IR 05000458/2019001
| ML19130A200 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 05/10/2019 |
| From: | Jason Kozal Division of Nuclear Materials Safety IV |
| To: | Vercelli S Entergy Operations |
| References | |
| IR 2019001 | |
| Download: ML19130A200 (25) | |
Text
May 10, 2019
SUBJECT:
RIVER BEND STATION - NRC INTEGRATED INSPECTION REPORT 05000458/2019001
Dear Mr. Vercelli:
On March 31, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your River Bend Station. On April 24, 2019, the NRC inspectors discussed the results of this inspection with Mr. Kent Scott, General Manager of Plant Operations, 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.
These findings involved violations of NRC requirements.
If you contest the violations or significance of the violations documented in this inspection report, 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 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 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 Reactor Projects Branch C
Docket No. 05000458 License No. NPF-47
Enclosure:
Inspection Report 05000458/2019001
Enclosure U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number(s):
05000458
License Number(s):
Report Number(s):
Enterprise Identifier: I-2019-001-0009
Licensee:
Entergy Operations, Inc.
Facility:
River Bend Station
Location:
St. Francisville, LA
Inspection Dates:
January 1, 2019 to March 31, 2019
Inspectors:
L. Merker, Senior Resident Inspector (BWR/TL)
B. Parks, Resident Inspector (BWR)
T. DeBey, Resident Inspector (BWR)
Approved By:
Jason W. Kozal
Chief, Reactor Projects Branch C
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a quarterly 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. Violations and other additional items being considered in the NRCs assessment are summarized in the table below.
List of Findings and Violations
Failure to Maintain Appropriate Surveillance and Maintenance Procedures for the Division III Emergency Diesel Generator Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2019001-01 Closed
[H.11] -
Challenge the Unknown 71152 The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to prescribe instructions appropriate to the circumstances, including appropriate quantitative or qualitative acceptance criteria, for an activity affecting quality. Specifically, instructions for surveillance and maintenance work on the turbocharger lubricating oil system of the Division III emergency diesel generator, which is an activity affecting quality, did not specify acceptance criterion for the DC lubricating pump motor continuity check nor did they require a post maintenance demonstration that the motor could run. As a result, the Division III emergency diesel generator was declared inoperable on November 28, 2018.
Inadvertent Initiation of Reactor Core Isolation Cooling due to Personnel Error Cornerstone Significance Cross-cutting Aspect Report Section Initiating Events Green NCV 05000458/2019001-02 Closed
[H.5] - Work Management 71153 The inspectors reviewed a self-revealed, Green, non-cited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to accomplish an activity affecting quality in accordance with a prescribed procedure.
Specifically, while conducting surveillance testing on the reactor core isolation cooling (RCIC)system, technicians installed an incorrect test fixture and caused an inadvertent injection of RCIC into the reactor vessel.
Additional Tracking Items
Type Issue number Title Inspection Procedure Status LER 05000458/2018-007-00 Manual Reactor Scram due to Reactor Recirculation Pump Trip Caused by Transformer Failure 71153 Closed LER 05000458/2018-008-00 Potential Loss of Safety Function and Unanalyzed Condition due to Legacy Design Deficiency in Control Building HVAC 71153 Closed LER 05000458/2018-009-00 Inadvertent Initiation of Reactor Core Isolation Cooling due to Personnel Error 71153 Closed
PLANT STATUS
River Bend Station began the inspection period at rated thermal power. On January 4, 2019, the unit was down powered to 85 percent to conduct a seal repair on main feedwater pump 1A. The unit was returned to rated thermal power on January 7, 2019. On January 12, 2019, the unit was down powered to 70 percent because of an issue with the inboard main steam isolation valve D solenoid pilot valve. The unit was returned to 75 percent power on January 13, 2019. The unit was shut down on March 30, 2019, to begin refueling outage RF-20 and remained shut down 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
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.04) (1 Sample)
The inspectors evaluated the site's readiness to cope with external flooding for the following areas:
- Control building on January 23, 2019
- Division I emergency diesel generator room on January 23, 2019
- Division II emergency diesel generator room on January 23, 2019
- Division III emergency diesel generator room on January 23, 2019
71111.04 - Equipment Alignment
Partial Walkdown (IP Section 02.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Division II 125 VDC system on January 17, 2019
- (2) Low pressure core spray system on March 7, 2019
- (3) Division I 125 VDC system on March 19, 2019
71111.04S - Equipment Alignment
Complete Walkdown (IP Section 02.02) (1 Sample)
The inspectors evaluated system configurations during a complete walkdown of the high pressure core spray system on January 30, 2019.
71111.05A - Fire Protection (Annual)
Annual Inspection (IP Section 03.02) (1 Sample)
The inspectors evaluated fire brigade performance on January 30, 2019.
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (4 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) High pressure core spray room, fire areas AB-2/Z-1 and AB-2/Z-2, on January 30, 2019
- (2) Standby liquid control area, fire area RC-4/Z-4, on January 31, 2019
- (3) Division I, II, and III battery rooms, fire areas C-18, C-19, and C-21, on February 1, 2019
- (4) Low pressure core spray pump room, fire area AB-6/Z-1, on March 7, 2019
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- High pressure core spray pump room on March 18, 2019
Inspection Activities - Underground Cables (IP Section 02.02c.) (1 Sample)
The inspectors evaluated cable submergence protection in:
- Electrical manhole EMH2A on March 14, 2019
- Electrical manhole EMH103 on March 14, 2019
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
The inspectors observed and evaluated licensed operator performance in the main control room during a reactor power maneuver on January 4, 2019.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
The inspectors observed and evaluated licensed operator requalification training in the simulator on February 12, 2019.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (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 the high pressure core spray system on March 6, 2019
- (2) Functional failure review of containment unit cooler 1A on March 21, 2019
- (3) Functional failure review of the Division I emergency diesel generator on March 25, 2019
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Yellow risk during surveillance testing of low pressure coolant injection pump A on January 8, 2019
- (2) Yellow risk during surveillance testing of reactor core isolation cooling system on January 15, 2019
- (3) Yellow risk during inspection of Division I standby service water system on February 8, 2019
- (4) Yellow risk during inspection of Division II standby service water system on February 21, 2019
71111.15 - Operability Determinations and Functionality Assessments
Sample Selection (IP Section 02.01) (5 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Division I control building air conditioning system after failure of air handling unit 2A to close electrically in the test position on March 4, 2019
- (2) Division I residual heat removal heat exchangers following thermal performance testing on March 11, 2019
- (3) Containment unit cooler 1A low air flow conditions on March 14, 2019
- (4) Division II hydrogen igniters surveillance testing results on March 21, 2019
- (5) Division II main steam positive leakage control system after failure of trip unit card on March 25, 2019
71111.19 - Post Maintenance Testing
Post Maintenance Test Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post maintenance tests:
- (1) Work Order 00514462, SVV-MOV1B Major Actuator Inspection / Div 2, following actuator inspection of main steam line pressure relief isolation valve SVV-MOV1B on February 20, 2019
- (2) Work Order 00514461, SWP-MOV503B Major Actuator Inspection / HVR-UC1B, following actuator inspection of containment unit cooler 1B return header inboard containment isolation valve SWP-MOV503B on February 20, 2019
- (3) Work Order 52829384, IAS-C2A - Perform 4,000 Hr Inspection, following 4,000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> preventive maintenance of instrument air compressor 2A on February 22, 2019
- (4) STP-403-0301, Revision 15, Containment Unit Cooler HVR-UC1A Flow Rate Verification, following cooling coil cleaning due to low air flow conditions on March 14, 2019
- (5) STP-251-3205, Revision 16, Diesel Fire Pump Operational Test, following system maintenance on fire pump engine 1B on March 18, 2019
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
In Service Testing (IST) (IP Section 03.01)
- (1) STP-201-6310, Revision 311, SLC Pump and Valve Operability Test, on January 31, 2019
- (2) STP-205-6301, Revision 25, LPCS Pump and Valve Operability Test, on March 7, 2019
Surveillance Testing (IP Section 03.01) (4 Samples)
- (1) STP-309-0201, Revision 062, Division I Diesel Generator Operability Test, on January 7, 2019
- (2) STP-256-0201, Revision 304, Div I SWP Valve Lineup Verification, on January 10, 2019
- (3) STP-051-4504, Revision 301, NSSSS-Reactor Vessel Water Level-Low Low, Level 2; Low Low Low, Level 1, Channel Functional Test (B21-N682D, B21-N681D),on January 23, 2019
- (4) STP-203-0201, Revision 308, HPCS Piping Water Fill and Valve Position Verification, on January 29, 2019
71114.06 - Drill Evaluation
Drill and/or Simulator-Based Licensed Operator Requalification Training (IP Section 02.01) (1 Sample)
The inspectors evaluated an emergency preparedness training drill on March 12,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===
(01/01/2018-12/31/2018)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)
(01/01/2018-12/31/2018)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)
(01/01/2018-12/31/2018)
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issue:
- Turbocharger lubricating oil pump failures on the Division III emergency diesel generator resulting in inoperability of the diesel generator
71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs) which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:
- (1) LER 05000458/2018-007-00, Manual Reactor Scram due to Reactor Recirculation Pump Trip Caused by Transformer Failure on February 1, 2018 (ADAMS Accession: ML18304A436):
The inspectors reviewed this LER and closed it to non-cited violation 05000458/2018012-04 issued in Inspection Report 05000458/2018012 (ADAMS Accession: ML18261A111).
- (2) LER 05000458/2018-008-00, Potential Loss of Safety Function and Unanalyzed Condition due to Legacy Design Deficiency in Control Building HVAC on September 25, 2018 (ADAMS Accession: ML18324A744):
The inspectors reviewed this LER and closed it to the licensee-identified violation issued in Inspection Report 05000458/2018003 (ADAMS Accession: ML18313A028).
- (3) LER 05000458/2018-009-00, Inadvertent Initiation of Reactor Core Isolation Cooling due to Personnel Error on November 2, 2018 (ADAMS Accession: ML19003A143):
The circumstances surrounding this LER are documented in the Inspection Results section.
INSPECTION RESULTS
Failure to Maintain Appropriate Surveillance and Maintenance Procedures for the Division III Emergency Diesel Generator Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems
Green NCV 05000458/2019001-01 Closed
[H.11] -
Challenge the Unknown 71152 The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to prescribe instructions appropriate to the circumstances, including appropriate quantitative or qualitative acceptance criteria, for an activity affecting quality. Specifically, instructions for surveillance and maintenance work on the turbocharger lubricating oil system of the Division III emergency diesel generator, which is an activity affecting quality, did not specify acceptance criterion for the DC lubricating pump motor continuity check nor did they require a post maintenance demonstration that the motor could run. As a result, the Division III emergency diesel generator was declared inoperable on November 28, 2018.
Description:
On November 28, 2018, operators in the River Bend Station (RBS) main control room received an alarm, Div III D/G System Trouble, for the Division III high pressure core spray (HPCS) emergency diesel generator. Investigation into the cause of the alarm revealed that both turbocharger lubricating oil pumps had failed, rendering the diesel generator inoperable. The inoperability lasted for about 8.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> while the oil pumps were repaired. Operability of the HPCS system during a loss of offsite power requires operability of its dedicated diesel generator. Since offsite power was available on November 28, 2018, the HPCS system remained operable. The HPCS diesel generator is one of three emergency diesel generators that are required to be operable by RBS Technical Specification 3.8.1. Per RBS Procedure SOP-0052, HPCS Diesel Generator (Sys #309), Revision 58, for Division III (HPCS) diesel generator operation, no planned starts of the engine should be performed without a turbocharger lubricating oil pump operating. The procedure also stated that if both (AC and DC-powered) turbocharger lubricating pumps are out of service, the diesel engine is not available for operation. Lubrication of the diesel engine turbocharger is supplied by an engine-driven pump while the engine is running and an AC electric pump when the engine is stopped. If the AC pump would stop while the engine is not running, a DC electric pump is designed to start so that lubricating oil flow to the turbocharger is maintained. The turbocharger lubrication system has two primary functions:
- (1) lubrication of the turbocharger bearings and
- (2) cooling of the turbocharger.
Condition Report CR-RBS-2018-06363 documented the loss of turbocharger lubricating oil flow to the HPCS diesel generator that resulted in its inoperability on November 28, 2018.
Troubleshooting by station personnel revealed that one of the two brushes on the DC lubricating pump motor was mispositioned, causing the motor to fail. Questioning from the inspectors revealed that the stations surveillance and maintenance of the DC motor was done on a biennial basis and was not appropriate to detect the mispositioned brush or to verify the ability of the motor to run after the electrical surveillance. Additionally, the licensees work order instructions were not appropriate and did not contain appropriate quantitative or qualitative acceptance criteria. Further inspector questioning revealed that the same instruction inadequacies also existed for the HPCS emergency diesel generator DC motor for the associated circulating oil lubrication system. It is likely that the DC motor was not able to operate from September 18, 2017 (the most recent inspection and preventive maintenance date), until November 28, 2018.
Corrective Actions: The licensee removed the DC motor from the diesel engine, reinstalled the mispositioned brush, returned the motor to the diesel engine, and performed a successful post maintenance test. Other corrective actions that the licensee is considering include performing monthly (vs. biennial) functional testing of the DC oil pump, requiring removal of the DC motor in order to do the brush inspections, improving the DC motor inspection process, sharing the lessons learned from this event, and revising the procedural requirement for declaring the diesel engine inoperable when the turbocharger lubricating oil flow is lost.
Corrective Action Reference: CR-RBS-2018-06363
Performance Assessment:
Performance Deficiency: The failure to prescribe instructions appropriate to the circumstances, including appropriate quantitative or qualitative acceptance criteria, for surveillance and maintenance of the turbocharger lubricating oil system of the Division III (HPCS) emergency diesel generator, resulting in inoperability of the diesel generator, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, instructions for surveillance and maintenance work on the turbocharger lubricating oil system of the Division III emergency diesel generator, which is an activity affecting quality, did not specify acceptance criterion for the DC lubricating pump motor continuity check nor did they require a post maintenance demonstration that the motor could run. As a result, the Division III emergency diesel generator was declared inoperable on November 28, 2018.
Significance: The inspectors assessed the significance of the finding using NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated July 1, 2012.
The finding was determined to be of very low safety significance (Green) because it did not represent a deficiency affecting the design or qualification of a mitigating structure, system, or component; did not represent a loss of system and/or function; did not represent an actual loss of function of at least a single train for more than its technical specification allowed outage time or two separate safety systems out-of-service for more than its technical specification allowed outage time; and did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Cross-cutting Aspect: The finding had a cross-cutting aspect in the area of human performance, challenge the unknown, because the licensee did not stop when faced with uncertain conditions, and risks were not evaluated and managed before proceeding. Specifically, the licensee did not question the lack of acceptance criterion for the DC lubricating pump motor continuity check or post maintenance demonstration that the motor could run [H.11].
Enforcement:
Violation: Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances. The instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the above, on September 18, 2017, the surveillance and maintenance procedure for the turbocharger lubricating oil system of the Division III emergency diesel generator, which is an activity affecting quality, was not appropriate to the circumstances because it did not include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Specifically, instructions for surveillance and maintenance work on the turbocharger lubricating oil system of the Division III emergency diesel generator, which is an activity affecting quality, did not specify acceptance criterion for the DC lubricating pump motor continuity check nor did they require a post maintenance demonstration that the motor could run. As a result, the Division III emergency diesel generator was declared inoperable on November 28, 2018.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Inadvertent Initiation of Reactor Core Isolation Cooling due to Personnel Error Cornerstone Significance Cross-cutting Aspect Report Section Initiating Events
Green NCV 05000458/2019001-02 Closed
[H.5] - Work Management 71153 The inspectors reviewed a self-revealed, Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to accomplish an activity affecting quality in accordance with a prescribed procedure.
Specifically, while conducting surveillance testing on the reactor core isolation cooling (RCIC)system, technicians installed an incorrect test fixture and caused an inadvertent injection of RCIC into the reactor vessel.
Description:
At 3:53 a.m. on November 2, 2018, during performance of surveillance Procedure STP-051-4524, ECCS/RCIC-Reactor Vessel Water Level-Low Low, Level 2; Low Low Low, Level 1; Channel Functional Test (B21-N692E, B21-N691E), Revision 5, RCIC initiated and began injecting water into the reactor vessel. After verifying that the initiation was inadvertent, operators tripped the RCIC turbine in accordance with Procedure AOP-0034, Inadvertent Initiation of an ECCS System or RCIC, Revision 2, and declared RCIC inoperable. Operators subsequently restored RCIC to a normal standby lineup and returned the system to operable status.
Subsequent investigation determined that technicians caused the initiation by installing an incorrect test fixture into the system. Procedure STP-051-4524, Step 7.1.9, instructed technicians to connect a red A/B contact test fixture and Simpson Multimeter to test jack E51A-J1, RCIC LOGIC A TEST. Instead of installing that contact test fixture, technicians installed a green B/C contact test fixture. The installation of the green B/C contact test fixture into jack E51A-J1 satisfied the coincidence logic for RCIC initiation, causing the inadvertent injection into the core.
The licensee conducted a review of the event and identified multiple deficiencies in the area of work management. In an attempt to recover lost time in the work schedule, the nightshift supervisor directed the technicians to perform an unusually high number of surveillance items in one shift. The supervisor assigned the items at the beginning of the shift and proceeded to focus on other plant issues for the remainder of the night, failing to sufficiently engage with and oversee the risk-significant testing that was being carried out. The technicians failed to fill out the required pre-job brief checklist and the peer reviewing technician failed to conduct an adequate peer check prior to the critical step.
Corrective Actions: The licensee restored RCIC to operable status after the event and issued corrective actions to augment supervisory oversight of pre-job briefs and testing evolutions.
Corrective Action Reference: CR-RBS-2018-05854
Performance Assessment:
Performance Deficiency: The failure to accomplish an activity affecting quality in accordance with a prescribed procedure was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor, and therefore a finding, because it was associated with the human 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. Specifically, by failing to properly complete the steps of the surveillance test procedure, the licensee caused an inadvertent RCIC injection into the reactor vessel.
Significance: The inspectors assessed the significance of the finding using NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 1, Initiating Events Screening Questions, dated June 19, 2012. The inspectors determined that the finding was of very low safety significance (Green) because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.
Cross-cutting Aspect: The finding had a cross-cutting aspect in the area of human performance, work management, because the licensee failed to implement a process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority. Specifically, the licensee conducted a risk-significant evolution with inadequate concurrent peer check and insufficient supervisory oversight [H.5].
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, on November 2, 2018, the licensee failed to accomplish an activity affecting quality in accordance with a prescribed procedure appropriate to the circumstances. Specifically, during surveillance testing of RCIC, which is an activity affecting quality, the licensee violated the surveillance test procedure by installing the wrong test fixture into the system.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On April 24, 2019, the inspector presented the quarterly resident inspector inspection results to Mr. K. Scott, General Manager of Plant Operations, and other members of the licensee staff.
DOCUMENTS REVIEWED
71111.01 - Adverse Weather Protection
Condition Reports (CR-RBS-)
2018-04723
2018-05237
2019-00366
Engineering
Reports
Number
Title
Revision
RBS-CS-15-00008 Fukushima Flooding Integrated Assessment Report
000
RBS-SA-17-00001 2017 Focused Evaluation for External Flooding
000
Procedures
Number
Title
Revision
Severe Weather Operation
040
Preparation for Mississippi River Flooding
000
71111.04 - Equipment Alignment
Condition Reports (CR-RBS-)
2016-06474
2017-08540
2018-01305
2018-01850
2018-02155
2018-02517
2018-03476
2018-03786
2018-04582
2018-05038
2018-05510
2018-05862
2019-00125
2019-01052
2019-01519
Procedures
Number
Title
Revision
Loss of 125 VDC
27
R-STM-0305
DC Distribution
006
SOP-0030
034
SOP-0032
Low Pressure Core Spray
25
SOP-0049
25 VDC System (Sys #305)
043
STP-203-0201
HPCS Piping Water Fill and Valve Position Verification
308
STP-203-6501
HPCS Pump and Valve Operability Test
2
71111.05AQ - Fire Protection Annual/Quarterly
Calculation
Number
Title
Revision
G13.18.12.2-022
River Bend Station Combustible Loading
005
Condition Reports (CR-RBS-)
2016-07444
2017-06932
2018-00526
2018-01736
2019-00347
Miscellaneous
Documents
Number
Title
Revision
Fire Brigade Drills
007
Fire Drill Scenario
007
Procedures
Number
Title
Revision
AB-070-501
LPCS Pump Room Fire Area AB-6/Z-1
004
AB-070-506
HPCS Pump Room Fire Area AB-2/Z-1
004
AB-095-517
HPCS Piping Area Fire Area AB-2/Z-2
004
CB-116-133
Battery 1A Room Fire Area C-18
004
CB-116-134
Battery 1B Room Fire Area C-19
004
CB-116-136
HPCS Battery Room Fire Area C-21
004
RB-141-008
SLC Area Fire Area RC-4/Z-4
003
STP-000-3602
Fire Barrier Visual Inspection
017
71111.06 - Flood Protection Measures
Calculations
Number
Title
Revision
PN-314
Moderate Energy Line Crack Flow Rates
PN-317
Max Flood Elevations for Moderate Energy Line Cracks
in Cat I Structures
Drawings
Number
Title
Revision
210-EB-40A-7
Floor & Equipment Drainage Aux Bldg EL 70-0 SH-1
210-EB-40B-9
Floor & Equipment Drainage Aux Bldg El 70-0 SH-2
210-EB-40C-5
Floor & Equipment Drainage Aux Bldg El 95-9 SH-3
210-EB-40D-7
Floor & Equipment Drainage Aux Bldg El 95-9 SH-4
EE-032J
Arrangement - Manholes Plan and Details
PID-32-09J
Engineering P&I Diagram System 609 Drains - Floor
and Equipment
PID-32-09K
Engineering P&I Diagram System 609 Drains - Floor
and Equipment
Procedure
Number
Title
Revision
Cable Reliability Program
Work Orders
2867111
2869316
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
Condition Reports (CR-RBS-)
2018-00225
2018-01263
2018-01576
2018-01690
2018-03330
2018-06304
Miscellaneous
Documents
Number
Title
Revision
EIP-2-0001
User Aid 1
F
RSMS-OOPS-19-
19-1 As Found Evaluation
Procedures
Number
Title
Revision
Reactor Scram
Main Turbine and Generator Trips
Automatic Isolations
Loss of Main Condenser Vacuum, Trip of Circulating
Water Pump
Loss of Standby Service Water
Reactor Pressure Control Malfunctions
Station Blackout
Conduct of Operations
RPV Control
281
Primary Containment Control
Secondary Containment and Radioactive Release
Control
Contingencies
GOP-0002
Power Decrease/Plant Shutdown
2
GOP-0005
Power Maneuvering
330
SOP-0003
Reactor Recirculation System
315
SOP-0009
Reactor Feedwater System
079
SOP-0035
Reactor Core Isolation Cooling System
SOP-0053
Standby Diesel Generator and Auxiliaries
71111.12 - Maintenance Effectiveness
Condition Reports (CR-RBS-)
2017-04898
2017-07080
2017-07111
2017-07532
2017-07983
2017-08041
2017-08048
2017-08190
2017-08529
2017-08561
2018-00170
2018-00635
2018-01002
2018-01805
2018-01982
2018-01987
2018-02314
2018-02524
2018-03780
2018-03895
2018-04275
2018-04276
2018-04751
2018-04992
2018-05603
2018-05618
2018-05698
2018-05709
2018-05752
2018-05764
2018-05854
2018-05857
2018-05866
2018-05876
2019-00034
2019-00229
2019-00732
2019-00750
2019-00826
2019-01230
2019-01246
2019-01275
2019-01362
2019-01386
2019-01422
2019-01431
2019-01437
Miscellaneous
Document
Number
Title
Date
System Health
Report: 309 and
405
Standby Emergency Diesel Generators - Division I, II, &
III and HVAC
03/19/2019
Procedures
Number
Title
Revision
Maintenance Rule Scope and Basis
Maintenance Rule Monitoring
Maintenance Rule (a)(1) Process
SOP-0030
High Pressure Core Spray (Sys #203)
SOP-0059
Containment HVAC System (Sys #403)
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Condition Reports (CR-RBS-)
2019-00035
2019-00068
Procedures
Number
Title
Revision
ADM-0096
Risk Management Program Implementation and On-line
Maintenance Risk Assessment
27
Protected Equipment Postings
010
On Line Risk Assessment
018
Procedures
Number
Title
Revision
STP-207-4536
RCIC Isolation RCIC Steam Line Flow High Channel
Functional Test (E31-N683A, E31-N690A, E51A-K64)
2
STP-207-4539
RCIC Isolation RCIC Steam Supply Pressure Low
Channel Functional Test (E31-N685B)
301
STP-207-4549
RCIC Isolation RCIC RHR Steam Line Flow High
Channel Functional Test (E31-N684B, E31-N691B)
011
Work Orders
2716192
2847802
2847803
2847804
71111.15 - Operability Determinations and Functionality Assessments
Calculation
Number
Title
Revision
G13.18.14.1-037
Residual Heat Removal System Heat Exchanger
Performance Guidance
Condition Reports (CR-RBS-)
2017-01774
2017-04636
2018-06569
2018-06683
2019-00744
2019-00868
2019-00947
2019-01265
2019-01362
2019-01386
2019-01510
Drawings
Number
Title
Revision
ESK-06HVC02
Elementary Diagram 480V Switchgear Control Room Air
Handling Unit ACU2A
GE-793E922A
Main Steam Positive Leakage Control System
Miscellaneous
Documents
Number
Title
Revision
21.432-000-019 RHR Heat Exchanger Calculated Performance
211.161-997-179 Glow Plug Equivalency Evaluation for Hydrogen Igniter
Assembly #6043 Autolite Model 1106 vs. Autolite
Model 1109 AC DELCO 7G, and 12G
Issue Calculation G13.18.14.1-037 R0, Residual Heat
Removal System Heat Exchanger Performance
Guidance
Procedures
Number
Title
Revision
Operability Determination Process
SOP-0040
Hydrogen Mixing, Purge, Recombiners, and Igniters
306
SOP-0059
Containment HVAC System
STP-000-0001
Daily Operating Logs
STP-000-0001
Daily Operating Logs
STP-208-4208
Containment System/MSIV Positive Leakage Control-
Reactor-Steam Line Differential Pressure Channel
Calibration Test (E33-N623, E33-R623, E33-N629,
E33-N630, E33-K623)
STP-254-1402
Div II Hydrogen Igniter Train Current and Voltage Check 24
STP-254-1402
Div II Hydrogen Igniter Train Current and Voltage Check 26
STP-403-0301
Containment Unit Cooler HVR-UC1A Flow Rate
Verification
Work Orders
00478283
00513411
00514664
00514722
00514723
00520091
00520586
00769860
2624439
2687133
2751160
2753000
2843654
71111.19 - Post Maintenance Testing
Condition Reports (CR-RBS-)
2001-01031
2008-05122
2016-01725
2019-01362
2019-01386
Miscellaneous
Document
Number
Title
Revision
CEP-IST-4
Standard on Inservice Testing
309
Procedures
Number
Title
Revision
Limitorque Valve Operator Model SMB/SB/SBD-000
Through 5 MOV and HBC Periodic Inspection
SOP-0037
Fire Protection Water System Operating Procedure
(Sys #251)
SOP-0059
Containment HVAC System
STP-251-3205
Diesel Fire Pump Operational Test
STP-251-7608
FPW-P1B Fire Pump Engine Maintenance and
Inspection
STP-403-0301
Containment Unit Cooler HVR-UC1A Flow Rate
Verification
Work Orders
00514461
00514462
00520586
2760448
2816820
2820964
2829384
71111.20 - Refueling and Other Outage Activities
Condition Reports (CR-RBS-)
2019-01756
2019-01792
2019-01806
Miscellaneous
Document
Number
Title
Date
Outage Risk Assessment Team RF-20 Outage Report
03/18/2019
Procedures
Number
Title
Revision
CMP-0102
Reactor Vessel Disassembly
Shutdown Safety Management Program (SSMP)
GOP-0002
Power Decrease/Plant Shutdown
2
Control of Obstructions for Primary Containment/Fuel
Building Operability
Shutdown Operations Protection Plan (SOPP)
STP-050-0700
RCS Pressure Temperature Limits Verification
309
STP-057-3804
Containment Breach Monitoring
71111.22 - Surveillance Testing
Condition Reports (CR-RBS-)
2018-02035
2018-03079
2018-03958
2018-04679
2018-05556
2018-05909
2018-06433
2018-06522
2019-00144
2019-00198
2019-00347
Procedures
Number
Title
Revision
PEP-0026
Diesel Generator Operating Logs
015
SEP-RBS-IST-1
RBS Inservice Testing Bases Document
SEP-RBS-IST-2
RBS Fourth Ten-Year Interval Inservice Testing
Program Plan
SEP-RBS-IST-3
RBS Inservice Testing Cross Reference Document
SOP-0053
Standby Diesel Generator and Auxiliaries (SYS 309)
339
Procedures
Number
Title
Revision
STP-051-4504
NSSSS-Reactor Vessel Water Level-Low Low, Level 2;
Low Low Low, Level 1, Channel Functional Test (B21-
N682D, B21-N681D)
301
STP-201-6310
SLC Pump and Valve Operability Test
311
STP-203-0201
HPCS Piping Water Fill and Valve Position Verification
308
STP-205-6301
LPCS Pump and Valve Operability Test
STP-256-0201
Division I SWP Valve Lineup Verification
304
STP-309-0201
Division I Diesel Generator Operability Test
2
Work Orders
2609386
2626891
2641960
2660045
2680119
2691959
2709560
2726046
2741308
2756900
2763675
2772829
2788501
2805284
2820064
2834274
2843518
2846504
2849069
2849071
2849859
2850921
2854285
2856057
2856492
2859581
71114.06 - Drill Evaluation
Condition Reports (CR-RBS-)
2019-01520
2019-01583
Miscellaneous
Document
Number
Title
Date
River Bend Station ERO Team C Site Drill Report
March 12, 2019
04/10/2019
Procedures
Number
Title
Revision
Reactor Scram
Fire Outside the Main Control Room in Areas Containing
Safety Related Equipment
EIP-2-001
Classification of Emergencies
Conduct of Operations
Plant Transient Response Rules
Emergency Operating Procedure - RPV Control
Emergency Operating Procedure - Primary
Containment Control
Emergency Operating Procedure - Secondary
Containment and Radioactive Release Control
Emergency Operating Procedure - Contingencies
Emergency Operating and Severe Accident Procedures
Enclosures
2
71151 - Performance Indicator Verification
Miscellaneous
Documents
Number
Title
Date
Main Control Room Shift Logs
01/01/2018 -
2/31/2018
Procedure
Number
Title
Revision
Regulatory Performance Indicator Process
71152 - Problem Identification and Resolution
Condition Reports (CR-RBS-)
2018-06363
2018-06375
Procedures
Number
Title
Revision
CMP-1026
MCC Circuit Breakers, Starters, and Thermal Overloads 21
Configuration Control
Post Maintenance Testing
Work Orders
00513628
00513629
71153 - Follow-up of Events and Notices of Enforcement Discretion
Condition Report (CR-RBS-)
2018-05854
Procedure
Number
Title
Revision
STP-051-4524
ECCS/RCIC-Reactor Vessel Water Level-Low Low,
Level 2; Low Low Low, Level 1; Channel Functional Test
(B21-N692E, B21-N691E)
AP-0034
Inadvertent Initiation of an ECCS System or RCIC
SUNSI Review Complete
By: DLP
ADAMS:
Yes No
Publicly Available
Non-Publicly Available
Non-Sensitive
Sensitive
Keyword:
OFFICE
ASRI:DRP/C
ASRI/RI:DRP/C
ARI:DRP/C
BC:DRS/EB1
ABC:DRS/EB2
BC:DRS/OB
NAME
LMerker
BParks
TDeBey
VGaddy
GPick
GWerner
SIGNATURE
lnm
bdp
tmd
vgg
gap
gew
DATE
5/02/2019
5/3/2019
4/30/19
4/24/19
4/27/19
04/25/2019
OFFICE
BC:DNMS/RIB
TL:DRS/IPAT
BC:DRS/RCB
SPE:DRP/C
BC:DRP/C
NAME
GWarnick
RKellar
NMakris
DProulx
JKozal
SIGNATURE
jfk for
rlk
nfm
dlp
/RA/
DATE
4/25/2019
4/24/2019
4/27/19
4/30/19
5/10/2019