IR 05000458/2019002
| ML19221B538 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 08/08/2019 |
| From: | Cale Young NRC/RGN-IV/DRP/RPB-C |
| To: | Vercelli S Entergy Operations |
| References | |
| IR 2019002 | |
| Download: ML19221B538 (29) | |
Text
August 8, 2019
SUBJECT:
RIVER BEND STATION - INTEGRATED INSPECTION REPORT 05000458/2019002
Dear Mr. Vercelli:
On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at River Bend Station. On July 2, 2019, the NRC inspectors discussed the results of this inspection with Mr. Keith Crissman, Senior Manager, Projects and Maintenance Support, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or significance or severity of the violation 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/
Cale H. Young, Acting Chief Reactor Project Branch C
Docket No. 05000458 License No. NPF-47
Enclosure:
Inspection Report 05000458/2019002 w/attachment: Request for Information for the
O
Inspection Report
Docket Number:
05000458
License Number:
Report Number:
Enterprise Identifier: I-2019-002-0009
Licensee:
Entergy Operations, Inc.
Facility:
River Bend Station
Location:
St. Francisville, LA
Inspection Dates:
April 1, 2019 to June 30, 2019
Inspectors:
I. Anchondo-Lopez, Reactor Inspector
R. Kumana, Senior Resident Inspector
L. Merker, Acting Senior Resident Inspector
J. O'Donnell, Health Physicist
B. Parks, Resident Inspector
D. Proulx, Senior Project Engineer
T. Steadham, Senior Resident Inspector, Grand Gulf Nuclear Station
Approved By:
Cale H. Young, Acting Chief
Reactor Project 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.
List of Findings and Violations
Failure to Place a Division of Reactor Protection System in Trip After Falling below the Minimum Required Intermediate Range Monitor Channels During Startup Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2019002-01 Closed
[H.14] -
Conservative Bias 71111.15 The inspectors identified a Green, non-cited violation of Technical Specification (TS) 3.3.1.1,
RPS Instrumentation, for the licensee's failure to take required actions for inoperable intermediate range monitors (IRM). Specifically, while operating in Mode 2, the licensee failed to place an IRM channel in trip within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of falling below the minimum number of required channels for a reactor protection system (RPS) division.
Additional Tracking Items
None.
PLANT STATUS
River Bend Station began the inspection period shut down in Mode 5 for refueling outage RF-20. The station performed a reactor startup on May 11, 2019, ending the outage. The unit reached 87 percent power and remained there while waiting to perform a rod pattern adjustment.
On May 22, 2019, the operators reduced power to 36 percent due to an oil leak from a reactor recirculation pump transformer. On May 24, 2019, the operators restored the reactor recirculation pump and resumed the reactor startup. The unit reached 90 percent power and remained there while waiting to perform a rod pattern adjustment.
On May 28, 2019, the operators reduced power to 65 percent due to a feedwater heater leak.
The station commenced a normal reactor shut down on May 31, 2019, to repair the leak.
On May 31, 2019, during the planned shutdown, the operators inserted a manual scram due to an unplanned loss of reactor feedwater. The plant remained shut down following the scram to repair the feedwater heater leak.
On June 6, 2019, the station performed a reactor startup. On June 8, 2019, the unit reduced power from 76 percent to 36 percent due to another oil leak on the reactor recirculation pump transformer. On June 11, 2019, the operators restored the reactor recirculation pump and resumed the reactor startup.
On June 17, 2019, the unit reached 100 percent power. Power remained at or near 100 percent 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
Summer Readiness Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated summer readiness of offsite and alternate alternating current (AC) power systems on June 26, 2019.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Alternate decay heat removal system on April 4, 2019
- (2) Division III emergency diesel generator system on May 10, 2019
- (3) Division I standby liquid control system on May 16, 2019
- (4) Division II residual heat removal system on June 20, 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) Standby switchgear 1B room, fire area C-14, on May 2, 2019
- (2) Division III diesel generator room, fire area DG-5/Z-1, on May 10, 2019
- (3) Standby liquid control area, fire area RC-4/Z-4, on May 16, 2019
- (4) Heating, ventilation, and air conditioning 1A/B room, fire area C-4, on June 18, 2019
71111.08G - Inservice Inspection Activities (BWR)
BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding
Activities (IP Section 03.01)
The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk--significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from April 15 to April 18, 2019:
03.01.a - Nondestructive Examination and Welding Activities.
The inspectors directly observed or reviewed records of the following nondestructive activities:
1. Ultrasonic Examination
a. Weld FWS-39A-SW007, Report Number ISI-UT-19-004, pipe--to--tee weld on feedwater system
b. Weld MSS-700A2-SW08F, Report Number ISI-UT-19-007, pipe--to--sweepolet weld
c. Weld RCS-900C-SW011BB, Report Number ISI-UT-19-011, pipe--to--elbow weld on reactor coolant system d. Weld RCS-900CX-SW014CA, Report Number ISI-UT-19-013, tee--to--reducer on reactor coolant system
e. Weld B13-D001-N04B-0, Report Number ISI-UT-19-022, inner--radius nozzle examination on reactor pressure vessel
f. Weld B13-D001-N04B-1, Report Number ISI-UT-19-022, nozzle--to--shell weld on reactor pressure vessel
g. Weld B13-D001-DP, Report Number ISI-UT-19-031, reactor vessel head meridional weld
h. Weld B13-D001-DR, Report Number ISI-UT-19-032, reactor vessel head meridional weld
2. Magnetic Particle Examination
a. Weld B13-D001-AG, reactor vessel head--to--flange weld
3. Radiographic Examination
a. Weld FW-XI-1, Report Number BOP-RT-19-001, pipe--to--valve weld
Identification and Resolution of Problems:
The inspector reviewed 20 notifications that dealt with inservice inspections issues and found that items were entered into the corrective action program at the appropriate level and addressed appropriately.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during the plant's return to steady state full power after a refueling outage on May 11, 2019.
- (2) The inspectors observed and evaluated licensed operator performance in the control room during the plant's startup following an outage on June 6, 2019.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
The inspectors observed and evaluated a licensed operator simulator training session on May 31, 2019.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (1 Sample)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
Functional failure review of standby liquid control system on June 30, 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 shutdown operation due to having primary containment open with reactor water level less than 23 feet above the reactor flange on April 2, 2019
- (2) Yellow risk with Division II fuel building filter train out of service during fuel movement on April 5, 2019
- (3) Yellow risk with containment open, Division I spent fuel pool cooling pump out of service, and Division I fuel building filter train out of service during fuel movement on May 1, 2019
- (4) Yellow risk during surveillance testing of Division II containment unit cooler on June 19, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (3 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Division II containment unit cooler after failed surveillance test on April 4, 2019
- (2) Standby liquid control system after discovery of a leak on vent valve SLS-V40 during system pressure testing on May 9, 2019
- (3) Intermediate range monitor H after failure of low frequency amplifier on June 15, 2019
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Design Change Package 76014, "Feedwater Debris Strainer (FWDS) Evaluation and Installation"
- (2) Design Change Package 79604, "Feedwater Sparger Nozzle Repair"
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (8 Samples)
The inspectors evaluated the following post-maintenance tests:
- (1) Work Order 00472643 following modification of Division II emergency diesel generator voltage regulator circuit per engineering change 71133 on April 12, 2019
- (2) Work Order 00521918 following relay replacement and breaker adjustment on Division II containment unit cooler on April 23, 2019
- (3) Work Order 52772211 following replacement of standby liquid control injection pipe on May 3, 2019
- (4) Work Order 00412852, as left leakage test of B21-MOVF067D and B21-AOVF028D, on May 3, 2019
- (5) Work Order 00523781 following replacement of control switch in Division I containment unit cooler after surveillance test failure on May 9, 2019
- (6) Work Order 00512270 following repair of jacket water leak on Division I emergency diesel generator on June 3, 2019
- (7) Work Order 00512098 following modification of Division I control building air conditioning system on June 19, 2019
- (8) Work Order 52747086 following modification of reactor core isolation cooling pump overspeed device on June 25, 2019
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (2 Samples)
- (1) The inspectors evaluated refueling outage RF-20 activities from March 29, 2019 to May 10, 2019.
- (2) The inspectors evaluated planned outage PO-19-01 activities from June 1, 2019 to June 7, 2019.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
STP-107-3807, Revision 005, Feedwater Penetration KJB-Z3B Valve Leak Rate Test, on June 3, 2019
Inservice Testing (IP Section 03.01) (1 Sample)
STP-201-6601, Revision 305, Standby Liquid Control System Refuel Injection Test, on April 30, 2019
RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)
STP-207-4250, Revision 19, RCS-Identified and Unidentified Leakage Detection System (DFR-LT105/ESX105/LI105, DFR-LT107/ESX107/LI107, DFR-LT128/ESX128/LI128, DER-LT118/ESX118/LI118, DER-LT119/ESX119/LI119, E31-R618, DER-KC174), on May 8, 2019
Surveillance Tests (other) (IP Section 03.01) (2 Samples)
- (1) STP-309-0201, Revision 63, Division I Diesel Generator Operability Test, on April 17, 2019
- (2) STP-509-4801, Revision 008, Main Turbine Bypass System Functional Test Response Time Test and Logic System Functional Test of FWS Main Turbine Trip System, on May 11,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Contamination and Radioactive Material Control (IP Section 02.03) (1 Sample)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material. The inspectors verified the following sealed sources are accounted for and are intact:
- C-179, Am241Be Neutron Source
- 6019, Cs137 Panoramic Irradiator
10171, Cs137 Model 28-8C Irradiator High Radiation Area and Very High Radiation Area Controls (IP Section 02.05)
The inspectors evaluated risk--significant high radiation area and very high radiation area controls.
Instructions to Workers (IP Section 02.02) (1 Sample)
The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas.
Radiation work packages:
- RWP 2019-1917, Under Vessel Activities (Rev. 0)
- RWP 2019-1953, Bioshield ISI/FAC Activities (Rev. 0)
- RWP 2019-1926, Drywell Valve Work (AOV/MOV/IVT) Activities (Rev. 1)
Electronic alarming dosimeter alarms:
Labeling of containers:
- B-25 Boxes on RW 106
- Ionizer Resin Drums
- C-Vans on Trailer in RW 106 Truck Bay
- Tote of Tritiated Water
- Yellow Radwaste Trash Bags
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 02.06) (1 Sample)
The inspectors evaluated radiation worker performance and radiation protection technician proficiency.
Radiological Hazard Assessment (IP Section 02.01) (1 Sample)
The inspectors evaluated radiological hazards assessments and controls. The inspectors reviewed the following:
Radiological surveys:
- Aux Building, RWCU Pump Room (RBS-1903-0148 and RBS-1902-0252)
- Aux Building, RCIC Pump Room (RBS 1903-0320)
- Dry Well, Bioshield (RBS-1904-0839 and RBS-1904-0840)
- Dry Well, 82 Elevation (RBS-1903-0599 and RBS-1904-0587)
- Dry Well, 95 Elevation (RBS-1903-0519 and RBS-1904-0598)
- Turbine Building, MSR (RBS-1903-0413 and RBS-1903-0553)
Risk significant radiological work activities:
- RWP 2019-1917, Under Vessel Activities (Rev. 0)
- RWP 2019-1909, Drywell Scaffolding Activities (Rev. 0)
- RWP 2019-1726, Valve Work (AOV/MOV) Medium & High Risk Activities (Rev. 0)
- RWP 2019-1800, Refuel Floor Activities (Rev. 0)
- RWP 2019-1953, Bioshield ISI/FAC Activities (Rev. 0)
Air sample survey records:
- RBS-AS-2019-004, RWCU Pump Room (Work Area)
- RBS-AS-RF20-0034, Refuel Floor Activities - Drywell Head Removal
- RBS-AS-RF20-0032, Drywell - Head Vent
- RBS-AS-RF20-0040, Reactor Cavity - Cavity Work
Radiological Hazards Control and Work Coverage (IP Section 02.04) (1 Sample)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
Radiological work package for areas with airborne radioactivity:
- RWP 2019-1800, Refuel Floor Activities (Rev. 0)
- RWP 2019-1917, Under Vessel Activities (Rev. 0)
- RWP 2019-1926, Drywell Valve Work (AOV/MOV/IVT) Activities (Rev. 1)
71124.02 - Occupational ALARA Planning and Controls
Implementation of ALARA and Radiological Work Controls (IP Section 02.03) (1 Sample)
The inspectors reviewed ALARA practices and radiological work controls by reviewing the following activities:
- RWP 2019-1917, Under Vessel Activities (Rev. 0)
- RWP 2019-1800, Refuel Floor Activities (Rev. 0)
- RWP 2019-1555, Refueling Activities on Fuel Building 113 (Rev. 1)
- RWP 2019-1926, Drywell Valve Work (AOV/MOV/IVT) Activities (Rev. 1)
Radiation Worker Performance (IP Section 02.04) (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance during the removal of local power range monitors (LPRMs) from under the vessel, the vacuuming of the reactor vessel, the survey of the cavity, the ultrasonic cleaning of the fuel, and the repacking of the recirculation B flow control valve.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
April 1, 2018 - March 31, 2019
MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)
April 1, 2018 - March 31, 2019
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
April 1, 2018 - March 31, 2019
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
October 1, 2018 - March 31, 2019
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:
Foreign material in the feedwater system and resulting feedwater debris strainer modification evaluation and installation
Semiannual Trend Review (IP Section 02.02) (1 Sample)
The inspectors reviewed the licensees corrective action program for potential adverse trends in the area of corrective maintenance that might be indicative of a more significant safety issue. During the first half of the year, the inspectors observed an adverse trend in corrective maintenance. The licensee performed maintenance on several safety--related or risk--significant components that subsequently failed, requiring rework. The inspectors noted examples including a repeat failure of an intermediate range monitor, a repeat failure of a recirculation pump transformer, and inadequate maintenance of a recirculation pump motor bearing lubrication system.
These failures have been documented in the corrective action program.
71153 - Followup of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)
The inspectors evaluated personnel performance in the control room during a reactor scram initiated in response to a loss of feedwater on May 31,
INSPECTION RESULTS
Failure to Place a Division of Reactor Protection System in Trip After Falling below the Minimum Required Intermediate Range Monitor Channels During Startup Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2019002-01 Closed
[H.14] -
Conservative Bias 71111.15 The inspectors identified a Green, non-cited violation of Technical Specification (TS) 3.3.1.1, RPS Instrumentation, for the licensee's failure to take required actions for inoperable intermediate range monitors (IRMs). Specifically, while operating in Mode 2, the licensee failed to place an IRM channel in trip within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of falling below the minimum number of required channels for a reactor protection system (RPS) division.
Description:
At 10:53 a.m. on May 11, 2019, during preparations for a reactor startup, IRM H began to spike, causing a half scram. After declaring the IRM inoperable and placing it in bypass, the licensee reset the half scram and proceeded with a Mode 2 startup.
At 1:50 p.m. on May 11, 2019, with the reactor startup underway, IRM F failed downscale.
With IRMs F and H both inoperable, the licensee no longer met the minimum IRM channel requirements of TS 3.3.1.1. The licensee therefore entered condition A of TS 3.3.1.1, which required placing one of the affected channels in trip within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
At 2:11 p.m. on May 11, 2019, the licensee noted that IRM H was now tracking with other instrument channels. The licensee therefore took IRM H out of bypass and placed IRM F in bypass.
At 4:43 p.m. on May 11, 2019, the licensee completed an operability evaluation on IRM H and determined that the IRM was inoperable because it was reading abnormally low on ranges 1 through 6.
At 1:10 a.m. on May 12, 2019, approximately 40 minutes prior to the 12-hour action statement deadline, the licensee completed a second version of the operability determination on IRM H. The licensee determined that the low reading on the instrument was due to the failure of a low frequency amplifier that only affected the instruments on ranges 1 through 6.
Since reactor power had since increased to a power level corresponding to range 7, the licensee noted that the instrument was capable of performing its safety function in the current plant condition and concluded that it was operable. The licensee therefore exited TS 3.3.1.1 without taking an instrument to trip.
River Bend Station TS define operability as a condition in which a component is capable of performing its specified safety function(s). The basis document for TS and the Updated Final Safety Analysis Report for the station specify that the safety function of IRMs is to monitor neutron flux levels from the upper range of the source range monitors to the lower range of the average power range monitors. With ranges 1 through 6 on IRM H reading erroneously low in the presence of a failed amplifier, IRM H was not capable of performing this function.
The inspectors concluded that the fact that IRM 'H' was capable of correctly monitoring power at the specific power level at which the plant happened to be operating when the second operability determination was completed was not a valid basis for concluding that the IRM was operable to meet TS requirements. Because power levels can change in unexpected and uncontrolled ways, operable nuclear instruments must be capable of performing their specified safety functions at all power levels that fall within a given mode of applicability.
IRM 'H' was not capable of doing so and was therefore inoperable.
Corrective Actions: At the time that the violation was identified, the plant was not in a mode of applicability that required the IRM instruments to be operable. The licensee subsequently conducted maintenance that restored the instruments to operable status.
Corrective Action References: CR-RBS-2019-04655
Performance Assessment:
Performance Deficiency: The failure to complete actions required by plant TS for inoperable IRMs within the required time frame was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone. Specifically, by failing to take the required TS action for multiple failed instruments on an RPS division, the licensee continued to operate in a mode of applicability without meeting a TS limiting condition for operation, thus reducing the availability, reliability, and capability of the Division II RPS system to generate trip signals during postulated accident sequences that can occur during startup in the intermediate range.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using "Exhibit 2 --
Mitigating Systems Screening Questions, Section C, the inspectors determined that the finding was of very low safety significance (Green) because the finding did not affect the function of other redundant trips and did not involve control manipulations or mismanagement of reactivity by operators.
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, the licensee accepted an incomplete justification for the operability of IRM 'C' instead of conducting a thorough review of the instrument's ability to perform its specified safety function.
Enforcement:
Violation: TS 3.3.1.1 requires, in part, that three IRM channels be operable in each division in Mode 2. For conditions in which less than three IRM channels are operable in a division in Mode 2, action A.1 requires the licensee to place an affected channel or the affected division in trip within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If this action is not taken in the required amount of time, action H.1 requires the licensee to be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Contrary to the above, from May 12, 2019, to May 13, 2019, while operating in Mode 2 with less than three operable IRM channels in Division II, and after failing to place an affected channel or the division in trip within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the licensee failed to place the unit in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The licensee restored compliance by exiting the mode of applicability for the affected function of TS 3.3.1.1 on May 13, 2019.
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 18, 2019, the inspectors presented the inservice inspection results to Mr. S. Vercelli, Site Vice President, and other members of the licensee staff.
- On April 19, 2019, the inspectors presented the occupational radiation safety baseline inspection results to Mr. K. Scott, General Manager, Plant Operations, and other members of the licensee staff.
- On July 2, 2019, the inspectors presented the integrated inspection results to Mr. K. Crissman, Senior Manager, Projects and Maintenance Support, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
PID-27-08A
Engineering P & I Diagram System 656 Suppression Pool
Clean Up/Alternate Decay Heat Removal
Miscellaneous
Main Control Room Logs 03/29/2019 - 04/04/2019
04/04/2019
Procedures
OPS-0041
Alternate Decay Heat Removal
308
Procedures
SOP-0140
Suppression Pool Cleanup and Alternate Decay Heat
Removal (Sys #656)
71111.08G Corrective Action
Documents
CR-RBS-
2017-01066, 2017-01119, 2017-01299, 2017-03470, 2017-
06458, 2017-06676, 2017-01484, 2017-01559, 2017-01622,
2017-02199, 2017-02865, 2017-06152, 2018-01429, 2018-
01786, 2018-03540, 2018-05906, 2018-06472, 2018-05294,
2018-05782
71111.08G Drawings
RPV Insulation Support Elevation Reactor Building
71111.08G Drawings
RBS-ISI-018
Bolting Arrangement & Weld Map
71111.08G Miscellaneous
SEP-ISI-RBS-001
Program Section for ASME Section XI, Division 1 RBS
Inservice Inspection Program
71111.08G Procedures
CEP-NDE-0255
Radiographic Examination ASME, ANSI, AWS, API, AWWA,
Welds and Components
71111.08G Procedures
CEP-NDE-0404
Manual Ultrasonic Examination of Ferritic Piping Welds
(ASME XI)
71111.08G Procedures
CEP-NDE-0423
Manual Ultrasonic Examination of Austenitic Piping Welds
71111.08G Procedures
CEP-NDE-0731
Magnetic Particle Examination (MT) for ASME Section XI
71111.08G Procedures
GE-UT-300
Procedure for Manual Examination of Reactor Vessel
Assembly Welds in Accordance with Performance
Demonstration Initiative (PDI)
71111.08G Procedures
WDI-STD-006
Manual Ultrasonic Procedure for Examination of Nozzle
Inner Corner Radius Areas in Accordance with ASME
Section XI, Including Appendix VIII
71111.08G Procedures
WDI-STD-1107
Generic Procedure for the Manual Ultrasonic Examination of
Reactor Pressure Vessel Welds in Accordance with PDI-UT-
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-RBS-
2017-01346, 2017-02681, 2017-02766, 2018-02771, 2018-
2956, 2019-00347, 2019-00632, 2019-00784, 2019-00943,
2019-01224,
Procedures
Procedures
Maintenance Rule Scope and Basis
Procedures
Maintenance Rule Monitoring
Procedures
Maintenance Rule (A)(1) Process
Procedures
SOP-0028
Standby Liquid Control (Sys #201)
Work Orders
WO 2356497, 52641444, 52764460
Corrective Action
Documents
CR-RBS-
2019-03017
Miscellaneous
Outage Risk Assessment Team RF-20 Outage Report
03/18/2019
Procedures
Shutdown Safety Management Program (SSMP)
Procedures
Control of Obstructions for Primary Containment/Fuel
Building Operability
Procedures
Shutdown Operations Protection Plan (SOPP)
Procedures
Shutdown Operations Protection Plan (SOPP)
Procedures
STP-057-3804
Containment Breach Monitoring
Work Orders
Corrective Action
Documents
CR-RBS-
2019-01787
Procedures
Operability Determination Process
016
Procedures
Emergency Operating Procedure - Primary Containment
Control
017
Procedures
SOP-0059
Containment HVAC System (Sys #403)
038
Procedures
STP-309-0602
Division II ECCS Test
047
Calculations
AX-017C
Feedwater - Headers to Reactor and Startup Recirculation
Calculations
G13.18.1.0-045
River Bend Feedwater Sparger Repair - Analysis of Repair
on Existing Equipment
Calculations
G13.18.1.0-046
River Bend Feedwater Sparger Repair - Fracture Mechanics
Analysis
Calculations
G13.18.2.7*107
Loss of One Feed Pump - SCRAM Avoidance
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
G13.18.2.7-119
RBS-FWS-P-001 - Water Hammer Analysis of Feedwater
System for Pump Trip and Valve Operation Hydraulic
Calculations
G13.18.4.0-064
Hydraulic Analysis to Support River Bend Feedwater
Sparger Repair
Calculations
PH-092
Revision of Condensate and Feedwater System Pressure
Drop
Calculations
Z-17-214
Pipe Support
Corrective Action
Documents
CR-RBS-
2018-00613
Drawings
004N8149
Feedwater Debris Strainer
Engineering
Changes
Feedwater Debris Strainer (FWDS) Evaluation and
Installation
Engineering
Changes
Feedwater Sparger Nozzle Repair
Miscellaneous
Independent Third Party Review of Feedwater Debris
Strainer Design Documents
2/08/2019
Miscellaneous
FWS-DPT201A & FWS-DPT201B Set Point Data Sheets
Miscellaneous
004N5996
River Bend Station Feedwater Debris Strainer Feasibility
Study
Miscellaneous
100413-Calc-1
GE-Hitachi Housing Strainer Flange Calculation
Miscellaneous
RBS-ME-19-
00003
Design Analyses and Evaluation of Flow Test Verification of
a 24-Inch Feedwater Strainer
Miscellaneous
SDC-050
Reactor Vessel and Internals
Miscellaneous
SDC-107
Feedwater System Design Criteria
Miscellaneous
SEP-RVI-003
River Bend Station Reactor Vessel Internals (RVI)
Inspection Program Plan
Miscellaneous
SL-RBS-17-004
Completion of the Independent Third Party Review of GEH
Feedwater Debris Study Feasibility Study
2/20/2017
Work Orders
Corrective Action
Documents
CR-RBS-
2019-01787, 2019-02348, 2019-02533, 2019-02745, 2019-
2755, 2019-02757
Miscellaneous
Certified Material Test Report for Stainless Steel Pipe, Heat
Number 544668
04/29/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
ASME Repair &
Replacement
Plan CEP-RR-
2
Replace a Section of SLS-150-037-1 Piping
04/28/2019
Miscellaneous
Procedure
Qualification
Record 107
Manual Gas Tungsten & Shielded Metal Arc Welding
Miscellaneous
Procedure
Qualification
Record 170
Manual Gas Tungsten & Shielded Metal Arc Welding
Miscellaneous
Procurement
Engineering
Evaluation
00194438
Stainless Steel Seamless Pipe
04/27/2019
Miscellaneous
SDC-201
Standby Liquid Control System Design Criteria
Miscellaneous
Welding
Procedure
Specification
CEP-WP-002
Manual Gas Tungsten Arc Welding
04/29/2010
NDE Reports
BOP-VT-19-022
Visual Inspection of SLC Injection Pipe
04/26/2019
Procedures
Engineering Change Process
26
Procedures
Post-Maintenance Testing
005
Procedures
STP-309-0207
Division II Diesel Generator 184 Day Operability Test
28
Procedures
STP-309-0602
Division II ECCS Test
047
Procedures
STP-403-1201
HVR-UC1B System B Timer Channel Functional Test
006
Work Orders
WO 00472643, 00506188, 00511497, 00521918
Calculations
G13.18.14*189-3
Time to Boil, Heat Up Rate, and Time to Top of Active Fuel
Curves Accounting for Power Uprate
Calculations
G13.18.2.6-190
Reactor Pressure Vessel Water Inventory Control Drain
Time
Miscellaneous
Outage Risk Assessment Team RF-20 Outage Report
03/18/2019
Procedures
Shutdown Safety Management Program (SSMP)
Procedures
FHP-0001
Control of Fuel Handling and Refuel Operations
Procedures
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Shutdown Operations Protection Plan (SOPP)
Procedures
Shutdown Operations Protection Plan (SOPP)
Procedures
Alternate Decay Heat Removal
308
Corrective Action
Documents
CR-RBS-
2019-02498, 2019-02883, 2019-02996, 2019-03269
Miscellaneous
Main Control Room Logs for April 11, 2019
04/11/2019
Miscellaneous
Outage Risk Assessment Team RF-20 Outage Report
03/18/2019
Miscellaneous
1.ILDFR.011
Loop Calibration Report
Miscellaneous
STP-309-
201R063CN-A
STP-309-0201 One-Time Change Notice Procedure Action
Request
04/11/2019
Procedures
STP-201-6601
Standby Liquid Control System Refuel Injection Test
305
Procedures
STP-207-4250
RCS-Identified and Unidentified Leakage Detection System
(DFR-LT105/ESX105/LI105, DFR-LT107/ESX107/LI107,
DFR-LT128/ESX128/LI128, DER-LT118/ESX118/LI118,
DER-LT119/ESX119/LI119, E31-R618, DER-KC174)
Procedures
STP-309-0201
Division I Diesel Generator Operability Test
Work Orders
WO 2500240, 52641444, 52764460, 52766622, 52870113
Corrective Action
Documents
CR-RBS-
2018-05978, 2018-06008, 2018-06556, 2019-00332, 2019-
00696, 2019-01158, 2019-01196, 2019-01619, 2019-01739,
2019-01747, 2019-01783, 2019-01845, 2019-01902, 2019-
01999, 2019-02002, 2019-02157
Miscellaneous
2019
NSTS Annual Inventory Reconciliation Confirmation
1/30/2019
Miscellaneous
RBS-RPT-19-001
Optimization of ARGOS-5AB Whole Body Contamination
Monitors in the Presence of Noble Gases
3/6/2019
Miscellaneous
RBS-RPT-19-003
Review of Radiological Data Relevant to RF20
3/20/2019
Procedures
Radiation Worker Expectations
Procedures
Access Control for Radiologically Controlled Areas
Procedures
Radiological Control
Procedures
Radiation Protection Posting
Procedures
Radioactive Material Control
Procedures
Alpha Monitoring
Procedures
Radiological Controls for Highly Radioactive Objects
Procedures
Source Control
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Radiation
Surveys
2/5/2019
Radiation
Surveys
2/5/2019
Radiation
Surveys
SB109 Rooms 224& 236
3/26/2019
Radiation
Surveys
TB 67 Chemistry
4/15/2019
Radiation
Surveys
RBS-AS-RFO20-
22
Cavity Decon
3/30/2019
Radiation
Surveys
RBS-AS-RFO20-
0047
Routine
3/30/2019
Self-Assessments 2017
RBS RP 10 CFR 20.1103(c) Report
6/21/2018
Self-Assessments LO-RLO-2017-
00075
Pre-NRC Radiological Hazard Assessment and Exposure
Controls (71124.01) & Performance Indicator Verification
(71151-OR01)
1/14/2019
ALARA Plans
2019-1500
In-Progress Review (50%)
4/13/2019
ALARA Plans
2019-1555
In-Progress Review (50%)
4/13/2019
ALARA Plans
2019-1801
In-Progress Review (40%)
4/13/2019
Corrective Action
Documents
CR-RBS-
2018-00935, 2018-01567, 2018-03244, 2018-04681, 2018-
05153, 2018-05481, 2018-05973, 2018-06401, 2018-06473,
2019-02006, 2019-02090
Miscellaneous
RBS-RPT-19-003
Review of Radiological Data Relevant to RF20
3/20/2019
Procedures
ALARA Program
Procedures
EN-RP-110-01
ALARA Initiative Deferrals
Procedures
EN-RP-110-03
Collective Radiation Exposure (CRE) Reduction Guidelines
Procedures
EN-RP-110-04
Radiation Protection Risk Assessment Process
Radiation Work
Permits (RWPs)
2019-1500
Refueling Activities on FB 113
Radiation Work
Permits (RWPs)
2019-1555
RFB 113 Fuel Sipping and Cleaning Operations
Radiation Work
Permits (RWPs)
2019-1801
Refuel Floor - Fuel Movements, IVVI, & Support Activities
Self-Assessments LO-RLO-2017-
Pre-NRC Occupational ALARA Planning & Controls
10/30/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0055
(71124.02)
Self-Assessments QA 14/15 2017
RBS 1
Quality Assurance Audit Report: Combined Radiation
Protection and Radwaste
10/24/2017
The following items are requested for the
Occupational Radiation Safety Inspection
at River Bend Station
Dates of Inspection: 04/08/2019 to 04/19/2019
Integrated Report 2019002
Inspection areas are listed in the attachments below.
Please provide the requested information on or before Monday, March 25, 2019.
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.
The information should be provided in electronic format or a secure document management
service. 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 John O'Donnell at 817-200-1441 or via
e-mail at John.ODonnell@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.
1.
Radiological Hazard Assessment and Exposure Controls (71124.01) and
Performance Indicator Verification (71151)
Date of Last Inspection:
November 5, 2018
A.
List of contacts and telephone numbers for the Radiation Protection Organization Staff
and Technicians, as well as the Licensing/Regulatory Affairs staff. Please include area
code and prefix. If work cell numbers are appropriate, then please include them as well.
B.
Applicable organization charts including position or job titles. Please include as
appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),
Engineering, and Emergency Protection. (Recent pictures are appreciated.)
C.
Copies of audits, self-assessments, LARs, and LERs written since the last inspection
date, related to this inspection area
D.
Procedure indexes for the radiation protection procedures and other related disciplines.
E.
Please provide procedures related to the following areas noted below. Additional
procedures may be requested by number after the inspector reviews the procedure
indexes.
1. Radiation Protection Program
2. Radiation Protection Conduct of Operations, if not included in #1.
3. Personnel Dosimetry
4. Posting of Radiological Areas
5. High Radiation Area Controls
6. RCA Access Controls and Radiation Worker Instructions
7. Conduct of Radiological Surveys
8. Radioactive Source Inventory and Control
9. Fuel Pool Inventory Access and Control
F.
Please provide a list of NRC Regulatory Guides and NUREGs that you are currently
committed to relative to this program. Please include the revision and/or date for the
commitment and where this may be located in your current licensing basis documents.
G.
Please provide a summary list of corrective action documents (including corporate and
sub-tiered systems) since the last inspection date.
1. Initiated by the radiation protection organization
2. Assigned to the radiation protection organization
NOTE: These lists should include a description of the condition that provides sufficient
detail that the inspectors can ascertain the regulatory impact, the significance
level assigned to the condition, the status of the action (e.g., open, working,
closed, etc.) and the search criteria used. Please provide in document formats
which are sortable and searchable so that inspectors can quickly and
efficiently determine appropriate sampling and perform word searches, as
needed. (Excel spreadsheets are the preferred format.) If codes are used,
please provide a legend for each column where a code is used.
H.
List of radiologically significant work activities scheduled to be conducted during the
inspection period. (If the inspection is scheduled during an outage, please also include a
list of work activities greater than 1 rem, scheduled during the outage with the dose
estimate for the work activity.) Please include the radiological risk assigned to each
activity.
I.
Provide a summary of any changes to plant operation that have resulted or could result
in a significant new radiological hazard. For each change, please provide the
assessment conducted on the potential impact and any monitoring done to evaluate it.
J.
List of active radiation work permits and those specifically planned for the on-site
inspection week.
K.
Please provide a list of air samples taken to verify engineering controls and a separate
list for breathing air samples in airborne radiation areas or high contamination work
areas. Please include the RWP the breathing air sampling supports.
L.
Please provide the current radioactive source inventory, listing all radioactive sources
that are required to be leak tested. Indicate which sources are deemed 10 CFR Part 20,
Appendix E, Category 1 or Category 2. Please indicate the radioisotope, initial and
current activity (w/assay date), and storage location for each applicable source.
M.
The last two leak test results for all required/applicable radioactive sources that have
failed its leak test within the last two years. Provide any applicable condition reports.
N.
A list of all non-fuel items stored in the spent fuel pools, and if available, their appropriate
dose rates (Contact / @ 30cm)
O.
A list of radiological controlled area entries greater than 100 millirem, since the last
inspection date. The list should include the date of entry, some form of worker
identification, the radiation work permit used by the worker, dose accrued by the worker,
and the electronic dosimeter dose alarm set-point used during the entry (for
Occupational Radiation Safety Performance Indicator verification in accordance with IP 71151).
P.
A list describing VHRAs and TS HRAs (> 1 rem/hour) that are current and historical.
Include their current status, locations, and control measures.
Q.
Temporary effluent monitor locations and calibrations (AMS-4) used to monitor normally
closed doors or off-normal release points (e.g., equipment hatch or turbine heater bay
doors). Include any CRs associated with this monitoring or instrumentation.
2.
Occupational ALARA Planning and Controls (71124.02)
Date of Last Inspection:
January 22, 2018
A.
List of contacts and telephone numbers for ALARA program personnel, as well as the
Licensing/Regulatory Affairs staff. Please include area code and prefix. If work cell
numbers are appropriate, then please include them as well.
B.
Applicable organization charts including position or job titles. Please include as
appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),
Engineering, and Emergency Protection. (Recent pictures are appreciated.)
C.
Copies of audits, self-assessments, LARs, and LERs, written since the date of last
inspection, focusing on ALARA
D.
Procedure index for ALARA Program procedures and other related disciplines.
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 Planning
3. ALARA Reviews
4. ALARA Committee
5. Radiation Work Permit Preparation
F.
Please provide a list of NRC Regulatory Guides and NUREGs that you are currently
committed to relative to this program. Please include the revision and/or date for the
commitment and where this may be located in your current licensing basis documents.
G.
Please provide a summary list of corrective action documents (including corporate and
sub-tiered systems) written since the date of last inspection, related to the ALARA
program, including exceeding RWP Dose Estimates.
NOTE: These lists should include a description of the condition that provides sufficient
detail that the inspectors can ascertain the regulatory impact, the significance
level assigned to the condition, the status of the action (e.g., open, working,
closed, etc.) and the search criteria used. Please provide in document formats
which are sortable and searchable so that inspectors can quickly and
efficiently determine appropriate sampling and perform word searches, as
needed. (Excel spreadsheets are the preferred format.) If codes are used,
please provide a legend for each column where a code is used.
H.
List of work activities (RWPs) greater than 1 rem, since date of last inspection,
including the original dose estimates and actual doses accrued. (Excel format
preferred). Please provide all revisions/changes, as well as any related RWPs that
support the work activity.
I.
List of active work activities (RWPs) that will be in use while we are onsite, including the
dose and dose rate settings, and if available, the planned dose. Include planning
documents and surveys. Include radiological risk assessments and proposed control
measures.
J.
Site dose totals for the past 3 years (based on dose of record). Also provide the current
year-to-date (YTD) collective radiation exposure (CRE). In addition, please provide
another document that separates the online and outage doses for the past 3 years.
K.
Most recent assessment of your isotopic mix, including the hard-to-detect radionuclides
and alpha hazards. Include a list of new and historical exposure issues (radiological
source term or high exposure areas/activities).
L.
If available, provide a copy of the lessons learned from the most recently completed
outage for each unit. Include a summary list of any associated corrective action
documents and the current status of any corrective actions assigned.
M.
Please provide the methods/reports that are in your process to meet the requirements of
CFR 20.1101(c) for periodic review of your RP program.
N.
Current exposure trends (BRAC dose rates and/or source term information).