a cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the

U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the

NRC resident inspector at the River Bend Station.

W. Maguire 2

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/

Jason

W. Kozal, Chief

Project Branch C

Division of Reactor Projects

Docket No. 50-458

License No. NPF-47

Enclosure:

Inspection Report 05000458/2018001

w/ Attachments:

1. Documents Reviewed

2. Occupational Radiation Safety Inspection

Request for Information

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000458

License Number: NPF-47

Report Number: 05000458/2018001

Licensee: Entergy Operations, Inc.

Facility: River Bend Station

Location: Saint Francisville, Louisiana

Inspection Dates: January 1, 2018 to March 31, 2018.

Inspectors:

J. Sowa, Senior Resident Inspector

B. Parks, Resident Inspector

M. OBanion, Acting Resident Inspector

J. Drake, Senior Reactor Inspector

C. Young, Senior Project Engineer

L. Carson II, Senior Health Physicist

Approved By:

J. Kozal, Chief, Branch C

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees

performance by conducting an integrated inspection at River Bend Station in accordance with

the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for

overseeing the safe operation of commercial nuclear power reactors. Refer to

https://www.nrc.gov/reactors/operating/oversight.html for more information. Findings and

violations being considered in the NRCs assessment are summarized in the table below.

List of Findings and Violations

Failure to Implement Procedure for Storage of Material in the Pools

Cornerstone Significance Cross-cutting Report

Aspect Section

Occupational Green [H.4] - 71124.02 -

Radiation NCV 05000458/2018001-01 Human Occupational

Safety Closed Performance, As Low As

Teamwork Reasonably

Achievable

(ALARA)

Planning and

Controls

The inspectors identified a non-cited violation of Technical Specification 5.4.1.a for the

licensees failure to implement written procedures for activities referenced in Appendix A of

Regulatory Guide 1.33, Revision 2, dated February 1978. Specifically, the licensee failed to

implement radioactive material control Procedure ADM-0071, Fuel Pools Material Control,

Revision 8, for the storage and movement of spent Tri-Nuke filters.

Installation of an Incorrectly Specified Relay Causes Plant Transient and Reactor Scram

Cornerstone Significance Cross-cutting Report

Aspect Section

Initiating Green [H.5] - 71152 -

Events FIN 05000458/2018001-02 Human Problem

Closed Performance, Identification

Work and

Management Resolution

The inspectors reviewed two examples of a self-revealed finding for the licensees installation

of an incorrectly specified relay in 1) the control circuitry for the feedwater level control system

and 2) the turbine generator voltage regulator circuitry. In each instance, the incorrectly

specified relay failed in service, causing a plant transient and automatic reactor scram.

Additional Tracking Items

Type Issue number Title Report Status

Section

LER 05000458/2017-007-00 Automatic Reactor Scram 71153 Closed

Due to Failure of Main

Generator Voltage Regulator

Mode Transfer Relay

LER 05000458/2017-008-00 Automatic Reactor Scram 71153 Closed

Due to Failure of Main

Feedwater Regulator

Transfer Relay

PLANT STATUS

River Bend Station began the inspection period at rated thermal power. On January 8, 2018,

the unit was shut down for a planned maintenance outage. A reactor startup was performed on

January 30, 2018. The unit was shut down to conduct a forced outage on February 1, 2018,

due to an unexpected trip of the B reactor recirculation pump. A reactor startup was performed

on February 9, 2018. The unit was shut down to conduct a forced outage on March 1, 2018,

due to a pipe leak associated with the main condenser. A reactor startup was performed on

March 6, 2018. The unit was returned to rated thermal power on March 20, 2018. The unit

remained at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in

effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with

their attached revision histories are located on the public website at http://www.nrc.gov/reading-

rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared

complete when the IP requirements most appropriate to the inspection activity were met

consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection

Program - Operations Phase. The inspectors performed plant status activities described in

IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem

Identification and Resolution. The inspectors reviewed selected procedures and records,

observed activities, and interviewed personnel to assess licensee performance and compliance

with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.04Equipment Alignment

Partial Walkdown (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) Division I residual heat removal system on January 25, 2018

(2) Division II residual heat removal system on January 25, 2018

(3) Control building heating, ventilation, and air conditioning (HVAC) system on

March 15, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the standby

service water system on March 8, 2018.

71111.05AQFire Protection Annual/Quarterly

Quarterly Inspection (4 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) Residual heat removal pump A room, fire area AB-5 on January 25, 2018

(2) Residual heat removal pump B room, fire area AB-3 on January 25, 2018

(3) Standby service water pump A room, fire area PH-1/Z-1on March 12, 2018

(4) Standby service water pump B room, fire area PH-2/Z-1 on March 12, 2018

71111.06Flood Protection Measures

Internal Flooding (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the standby service

water pump rooms, SW-01 on January 12, 2018.

Cables (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Electrical manhole 1EMH607 on January 16, 2018

(2) Electrical manhole 1EMH613 on January 16, 2018

71111.11Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated licensed operator requalification training on

February 6, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated the operators performance during a plant shutdown for

a planned maintenance outage on January 7, 2018.

71111.12Maintenance Effectiveness

Routine Maintenance Effectiveness (3 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions:

(1) Functional failure review of standby service water on January 16, 2018

(2) Functional failure review of the 120 VAC system on February 19, 2018

(3) Functional failure review of the reactor recirculation system associated with the failure of

the B recirculation pump to upshift to fast speed on March 1, 2018

71111.13Maintenance Risk Assessments and Emergent Work Control (4 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) Yellow shutdown risk condition with containment access hatch open on January 8, 2018

(2) Yellow risk condition due to fuel movement and Division III emergency diesel generator

inoperability while in Mode 5 on January 24, 2018

(3) Yellow risk condition due to high pressure core spray pump inoperability during remote

shutdown panel surveillance testing on February 23, 2018

(4) Yellow risk condition due to residual heat removal pump B discharge flow inoperability

during maintenance and testing on March 15, 2018

71111.15Operability Determinations and Functionality Assessments (5 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) E31-N604F main steam line tunnel temperature exceeded allowable values per

surveillance test requirements on January 3, 2018

(2) Jacket water leaks associated with Division I emergency diesel generator on

January 5, 2018

(3) Unexpected system response during Division II standby service water surveillance

testing on January 15, 2018

(4) Residual heat removal shutdown cooling outboard isolation valve E12-MOVF008

over-torqued on February 19, 2018

(5) Division I inverter DNB-INV01A1 system output voltage exceeded max allowable voltage

on March 20, 2018

71111.18Plant Modifications (1 Sample)

The inspectors evaluated the following permanent modification:

(1) Division I standby diesel generator exhaust manifold piping to eliminate a vulnerability to

flaw formation and leakage after Division I emergency diesel generator shroud

replacement on January 19, 2018

71111.19Post Maintenance Testing (7 Samples)

The inspectors evaluated the following post maintenance tests:

(1) STP-209-6310, Revision 39, RCIC Pump and Valve Quarterly Operability and Flow

Test, following maintenance on the reactor core isolation cooling governor valve on

January 5, 2018

(2) STP-504-4504, Revision 18, RPS/Control Rod Block - IRM D Channel Functional Test

and LSFT, following replacement of intermediate range monitor D control relay

H13-P672-Z2K18 on January 13, 2018

(3) STP-309-0206, Revision 29, Division I Diesel Generator 184 Day Operability Test,

following maintenance on Division I emergency diesel generator on January 22, 2018

(4) STP-309-0203, Revision 329, Division III Diesel Generator Operability Test, following

replacement of the Division III emergency diesel generator voltage regulator on

January 24, 2018

(5) STP-504-4503, Revision 20, RPS/Control Rod Block - IRM C Channel Functional Test

and LSFT, following maintenance on intermediate range monitor C on January 30, 2018

(6) SOP-0030, Revision 33, High Pressure Core Spray System (Sys 203), following

maintenance on high pressure core spray motor supply breaker on February 22, 2018

(7) STP-256-6603, Revision 21, Division I Standby Service Water Quarterly Valve

Operability Test, following maintenance and repairs to standby service water valve

SWP-MOV96A on March 5, 2018

71111.20Refueling and Other Outage Activities (3 Samples)

(1) The inspectors evaluated a planned maintenance outage implemented to remove

damaged fuel assemblies. Inspection activities occurred from January 8, 2018, to

January 31, 2018.

(2) The inspectors evaluated forced outage activities from February 1, 2018, to

February 9, 2018. The forced outage occurred due to a failure of the B reactor

recirculation pump to shift to fast speed. Station personnel conducted a forced outage

and replaced the 13.8 kV transformer associated with the B reactor recirculation

pump.

(3) The inspectors evaluated forced outage activities from March 1, 2018, to

March 7, 2018. The forced outage occurred due to a leak from a crack on piping

associated with the main condenser. Station personnel conducted a forced outage

and repaired the leak.

71111.22Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (3 Samples)

(1) STP-203-1302, Revision 25, E22-S001BAT Quarterly Surveillance, on

January 18, 2018

(2) STP-057-3801, Revision 012, Containment Equipment Hatch Leak Rate Test, on

January 27, 2018

(3) OSP-0604, Revision 2, Remote Shutdown System Control Circuit Operability Test, on

February 26, 2018

In-service (2 Samples)

(1) STP-204-1300, Revision 18, LPCI Pump A Start Time Delay Channel Calibration and

Channel Functional Test, on January 2, 2018

(2) STP-256-6301, Revision 23, Division I Standby Service Water Quarterly Valve

Operability Test, on January 6, 2018

Reactor Coolant System Leak Detection (1 Sample)

(1) STP-000-0001, Revision 082, Daily Operating Logs, on January 4, 2018

Containment Isolation Valve (1 Sample)

(1) STP-057-7705, Revision 012, Primary Containment Airlocks Seal Leakage Rate Test,

on January 28, 2018

71114.06Drill Evaluation

Drill/Training Evolution (1 Sample)

The inspectors evaluated a simulator-based emergency preparedness drill on

March 13, 2018.

RADIATION SAFETY

71124.02Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls

Radiological Work Planning (1 Sample)

The inspectors evaluated the licensees radiological work planning by reviewing the

following activities:

(1) RWP 2017-1220, Pre/Post Outage Prep Including Support

(2) RWP 2017-1296, RWCU Pump Replacement and Support Activities

(3) RWP 2017-1426, Motor Operated Valve and In-Vessel Testing

(4) RWP 2017-1436, Installation/Removal of Temporary Installation Main Steam Tunnel

(5) RWP 2017-1753, RWCU Hx Room Flow Accelerated Corrosion (FAC) Piping

Replacement

(6) RWP 2017-1800, RF-19 Refuel Floor Outage Activities

(7) RWP 2018-1327, Separator Repair Following SHZAM Bolt Disengagement

Verification of Dose Estimates and Exposure Tracking Systems (1 Sample)

The inspectors evaluated dose estimates and exposure tracking.

Implementation of ALARA and Radiological Work Controls (1 Sample)

The inspectors reviewed ALARA practices and radiological work controls by reviewing the

following activities:

(1) RWP 2017-1220, Pre/Post Outage Prep Including Support

(2) RWP 2017-1296, RWCU Pump Replacement and Support Activities

(3) RWP 2017-1426, Motor Operated Valve and In-Vessel Testing

(4) RWP 2017-1436, Installation/Removal of Temporary Installation Main Steam Tunnel

(5) RWP 2017-1753, RWCU HX Room FAC Piping Replacement

(6) RWP 2017-1800, RF-19 Refuel Floor Outage Activities

(7) RWP 2018-1327, Separator Repair Following SHZAM Bolt Disengagement

Radiation Worker Performance (1 Sample)

The inspectors evaluated radiation worker and radiation protection technician performance.

71124.04 - Occupational Dose Assessment

Source Term Characterization (1 Sample)

The inspectors evaluated the licensees source term characterization.

External Dosimetry (1 Sample)

The inspectors evaluated the licensees external dosimetry program.

Internal Dosimetry (1 Sample)

The inspectors evaluated the licensees internal dosimetry program.

Special Dosimetric Situations (1 Sample)

The inspectors evaluated the licensees performance for special dosimetric situations.

OTHER ACTIVITIES - BASELINE

71151Performance Indicator Verification (3 Samples)

The inspectors verified licensee performance indicators submittals listed below:

(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (01/01/2017 - 12/31/2017)

(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (01/01/2017 -

2/31/2017)

(3) IE04: Unplanned Scrams with Complications (USwC) Sample (01/01/2017 -

2/31/2017)

71152Problem Identification and Resolution

Annual Follow-up of Selected Issues (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issue:

(1) Relay failures in the feedwater level control system and the turbine generator voltage

regulator control system resulted in reactor scrams

71153Follow-up of Events and Notices of Enforcement Discretion

Licensee Event Reports (2 Samples)

The inspectors evaluated the following licensee event reports which can be accessed at

https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report 05000458/2017-007-00, Automatic Reactor Scram Due to

Failure of Main Generator Voltage Regulator Mode Transfer Relay on August 21, 2017

(2) Licensee Event Report 05000458/2017-008-00, Automatic Reactor Scram Due to

Failure of Main Feedwater Regulator Transfer Relay on October 12, 2017

INSPECTION RESULTS

Failure to Implement Procedure for Storage of Material in the Pools

Cornerstone Significance Cross-cutting Report Section

Aspect

Occupational Green [H.4] - Human 71124.02 -

Radiation Safety NCV 05000458/2018001-01 Performance, Occupational

Closed Teamwork As Low As

Reasonably

Achievable

(ALARA)

Planning and

Controls

The inspector identified a non-cited violation of Technical Specification 5.4.1.a, for the

licensees failure to implement written procedures for activities referenced in Appendix A of

Regulatory Guide 1.33, Revision 2, dated February 1978. Specifically, the licensee failed to

implement radioactive material control Procedure ADM-0071, Fuel Pools Material Control,

Revision 8, for the storage and movement of spent Tri-Nuke filters.

Description:

The inspector reviewed condition reports (CRs) that documented incidents associated with the

movement and storage of highly radioactive materials in the various pools at River Bend

Station (RBS) in 2017. Four radiological occurrences involved unplanned and unanticipated

movements of spent Tri-Nuke filters around the separator and upper inclined fuel transfer

storage (IFTS) pools.

• January 5, 2017, CR-RBS-2017-0100: Radiation Protection (RP) was notified that

a spent Tri-Nuke filter was found floating on the surface of the separator pool.

Surveys of the filter and surrounding area were performed by RP technicians.

Dose rates on the filter measured 2.2 Roentgen/hour (R/hr) on contact and

0.85 R/hr at 30 centimeters (cm).

• April 3, 2017, CR-RBS-2017-03011: A used Tri-Nuke filter measuring 1.3 R/hr and

0.350 R/hr at 30 cm was discovered floating in the reactor building (RB)-186

separator pool.

• April 24, 2017, CR-RBS-2017-03424: While performing video surveillance of the

refueling pool on RB-186, a Tri-Nuke filter was discovered floating on the surface of

the separator pool. The filter had a dose rate of 11 R/hr on contact and 6 R/hr at

cm.

• During the week of April 27, 2017, the licensee transferred the 30 Tri-Nuke filters

from the separator pool to the IFT

S. However, one of the Tri-Nuke filters

(0.300 R/hr) had been damaged when falling into the bottom of the IFTS pool. It

was eventually recovered and stored.

The inspector examined the circumstances that caused the Tri-Nuke filters to become buoyant

and float around the separator pool resulting in unintended radiological hazards. Two CRs

from 2015 (CR-RBS-2015-07893 and CR-RBS-2015-08050) identified concerns with air

intrusion from a leaky spent fuel cooling system valve. Also, two CRs from 2017

(CR-RBS-2017-01881 and CR-RBS-2017-03424) identified that the leaky valve caused spent

Tri-Nuke filters to float. The licensee eventually determined the solution to the problem was to

transfer the spent Tri-Nuke filters to the upper IFTS pool. However, the inspector determined

that the licensee was not supposed to leave the spent Tri-Nukes in the separator and upper

IFTS pools unless designed storage racks were in place or an engineering change request

(ECR) evaluation allowed the practice.

The movement and storage of radioactive material in and around the pools at RBS are

implemented through the following procedures:

• EN-RP-121, Revision 13, Radioactive Material Control

• EN-RP-123, Revision 1, Radiological Controls of Highly Radioactive Objects

• ADM-0071, Revision 8, Fuel Pools Material Control

The inspector determined that the purpose of Entergy Corporate Procedures EN-RP-121 and

EN-RP-123 was to prevent the unauthorized movement and removal of radioactive materials

around the site and from pools. These procedures required that licensee personnel receive

proper authorization from reactor engineering and radiation protection management for

movement and storage of radioactive materials in pools and the around pools. Based on the

documents and procedures reviewed by the inspector, the licensee did not specify storage

requirements or equipment for these filters to prevent them from floating to the top of the pools

and becoming radiological hazards.

The inspector reviewed RBS site-specific Procedure ADM-0071, Revision 8, which described

the requirements established for the control of miscellaneous material stored in fuel pools. At

RBS, radioactive materials are stored in the following seven pools: spent fuel pool, cask pool,

lower IFTS, upper IFTS, upper containment pool, dryer storage pool, and separator pool.

ECR RBS-ER-97-504, Fuel Pool Inventory Identification, Justification, and Evaluation, dated

September 30, 1997, stated that the purpose of ADM-0071 was to provide a means to

adequately control, regulate, and inventory non-special nuclear material stored in the spent

fuel pool and upper containment pools. Items may not be stored in the spent fuel storage

upper containment pools, which includes the separator pool, without design engineering

approval. Additionally, items that are not stainless steel or in a stainless steel container are

not to be stored without being verified radiation resistant and not detrimental to the fuel pool

water quality.

Section 7.3 of Procedure ADM-0071 provided instructions for storing or moving material within

the same pool or to another pool location. Section 7.3.7 required that the pool material

inventory POOL MATERIAL CONTROL FORM be completed and updated after approval of

the material storage/move by the reactor engineering manager and radiation protection

superintendent. The form required specific information about proposed items to be stored,

such as the radiation surveys taken, work order used, storage container location, special

requirements, radiation exposure duration, and applicable ECR evaluations. At the time of this

inspection, the licensee did not have any pool material control forms completed for the 30 Tri-

Nuke filters that were placed into the separator pool and subsequently transferred to the IFTS

in 2017. In particular, there was no pool material control forms signed by the reactor

engineering manager and radiation protection superintendent approving the proper storage

and movement of these Tri-Nuke filters for either location.

Procedure ADM-0071 allowed miscellaneous items such as Tri-Nuke filters to be stored in the

separator and IFTS pools if an ECR evaluation and engineering approval on the storage

method were done. The inspector queried whether any ECRs had been performed for storage

of the Tri-Nuke filters. Only two were available for the inspectors review. The two ECRs

(ECR RBS-ER-97-504 and ECR 33163) revealed that the licensee had not made specific

provisions or performed evaluations for the storage of Tri-Nuke filters in the separator or upper

IFTS pools.

The inspector determined that licensees procedures did not adequately address securing

highly radioactive material in pools such as Tri-Nuke filters to prevent radioactive material from

floating to the pool surface and thereby becoming radiation hazards to personnel, as had

occurred three times in early 2017. Further, the failure to follow the requirements of

Procedure ADM-0071 resulted in bypassing the performance of an evaluation to ensure proper

movement and storage of the filters.

Corrective Actions: Immediate safety concerns with filters becoming buoyant due to the air

intrusion in the separator pool were addressed when the licensee transferred the 30 Tri-Nuke

filters to the IFTS pool in late April 2017. Procedure compliance issues are being addressed

through an action item in CR-RBS-2018-00523.

Corrective Action References: CR-RBS-2018-00523

Performance Assessment:

Performance Deficiency: The licensees failure to implement written procedures for activities

referenced in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978, as

required by Technical Specification 5.4.1.a, was a performance deficiency. Specifically, the

licensee failed to implement radioactive material control Procedure ADM-0071, Fuel Pools

Material Control, Revision 8, for the storage and movement of spent Tri-Nuke filters.

Screening: The performance deficiency was more than minor because it adversely affected

the programs and process (exposure control) attribute of the Occupational Radiation Safety

Cornerstone and its objective to ensure the adequate protection of the worker health and

safety from exposure to radiation from radioactive material. Specifically, allowing highly

radioactive material (Tri-Nuke filters) to be moved and stored in an unsafe, unevaluated,

unapproved manner resulted in unanticipated dose rates and unplanned worker exposures to

radiation.

Significance: The inspectors assessed the significance of the finding using NRC Inspection

Manual Chapter 0609, Appendix, C, Occupational Radiation Safety Significance

Determination Process, and determined that the finding was of very low safety significance

(Green) because it did not: (1) involve ALARA planning or work controls, (2) did not involve

an overexposure, (3) did not have a substantial potential to be an overexposure, and (4) the

ability to assess dose was not compromised.

Cross-cutting Aspect: The finding has a cross-cutting aspect in the area of human

performance, associated with teamwork, because individuals and work groups failed to

communicate and coordinate their activities within and across organizational boundaries to

ensure nuclear safety was maintained. Specifically, the communication and coordination of

activities between construction projects, health physics, and nuclear engineering failed to

prevent radiological issues associated with the storage and movement of Tri-Nuke filters.

Enforcement:

Violation: Technical Specification 5.4.1.a requires, in part, that procedures be written,

implemented, and established for those areas recommended in Regulatory Guide 1.33,

Appendix A, Revision 2, 1978. Section 7(b) of Regulatory Guide 1.33, Appendix A, requires

procedures for control of radioactive materials to minimize potential releases to the

environment and control personnel exposure associated with solid radioactive waste.

Licensee Procedure ADM-0071, Fuel Pools Material Control, Revision 8, Section 7.1,

requires that if material must be stored in a pool or previously stored material must be moved

from one pool to a different pool or to a different area in the same pool, Section 7.3 must be

completed. Section 7.3.7 requires that the pool material inventory POOL MATERIAL

CONTROL FORM be updated after approval of the material storage/move by the reactor

engineering manager and radiation protection superintendent.

Contrary to the above, beginning in 2017 and to present, the licensee stored material in a

pool and moved previously stored material from one pool to a separate pool without

completing Section 7.3 of Procedure ADM-0071. Specifically, the licensee stored 30 Tri-Nuke

filters in the separator pool without completing the pool material Inventory form and, in

April 2017, moved the filters to the incline fuel transfer storage pool without completing/

updating a pool material Inventory POOL MATERIAL CONTROL FORM and obtaining the

required approvals.

As of January 26, 2018, the licensee had not fully implemented Section 7.3 of

Procedure ADM-0071 by updating the form and obtaining written approval from the radiation

protection superintendent and reactor engineering manager for the movement and safe

storage of the 30 Tri-Nuke filters in the incline fuel transfer storage pool.

Disposition: This violation is being treated as a non-cited violation consistent with

Section 2.3.2.a of the NRC Enforcement Policy.

Installation of an Incorrectly Specified Relay Causes Plant Transient and Reactor Scram

Cornerstone Significance Cross-cutting Report

Aspect Section

Initiating Events Green [H.5] - Human 71152 -

FIN 05000458/2018001-02 Performance, Problem

Closed Work Identification

Management and

Resolution

The inspectors reviewed two examples of a self-revealed finding for the licensees installation

of an incorrectly specified relay in 1) the control circuitry for the feedwater level control system

and 2) the turbine generator voltage regulator circuitry. In each instance, the incorrectly

specified relay failed in service, causing a plant transient and automatic reactor scram.

Description:

Example 1: On August 18, 2017, with the plant operating at 100 percent power, an automatic scram occurred. At the time of the scram, operators were performing a scheduled

surveillance test that called for a planned shift of the controlling channel of the feedwater level

control system from channel B to channel

A. Immediately after the shift, feedwater regulating

valves went full open and recirculation pumps downshifted to slow speed. The combination

of these events caused an automatic scram to occur on high flow-biased thermal power.

The cause of the scram was a failure of the feedwater level select relay, C33A-K12. The

failure of this relay caused the interpreted level in the feedwater level control system to go to

zero, which in turn caused a full open demand on the feedwater regulating valves and a

downshift of recirculation pumps from fast to slow speed on a perceived low level condition in

the reactor vessel.

A subsequent investigation determined that the feedwater level select relay failed due to a

degradation in the electrical contacts on the relay. The degradation caused a sharp increase

in resistance across the contacts, which in turn led to a substantial reduction in the current

passing through these contacts to the rest of the feedwater level control circuit. With the

current substantially reduced, the circuit incorrectly perceived a low vessel level condition.

The failed relay was a General Electric Agastat GPI type relay. Operating experience at

River Bend Station and at other sites in the industry has established that this type of relay is

prone to intermittent failure. When used in low current applications such as those associated

with the feedwater level control circuit, there is a potential for oxidation to build up on the

contacts of the relay, which will create resistance across the relay and impair its ability to pass

current. In light of this operating experience, the licensee issued part interchangeability

evaluation (PIE) 411 in March 1993. PIE 411 called for a GPIA type relay with gold-plated

contacts to be used for C33A-K12 in lieu of the silver-plated GPI type relay that had

traditionally been used.

The inspectors determined that PIE-411 was a self-imposed licensee standard. The licensee

complied with this standard until February 2017, when the gold-plated relay installed in the

system was incorrectly replaced with a silver-plated relay. Given that the silver-plated relay

was being used in a low current application, it built up resistance over time and eventually

failed, causing the scram.

Example 2: On June 23, 2017, with the plant operating at 100 percent power, an automatic scram occurred. At the time of the scram, operators were performing a scheduled

surveillance test that called for a planned shift of the turbine generator voltage regulator

control from automatic to manual. Immediately after the shift, the main generator tripped

which caused a subsequent reactor scram.

The cause of the scram was a failure of the voltage regulator transfer circuit relay,

EXS-PNL1-43A. The failure of this relay caused an open circuit in both the manual and

automatic voltage regulators and complete loss of control of the Alterrex Excitation System.

When neither the manual nor the automatic voltage regulator is connected to the Alterrex

Excitation System, there is no excitation field applied. The result is a turbine trip on loss of

excitation.

A subsequent investigation determined that the main generator voltage regulator mode

transfer relay failed due to a degradation in the electrical contacts on the relay. The

degradation caused a sharp increase in resistance across the contacts, which in turn led to a

substantial reduction in the current passing through these contacts to the rest of the voltage

regulator control circuit. With the current substantially reduced, the circuit could not be

completed for either the manual or automatic control system of the turbine voltage regulator.

The failed relay was a General Electric DC operated 4-pole double throw miniature 43A relay

provided as part of the turbine generator package and is part of the Alterrex exciter transfer

panel assembly. Operating experience at River Bend Station and at other sites in the

industry has established that this type of relay is prone to intermittent failure. The station

generated engineering change 40442 in 2012 to replace the 43A relay with a different model

documenting obsolescence of this relay as well as operating experience related to intermittent

failures of this type of relay. In light of this operating experience, the licensee cancelled

engineering change 40442 for unknown reasons and did not replace the 43A relay with a

different style.

Corrective Actions: The licensee installed the correctly specified relay in the feedwater level

control system and an upgraded vendor recommended relay in the turbine voltage regulator

control system. The licensee also completed an extent of condition review on similar relays.

Corrective Action References: Condition Reports CR-RBS-2017-06118 and

CR-RBS-2017-04961

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees installation of an

incorrectly specified relay in 1) the control circuitry for the feedwater level control system and

2) the control circuitry for the main generator voltage regulator were two examples of a

performance deficiency.

Screening: The performance deficiency was more than minor, and therefore a finding,

because it was associated with the equipment performance attribute of the Initiating Events

Cornerstone and adversely affected the cornerstone objective to limit the likelihood of events

that upset plant stability and challenge critical safety functions during shutdown as well as

power operations.

Significance: The inspectors assessed the significance of the finding using Inspection

Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-

Power. The finding was determined to be of very low safety significance (Green) because

the finding did not contribute to both the likelihood of a reactor trip and the likelihood that

mitigating equipment would not be available.

Cross-cutting Aspect: The finding has a cross-cutting aspect in the area of human

performance associated with work management because the licensee failed to implement a

process of planning, controlling, and executing work activities such that nuclear safety is the

overriding priority.

Enforcement: Inspectors did not identify a violation of regulatory requirements associated

with this finding.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On January 26, 2018, the inspectors presented the radiation safety inspection results to

Mr.

W. Maguire, Site Vice President, and other members of the licensee staff.

On April 25, 2018, the inspectors presented the quarterly resident inspector inspection results to

Mr.

W. Maguire, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

71111.04 - Equipment Alignment

Condition Reports (CR-RBS-)

2017-05292 2017-07460 2017-07880 2018-00615

2018-00992

Drawings

Number Title Revision

PID-09-10E Engineering P&I Diagram, System 256, Service 24

Water - Standby

PID-22-09A Engineering P&I Diagram, System 402, HVAC - 21

Control Building

Procedures

Number Title Revision

R-STM-0118 Service Water Systems 26

R-STM-0402 HVAC - Control Building and Diesel Generator 9

Building

SOP-0031 Residual Heat Removal 338

SOP-0042 Standby Service Water System (Sys #256) 46

SOP-0058 Control Building HVAC System (Sys #402) 24

71111.05 - Fire Protection

Procedures

Number Title Revision

AB-070-502 RHR Pump A Room, Fire Area AB-5 4

AB-070-505 RHR Pump B Room, Fire Area AB-3 3

EN-DC-161 Control of Combustibles 17

SP-118-450 Standby Cooling Pump A Room, Fire Area PH-1/Z-1 3

SP-118-451 Standby Cooling Pump B Room, Fire Area PH-2/Z-1 3

STP-250-4533 FPM-PNL6 Fire Detection Channel Functional and 1

Operational Tests for Zone SD72, SD73, and SD89

(A&B)

71111.06 - Flood Protection Measures

Condition Reports (CR-RBS-)

2018-00200 2018-00367 2018-00369

Procedure

Number Title Revision

PN-317 Max Flood Elevations for Moderate Energy Line 01

Cracks in Cat I Structures

Work Orders

0052802383 0052802384

71111.11 - Licensed Operator Requalification Program and Licensed Operator

Performance

Procedures

Number Title Revision

GOP-0002 Power Decrease/Plant Shutdown 078

RSMS-OPS-HIT1 Licensed Operator Requalification 0

71111.12 - Maintenance Effectiveness

Condition Reports (CR-RBS-)

2017-00629 2017-01579 2017-01668 2017-01703

2017-01739 2017-01748 2017-01749 2017-03871

2017-04048 2017-04514 2017-05273 2017-05939

2017-06767 2017-06977 2017-06998 2017-07017

2017-07200 2017-07410 2017-07454 2017-07820

2017-07880 2017-07950 2018-00825 2018-01363

Procedures

Number Title Revision

EN-DC-203 Maintenance Rule Program 3

EN-DC-204 Maintenance Rule Scope and Basis 4

EN-DC-205 Maintenance Rule Monitoring 6

EN-DC-206 Maintenance Rule (A)(1) Process 3

Procedures

Number Title Revision

SOP-0042 Standby Service Water System (Sys #256) 45

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Condition Report (CR-RBS-)

2018-00505

Procedures

Number Title Revision

ADM-0096 Risk Management Program Implementation and 326

On-Line Maintenance Risk Assessment

EN-WM-104 On Line Risk Assessment 16

OSP-0037 Shutdown Operations Protection Plan (SOPP) 036

71111.15 - Operability Determinations and Functionality Assessments

Condition Reports (CR-RBS-)

2016-05866 2017-04048 2017-04097 2017-04302

2017-05033 2017-07111 2017-07162 2017-07199

2017-07219 2017-07532 2017-08048 2018-00194

2018-00402

Miscellaneous

Number Title Revision

EC 66261 SWP-SOV523B Reasonable Expectation of 0

Operability Input for CR-RBS-2016-05866

Procedures

Number Title Revision

OSP-0028 Log Report - Normal Switchgear, Control, and 108

Diesel Generator Buildings

STP-000-0001 Daily Operating Logs 82

STP-256-6608 Division II Standby Service Water 2 Year Position 4

Indication Verification Test

STP-309-0201 Division I Diesel Generator Operability Test 59

Work Orders

00469400 00476322 00479296

71111.18 - Plant Modifications

Calculation

Number Title Revision

G13.18.2.4-108 LPI, Inc. Evaluation of Standby Diesel Generator 1

Exhaust Manifold Stiffeners

Condition Reports (CR-RBS-)

2015-04817 2016-06841 2016-07753 2017-07111

2017-07532 2017-08048

Drawing

Number Title Revision

PID-08-09B Engineering P&I Diagram System 309 Diesel 23

Generator

Procedure

Number Title Revision

SOP-0053 Standby Diesel Generator and Auxiliaries 057

(Sys #309)

Work Order 228397

71111.19 - Post-Maintenance Testing

Condition Reports (CR-RBS-)

2017-07237 2017-07728

Miscellaneous

Number Title Revision/Date

E22-S004 ACB2 Vendor Overhaul Breaker 0

Procedures

Number Title Revision

CMP-EM-203-1001 Inspection and Maintenance of 4.16 KV 1

Magne-Blast Circuit Breakers

STP-209-0201 RCIC Discharge Piping Fill and Valve Lineup 13

Verification

Work Orders

228397 00478865 00492550 00493155 00493741

2650988 52769345 52779858

71111.20 - Refueling and Other Outage Activities

Procedures

Number Title Revision

GOP-0001 Plant Startup 099

GOP-0002 Power Decrease/Plant Shutdown 078

71111.22 - Surveillance Testing

Condition Reports (CR-RBS-)

2015-02736 2018-00290

Drawing

Number Title Revision

GE-828E534AA Elementary Diagram Residual Heat Removal 28

Sheet 8

Procedures

Number Title Revision

SOP-0018 Normal Service Water System 67

SOP-0042 Standby Service Water System 45

Work Orders

00492725 52785880 52787021

71114.06 - Drill Evaluation

Miscellaneous

Number Title Revision

RDRL-EP-1201 Site Drill Scenario 01

71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and

Controls

Audits and Self-Assessments

Number Title Date

LO-RLO-2017-0055 Pre-NRC Self-Assessment Radiation Safety - December 4, 2017

IP 71124.02

LO-RLO-2016-0145 Pre-NRC Self-Assessment Radiation Safety - January 17, 2017

IP 71124.02

Condition Reports (CR-RBS-)

2015-07893 2015-08050 2017-00100 2017-00707

2017-00868 2017-01250 2017-01355 2017-01731

2017-01881 2017-01927 2017-03011 2017-03237

2017-03266 2017-03424 2017-03598 2017-03788

2017-04856 2017-04941 2017-05499 2017-01372

2017-01422

Miscellaneous

Number Title Date

RF-19 Water Movement Plan January 2017

CFR Part 20.1101(c) Report for 2016 June 2017

ADM-0071 Post Material Inventory Report Post RF-19 May 31, 2017

WO 473593 Relocate Tri-Nuke filters from the Separator Pool April 11, 2017

the IFTS

Procedures

Number Title Revision

ADM-0071 Fuel Pools Material Control 08

EN-RP-100 Radiation Worker Expectations 12

EN-RP-101 Access Control for Radiologically Controlled Areas 13

Procedures

Number Title Revision

EN-RP-102 Radiological Control 05

EN-RP-105 Radiological Work Permits 18

EN-RP-106 Radiological Survey Documentation 07

EN-RP-108 Radiation Protection Posting 19

EN-RP-109 Hot Spot Program 05

EN-RP-110 ALARA Program 14

EN-RP-110-03 Collective Radiation Exposure (CRE) Guidelines 04

EN-RP-110-04 Radiation Protection Risk Assessment Process 07

EN-RP-110-06 Outage Dose Estimating and Tracking 01

EN-RP-115-01 BRAC Survey Instructions 00

EN-RP-121 Radioactive Material Control 13

EN-RP-123 Radiological Controls for Highly Radioactive 01

Objects

EN-RP-143 Source Control 13

EN-RP-151 Radiological Diving 03

GMP-0111 Tri-Nuclear Filter Operations 01

Radiation Surveys

Number Title Date

RBS-1701-0042 RB +186 Upper Pool HCA Handrail January 5, 2017

RBS-1703-0124 RB +186 Upper Pool and Carousel Area March 5, 2017

RBS-1704-0059 RB +186 Upper Pool 354 R/hr. Tri-Nuke Filter April 5, 2017

RBS-1704-0248 RB +186 Upper Pool 11 R/hr. Tri-Nuke Filter April 21, 2017

RBS-1704-0303 RB +186 Upper Pool 24 Tri-Nuke Filters April 21, 2017

Radiation Work Permits/ALARA Reviews

Number Title Revision

2017-1220 Pre/Post Outage Prep Including Support 01

2017-1296 RWCU Pump Replacement and Support Activities 01

2017-1426 Motor Operated Valve and In-Vessel Testing 01

Radiation Work Permits/ALARA Reviews

Number Title Revision

2017-1436 Installation/Removal of Temporary Installation Main 01

Steam Tunnel

2017-1753 RWCU HX Room FAC Piping Replacement 01

2017-1800 RF-19 Refuel Floor Outage Activities 01

2018-1327 Separator Repair Following SHZAM Bolt 00

Disengagement

71124.04 - Occupational Dose Assessment

Audits and Self-Assessments

Number Title Date

LO-RBS-2017-00055 Pre-NRC Assessment IP71124.04 October 27, 2017

Occupational Dose

Condition Reports (CR-RBS-)

2016-05858 2017-08105 2017-00707 2017-00868

2017-00910 2017-03788 2017-05176 2017-05489

Miscellaneous

Number Title Date

2017 Multi-Pack TLD Results 2017

2018 NVLAP Accreditation Report 2018

Procedures

Number Title Revision

EN-RP-131 Air Sampling 15

EN-RP-201 Dosimetry Administration 05

EN-RP-202 Personnel Monitoring 13

EN-RP-203 Dose Assessment 10

EN-RP-204 Special Monitoring Requirements 11

EN-RP-205 Prenatal Monitoring 04

EN-RP-206 Dosimeter of Legal Record QA 07

EN-RP-208 Whole Body Counting / In-Vitro Bioassay 07

Procedures

Number Title Revision

EN-RP-311 Electronic Alarming Dosimeter 02

EN-RP-317-09 Electronic Alarming Dosimeter Calibration 02

Self-Reading Dosimeter Calibration Records

Number Title Date

2017-B2-28- Self-Reading Dosimeter September 18, 2017

CALDAT-05667

2017-B2-28- Self-Reading Dosimeter September 30, 2017

CALDAT-05713

2017-B2-28- Self-Reading Dosimeter September 30, 2017

CALDAT-05736

2017-B2-28- Self-Reading Dosimeter September 26, 2017

CALDAT-05836

2017-B2-28- Self-Reading Dosimeter December 15, 2017

CALDAT-06692

71151 - Performance Indicator Verification

Procedures

Number Title Revision

EN-LI-114 Performance Indicator Process 11

NEI 99-02 Regulatory Assessment Performance Indicator 7

Guideline

71152 - Problem Identification and Resolution

Condition Reports (CR-RBS-)

2017-06118 2017-04961

71153 - Follow-up of Events and Notices of Enforcement Discretion

Condition Report (CR-RBS-)

2017-06118

Miscellaneous

Number Title Revision

PIE-411 Part Interchangeability Evaluation 411 0

Procedure

Number Title Revision

EN-MA-101 Conduct of Maintenance 22

Work Order 00441196

The following items are requested for the

Occupational Radiation Safety Inspection

at River Bend Station

January 22-25, 2018

Integrated Report 2018001

Inspection areas are listed in the attachments below.

Please provide the requested information on or before January 12, 2018.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

1- A, applicable organization charts in file/folder 1- B, etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Louis Carson at (817) 200-1221 or

Louis.Carson@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.

2. Occupational ALARA Planning and Controls (71124.02)

Date of last inspection: January 21, 2016

A. List of contacts and telephone numbers for ALARA program personnel

B. Applicable organization charts

C. Copies of audits, self-assessments, and LERs, written since date of last inspection,

focusing on ALARA

D. Procedure index for ALARA Program

E. Please provide specific procedures related to the following areas noted below.

Additional specific procedures may be requested by number after the inspector reviews

the procedure indexes.

1. ALARA Program

2. ALARA Committee

3. Radiation Work Permit (RWP) Preparation

F. A summary list of corrective action documents (including corporate and sub-tiered

systems) written since date of last inspection, related to the ALARA program. In addition

to ALARA, the summary should also address RWP violations, electronic dosimeter

alarms, and RWP dose estimates

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G. List of work activities greater than 1 rem, since date of last inspection,

Include original dose estimate and actual dose.

H. Site dose totals and 3-year rolling averages for the past 3 years (based on dose of

record)

I. Outline of source term reduction strategy

J. If available, provide a copy of the ALARA outage report for the most recently completed

outages for each unit

K. Please provide your most recent Annual ALARA Report.

4. Occupational Dose Assessment (Inspection Procedure 71124.04)

Date of Last Inspection: January 21, 2016

A. List of contacts and telephone numbers for the following areas:

1. Dose Assessment personnel

B. Applicable organization charts

C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs

written since date of last inspection, related to:

1. Occupational Dose Assessment

D. Procedure indexes for the following areas:

1. Occupational Dose Assessment

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Radiation Protection Program

2. Radiation Protection Conduct of Operations

3. Personnel Dosimetry Program

4. Radiological Posting and Warning Devices

5. Air Sample Analysis

6. Performance of High Exposure Work

7. Declared Pregnant Worker

8. Bioassay Program

F. List of corrective action documents (including corporate and sub-tiered systems) written

since date of last inspection, associated with:

1. National Voluntary Laboratory Accreditation Program (NVLAP)

2. Dosimetry (TLD/OSL, etc.) problems

3. Electronic alarming dosimeters

4. Bioassays or internally deposited radionuclides or internal dose

5. Neutron dose

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G. List of positive whole body counts since date of last inspection, names redacted if

desired

H. Part 61 analyses/scaling factors

I. The most recent National Voluntary Laboratory Accreditation Program (NVLAP)

accreditation report or, if dosimetry is provided by a vendor, the vendors most recent

results

ML18128A246

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: CHY/rdr Yes No Publicly Available Sensitive NRC-002

OFFICE SRI:DRP/C RI:DRP/C ARI:DRP/C SPE:DRP/C C:DRS/EB1 C:DRS/EB2

NAME JSowa BParks MOBanion CYoung TFarnholtz JDrake

SIGNATURE /RA/ /RA/ /RA-E/ /RA/ /RA/ /RA/

DATE 4/23/18 4/30/18 4/24/18 4/27/18 4/23/18 4/23/18

OFFICE C:DRS/OB C:DRS/PSB2 TL:IPAT BC:DRP/C

NAME VGaddy HGepford GGeorge JKozal

SIGNATURE /RA/ /RA/ /RA/ /RA/

DATE 4/14/18 4/23/18 4/24/18 5/08/18