IR 05000458/2021004
| ML22019A301 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 01/25/2022 |
| From: | Jeffrey Josey NRC/RGN-IV/DRP/RPB-C |
| To: | Karenina Scott Entergy Operations |
| References | |
| IR 2021004 | |
| Download: ML22019A301 (26) | |
Text
January 25, 2022
SUBJECT:
RIVER BEND STATION - INTEGRATED INSPECTION REPORT 05000458/2021004
Dear Mr. Scott:
On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at River Bend Station. On January 10, 2022, 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.
Two findings of very low safety significance (Green) are documented in this report. Both of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Jeffrey E. Josey, Chief Reactor Projects Branch C Division of Reactor Projects Docket No. 05000458 License No. NPF-47
Enclosure:
As stated
Inspection Report
Docket Number:
05000458
License Number:
Report Number:
Enterprise Identifier:
I-2021-004-0141
Licensee:
Entergy Operations, Inc.
Facility:
River Bend Station
Location:
St. Francisville, Louisiana
Inspection Dates:
October 1, 2021 to December 31, 2021
Inspectors:
R. Kopriva, Senior Reactor Inspector
R. Kumana, Senior Resident Inspector
J. ODonnell, Senior Health Physicist
C. Osterholtz, Senior Operations Engineer
W. Sifre, Senior Reactor Inspector
C. Wynar, Resident Inspector
Approved By:
Jeffrey E. Josey, Chief
Reactor Projects 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 Maintain the Ability of a Fire Door to Close Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2021004-01 Open/Closed None (NPP)71111.05 The inspectors identified a Green finding and associated non-cited violation of River Bend Station, Unit 1, Renewed Facility Operating License, Section 2.C(10), for failure to implement the fire protection program by not verifying that automatic closing mechanisms for normally open fire doors were operable.
Failure to Demonstrate Effective Control of Performance for a Maintenance Rule (a)(2)
System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2021004-02 Open/Closed
[H.8] -
Procedure Adherence 71111.06 The inspectors identified a Green finding and associated non-cited violation of 10 CFR 50.65(a)(2) with 13 examples of failures to demonstrate effective control of performance of a maintenance rule scoped system through appropriate preventive maintenance.
Additional Tracking Items
Type Issue Number Title Report Section Status NOV 05000458/2021010-03 Failure to Restore Compliance Associated with Technical Specification Required Procedures 71152 Closed
PLANT STATUS
River Bend Station began the inspection period at rated thermal power. On November 14, 2021, River Bend Station lowered power to approximately 62 percent for a rod pattern adjustment. River Bend Station returned to rated thermal power on November 22, 2021 and 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 activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed onsite portions of IPs. 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.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted.
As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed onsite portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
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) Containment unit coolers A, B, and C on November 15, 2021
- (2) Division I 4160 volt AC control system on November 29, 2021
- (3) Residual heat removal B on November 29, 2021
- (4) Drywell floor and equipment drain instrumentation on December 15, 2021
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the remote shutdown system on December 1, 2021.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Heating, ventilation, and air conditioning 1B room, fire area C-4, on November 2, 2021
- (2) Diesel driven fire pump 1B room, fire area FP-3, on November 9, 2021
- (3) Containment unit cooler area, fire area RC-4/Z-5, on November 12, 2021
- (4) Control rod drive system pump and filter room, fire area FB-1/Z-1, on December 2, 2021
- (5) Standby switchgear 1A room, fire area C-15, on December 13, 2021
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Low pressure core spray system room
- (2) High pressure core spray system room
71111.07A - Heat Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Heat exchanger SFC-E1B
71111.07T - Heat Sink Performance Heat Exchanger (Service Water Cooled) (IP Section 03.02)
The inspectors evaluated heat exchanger/sink performance on the following:
- (1) Emergency diesel generator B jacket water cooler - EGT-E1B (cooled by service water)
- (2) Steam tunnel room cooler - HVR-UC8 (room cooler cooled by service water)
- (3) Containment unit cooler B - HVR-UC1B (cooled by service water)
- (4) Reactor core isolation cooling / low pressure core spray / residual heat removal A room cooler - HVR-UC6 (cooled by service water)
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered on November 9, 2021.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed an evaluated simulator training session on October 22, 2021.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:
- (1) Review of control building ventilation system performance on November 29, 2021
- (2) Performance monitoring of pressure tight doors on December 15, 2021
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Elevated risk with reactor core isolation cooling out of service on November 10, 2021
- (2) Elevated risk due to unit cooler HVR-UC6 coil inspection on November 15, 2021
- (3) Elevated risk due to reactor core isolation cooling drain pot level instrument out of service on November 22, 2021
- (4) Elevated risk with auxiliary building internal flooding door AB070-03 out of service on December 15, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensees justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Division I penetration valve leakage control system air compressor on November 3, 2021 (CR-RBS-2021-05930)
- (2) Diesel air compressor functionality with dryer pressure drop on November 4, 2021 (CR-RBS-2021-01240)
- (3) Division I and Division III emergency diesel generator operability for STP-200-0603, Revision 19, Division III Remote Shutdown System Control Circuit Operability Test, while in Mode 1 on November 15, 2021
- (4) Reactor core isolation cooling on December 2, 2021 (CR-RBS-2021-06973)
- (5) Suppression pool cooling spurious valve opening and suppression pool level drop on December 15, 2021 (CR-RBS-2021-07351)
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Unit coolers HVR-UC11A and HVR-UC11B motor replacement (EC 88863)
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (9 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Work Order (WO) 00497132, high pressure core spray minimum flow restriction orifice, on October 5, 2021
- (2) WO 00490016, Division III remote shutdown relay replacement, on October 12, 2021
- (3) WO 00558034, Division I diesel generator overspeed pilot 3-way valve replacement, on October 19, 2021
- (4) WO 52863766, Division III diesel generator 18-year inspection, on October 21, 2021
- (5) WO 00567590, reactor core isolation cooling solenoid, on November 17, 2021
- (6) WO 00489142, replacement of remote shutdown system J11 relays, on December 6, 2021
- (7) WO 52852289, replacement of B21C-K13B relay, on December 21, 2021
- (8) WO 52942091, adjustment of AB070-03 door seal, on December 22, 2021
- (9) WO 00566861, troubleshooting of control rod 24-25 rod block, on December 27, 2021
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) STP-309-0611, Revision 055, Division I Diesel Generator 24 Hour Run, on November 15, 2021
- (2) COP-0032, Revision 11, Startup and Operation of the Reactor Sample Panel G33-Z020 and EN-CY-110, Revision 04, Chemistry Gamma Spectroscopy System Operation, on December 6, 2021
- (3) STP-410-3601, Revision 12, Control Building Chiller 1A Performance Test, on December 13, 2021
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) STP-205-6301, Revision 28, LPCS Pump and Valve Operability Test, on November 16, 2021
RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)
- (1) STP-000-0001, Revision 92, Reactor Coolant System Leakage, on December 16, 2021
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) Emergency response organization drill on October 13, 2021
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) Emergency response organization drill on November 10,
RADIATION SAFETY
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (9 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Area radiation monitors in various buildings - reactor building general area [RE-144]
and sample station [RE-151], radwaste solidification area [RE-188] and offgas building, and valve area [RE-167]
- (2) Effluent monitors for the fuel building ventilation exhaust [RE-5A/B], radwaste building ventilation exhaust [RE-6A/B], main plant exhaust duct [RE-125/RE-126]
- (3) Portable frisker (Ludlum Model 177) stationed in the services building 123-foot hallway [CHP-CR-074] and portable frisker (ASP-1) stored and ready for use in the services building 109-foot count room [CHP-MF-030]
- (4) Portable ion chamber (Ludlum Model 9-3) stored and ready for use in the services building 109-foot count room [CHP-DR-487]
- (5) High dose rate G-M instrument (TelePole) stored and ready for use in the services building 109-foot count room [CHP-TEL097]
- (6) Laboratory instruments for smear counting (BC-4 [HP-CS-008]; SAC-4 [HP-DS-070];
iSOLO [CHP-C-011]) located in the service building 109-foot count room
- (7) Personnel contamination monitors (Argos) used at the exit to the radiologically controlled area [1410-184, 1410-185, 1410-186]
- (8) Portal monitors (PM-7) used at the exit to the radiologically controlled area [PM7-394, PM7-395]
- (9) Tool and equipment monitor (Cronos) used at the exit to the Unit 2 radiologically controlled area [1011-061]
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (4 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
- (1) Standby gas treatment ventilation system discharge to main plant vent stack
- (2) Radwaste building ventilation system discharge to atmosphere
- (3) Fuel building ventilation system discharge to atmosphere
- (4) Auxiliary building ventilation system discharge to main plant vent stack
Sampling and Analysis (IP Section 03.02) (1 Sample)
The inspectors evaluated the following effluent samples, sampling processes, and compensatory samples:
- (1) Weekly iodine and particulate sampling for the plant vent [RE-126], the fuel building vent [RE-05A], and the radwaste building vent [RE-06A]
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
- (1) The inspector evaluated environmental monitoring equipment. No environmental sample collection was available for observation.
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01)
The inspectors evaluated the licensees performance in controlling, labeling, and securing the following radioactive materials:
- (1) Radwaste 106-foot storage room with drums, bags, and boxes of radioactive waste
Radioactive Waste System Walkdown (IP Section 03.02) (1 Sample)
The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:
- (1) Waste and floor drain collector subsystem of the liquid waste system
Shipment Preparation (IP Section 03.04) (1 Sample)
- (1) The inspectors observed the preparation of condensate bead resin liner #200L-21003 for shipment as an LSA-II shipment (RBS-2021-083) on November 17,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===
- (1) October 1, 2020 through September 30, 2021
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
- (1) October 1, 2020 through September 30, 2021
71152 - Problem Identification and Resolution (PI&R)
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in condition report classification that might be indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Entry into EOP-0002 on June 2, 2021 (CR-RBS-2021-04016)
- (2) Response to cited violation of Technical Specification 5.4.1 (CR-RBS-2021-00644)
The inspectors reviewed the licensees response to NOV 05000458/2021010-03 and determined that the reason, corrective actions taken and planned to address recurrence, and the date when full compliance was achieved for this violation is adequately addressed and captured on the docket.
INSPECTION RESULTS
Failure to Maintain the Ability of a Fire Door to Close Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2021004-01 Open/Closed None (NPP)71111.05 The inspectors identified a Green finding and associated non-cited violation of River Bend Station, Unit 1, Renewed Facility Operating License, Section 2.C(10), for failure to implement the fire protection program by not verifying that automatic closing mechanisms for normally open fire doors were operable.
Description:
During a walkdown of fire protection requirements in the fire pump house, the inspectors noted that the fire suppression pumps were separated by normally open rated fire doors. The inspectors reviewed the testing program for fire doors to determine if these doors complied with the approved fire protection program.
River Bend Station incorporated their fire protection program requirements and fire hazard analysis into Chapter 9A of their updated safety analysis report (USAR). The USAR states that each fire suppression pump is separated by a 3-hour rated fire barrier. The arrangement of fire suppression pumps at River Bend Station is such that the two diesel driven pumps are on either side of the motor driven pump. The doors separating the pumps are large, horizontally sliding, rated metal fire doors, with a mechanical pulley closing mechanism.
Each door is held fully open by a rope with two fusible links. The USAR states that all fire doors shall be provided with closing mechanism and inspected semiannually to verify the closing mechanisms are operable.
The inspectors found that River Bend Station did not verify semiannually that the two fire doors that comprise the 3-hour rated fire barrier between the electrically driven fire pump and the two diesel driven fire pumps were operable. While the doors had originally been inspected periodically, the inspectors found that the doors had not been inspected to verify the closing mechanisms were operable since October 2003.
The fire suppression pumps are required to be separated such that a failure of one supply does not result in a failure of the other supply. The pumps are 50 percent capacity pumps such that at least two must function to supply 100 percent fire water demand. If either of the fire doors fail to close, a failure of any pump due to fire will fail at least one other pump. The inspectors determined that the failure to verify the door closing mechanisms were operable was a failure to meet the licensees approved fire protection program.
The inspectors also determined that the doors were removed from the licensees inspection program without making a change to the approved fire protection program in accordance with their license condition. The inspectors determined that the decision to change the inspections occurred in 2003 and was not indicative of current performance.
Corrective Actions: The licensee added the two doors to their testing program.
Corrective Action References: CR-RBS-2021-06648
Performance Assessment:
Performance Deficiency: The failure to verify operability of a required fire door in accordance with the approved fire protection plan was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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, the finding represented a loss of control of fire barriers required to ensure the availability of fire suppression equipment.
Significance: The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. Using Inspection Manual Chapter 0609, 04, Initial Characterization of Findings, the inspectors determined the finding was associated with the Mitigating Systems cornerstone. Using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, the inspectors determined the finding was associated with fire confinement and was assigned a High degradation rating. The inspectors used Step 1.4.4 to determine that the finding was of very low safety significance (Green) because there was an adequate automatic suppression system on one side of each fire confinement element.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. The inspectors determined that the performance deficiency was not reflective of present performance because the performance deficiency occurred in 2003.
Enforcement:
Violation: The River Bend Station, Unit 1, Renewed Facility Operating License, Section 2.C(10) and Attachment 4, requires that the licensee implement and maintain in effect all provisions of the approved fire protection program. The approved fire protection plan requires that self-closing fire doors shall be inspected semiannually to verify that automatic hold-open, release, and closing mechanisms and latches are operable. Contrary to the above, from October 2003 to December 2021, the licensee failed to verify that the affected automatic hold-open, release, and closing mechanisms were operable.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Demonstrate Effective Control of Performance for a Maintenance Rule (a)(2)
System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2021004-02 Open/Closed
[H.8] -
Procedure Adherence 71111.06 The inspectors identified a Green finding and associated non-cited violation of 10 CFR 50.65(a)(2) with 13 examples of failures to demonstrate effective control of performance of a maintenance rule scoped system through appropriate preventive maintenance.
Description:
The inspectors identified multiple examples where the performance of structures, systems, and components (SSCs) that were subject to the maintenance rule were neither monitored against goals and corrective actions nor demonstrated to be effectively controlled through appropriate preventive maintenance.
All of the examples are related to Systems 888 and 889, Pressure and Watertight Doors, however the one discussed in detail for this finding is AB070-03.
Watertight door AB070-03 is an internal flood mitigation door between two safety-related systems, low pressure core spray (LPCS) and residual heat removal train A (RHR A). The licensees maintenance rule program classifies this door as a high-risk safety-related door, and the door is currently included in their systems to be monitored under (a)(2) of the maintenance rule. Procedure EN-DC-150, Condition Monitoring of Maintenance Rule Structures, Section 7.1.5 states: follow-up inspections will be performed at 5-year intervals for high-risk and 10-year intervals for low-risk systems, if the walkdown is not conducted in interval plus grace period it should be classified as A1. River Bend Station Specification No. 210.461, Pressure tight Doors, Watertight Doors, and Special Doors, Revision 2, specifically states that AB070-03 shall be designed to sustain a pressure of 2.1 psi multiplied by a dynamic load factor of 1.85 and that the door shall withstand 28 feet of head from both sides. Additionally, the vendor manual, 3210.461-3040002C, Revision A, requires removing the boltwork cover to check and lubricate the linkages every 6 months. It gives a specification for door seal adjustment to 3/32-inch utilizing set screws in order to ensure 100 percent seal engagement with the door frame. However, it does not specify a periodicity to perform this action.
To ensure the door could meet its design function as specified, the performance monitoring requirement utilized by the licensee was work order (WO) 00196451. This work order was last completed January 12, 2010. This has exceeded the 5-year performance monitoring criteria of EN-DC-150 and the door should have had goals and corrective actions established per 10 CFR 50.65(a)(1). The licensee failed to do this.
After the inspectors brought this issue to the licensees attention, they went to the field with licensee engineers to assess the status of the door seal and to ascertain its ability to accomplish its design function. During the field inspection, the inspectors discovered that air could be felt leaking past the door seal in various locations and questioned the doors ability to maintain pressure tight and watertight integrity. The licensee agreed that the door failed to meet its inspection acceptance criteria, declared the door non-functional, and took action to correct the deficiency.
Additional watertight and pressure tight doors scoped into (a)(2) as high risk that have work orders to validate the doors safety function but have not been monitored every 5 years are:
AB095-02, AB095-06, AB141-04, DG098-01, DG098-02, DG098-03, DG098-10, FB070-04, SS118-05, SS118-06, SS154-01, and SS154-02.
Corrective Actions: The licensee entered this issue into their corrective action program, performed an engineering inspection on door AB070-03, and adjusted the door to restore its function.
Corrective Action References: CR-RBS-2021-07349, CR-RBS-2021-07493, and CR-RBS-2022-00061
Performance Assessment:
Performance Deficiency: The failure to monitor the performance or demonstrate effective control of performance of systems covered by the maintenance rule is a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the SSC 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.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated October 7, 2016, the inspectors determined the finding was associated with the Mitigating Systems cornerstone. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) For Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, led the inspectors to Exhibit 4, External Events Screening Questions.
The inspectors determined the finding was of very low safety significance (Green) because the finding did not represent a degradation in two or more trains of a multi-train system or function and did not involve a loss of any Probabilistic Risk Assessment function.
Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. The licensee had the opportunity to identify and correct this gap in System 889 performance monitoring during their last SSC inspection to meet the objectives of EN-DC-150 in 2019.
Enforcement:
Violation: Title 10 CFR 50.65(a)(1), requires, in part, that the holders of an operating license shall monitor the performance or condition of SSCs within the scope of the rule as defined by 10 CFR 50.65(b), against licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions.
Title 10 CFR 50.65(a)(2) states, in part, that monitoring as specified in 10 CFR 50.65(a)(1) is not required where it has been demonstrated that the performance or condition of an SSC is being effectively controlled through the performance of appropriate preventive maintenance, such that the SSC remains capable of performing its intended function.
Contrary to the above, from January 12, 2010 to December 15, 2021, the licensee failed to demonstrate that the performance or condition of watertight door AB070-03 had been effectively controlled through the performance of appropriate preventive maintenance and did not monitor against licensee-established goals. Specifically, the licensee failed to monitor the performance of watertight door AB070-03 for over 10 years, exceeding the established 5-year monitoring period. The performance or condition of this SSC was not being effectively controlled through the performance of appropriate preventive maintenance and, as a result, goal setting and monitoring was required. The licensee then failed to evaluate the door for (a)(1) status. There were 12 additional examples of this violation associated with watertight and pressure tight doors AB095-02, AB095-06, AB141-04, DG098-01, DG098-02, DG098-03, DG098-10, FB070-04, SS118-05, SS118-06, SS154-01, and SS154-02.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Semiannual Trend Review 71152 The inspectors reviewed a selection of several condition reports for appropriate screening and classification in accordance with the licensees corrective action procedure. Title 10 CFR 50, Appendix B, Criterion XVI, states Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. The inspectors noticed a trend of condition reports that identified failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, but were not classified as conditions adverse to quality.
The licensee uses Procedure EN-LI-102, Corrective Action Program, as guidance for meeting the regulatory requirements of Criterion XVI. Under the definitions section, the procedure defines condition adverse to quality (CAQ) as a failure, malfunction, deficiency, deviation, defective material or equipment, or nonconformance affecting the safety-related function of a structure, system or component. It further breaks down the definitions of all the terms used to define a CAQ. If an equipment condition is found to not be a CAQ, their procedure allows it to be classified as non-adverse, which does not require corrective action to be taken.
The inspectors determined that the licensee has in some cases used a determination that a component is operable in accordance with the approved Technical Specification as a basis for determining a condition is not a condition adverse to quality. The inspectors noted that a determination of operability is not used in the language of Criterion XVI or the licensees procedure as a basis to determine whether a condition is a CAQ and whether it is required to be corrected. Some examples are defined below:
Condition Report CR-RBS-2021-03195 describes a safety-related residual heat removal sample isolation valve that failed to open. The licensee initially classified this condition report as non-adverse, but after the inspectors questioned the classification, the licensee reclassified it as a CAQ.
Condition Report CR-RBS-2021-03617 describes a steam leak on the reactor core isolation cooling turbine flange. The licensee classified this condition report as non-adverse despite it being a deficiency of a safety-related component.
Condition Report CR-RBS-2021-03618 describes a steam leak on the reactor core isolation cooling governor valve. The licensee classified this condition report as non-adverse despite it being a deficiency of a safety-related valve.
Condition Report CR-RBS-2021-05750 describes a ground on the safety-related 125 VDC bus. The licensee classified this condition report as non-adverse despite it being a deficiency of a safety-related bus.
Condition Report CR-RBS-2021-07000 describes significant corrosion on the diesel fire pump 1A exhaust pipe, which is a quality-related component. The licensee classified this condition report as non-adverse despite it being a deficiency of a quality-related pipe.
The inspectors noted that these condition reports were closed to the work management system and had open work orders associated with them. Procedure EN-LI-102 allows use of the work management system but has administrative controls to ensure that these CAQs are corrected. Because the conditions were classified as non-adverse, the licensee would be allowed by procedure to close the work orders without correcting the condition.
The inspectors identified one example of a minor violation of 10 CFR 50, Appendix B, Criterion XVI.
Condition Report CR-RBS-2017-02678 describes a failed remote shutdown panel light socket, which is a safety-related component, that was identified on March 19, 2017. The lack of indication prevents normal operation of the system because operators would have to take additional actions to operate the system. Specifically, the circuit automatically repositioned valves required for shutdown outside the control room, and the light provided indication that the associated switches were in the correct position. With the light socket failed, operators would have to verify proper alignment of components in the field. The licensee classified the condition report as non-adverse and closed the associated work order without correcting the deficiency. The deficiency was identified again in 2019 and a new condition report (CR-RBS-2019-03671) was generated. This condition report was also classified as non-adverse and closed to a work order that remains open. The inspectors determined that the licensee had not promptly corrected this CAQ because the condition has existed for nearly four years with multiple opportunities to correct the condition. The inspectors determined the violation was minor because it would not lead to a more significant safety concern and did not adversely impact any reactor oversight process cornerstone. The inspectors determined that, while the condition requires additional operator actions to verify proper operation of the circuit, the licensee had demonstrated through unrelated test and maintenance activities that the circuit would still automatically operate the affected components as designed. The licensee has an open work order in place to repair the light socket. This failure to comply with 10 CFR 50, Appendix B, Criterion XVI, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The licensee entered this violation into their corrective action program under Condition Report CR-RBS-2021-07529.
The inspectors did not identify a finding associated with this review.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On January 10, 2022, the inspectors presented the integrated inspection results to Mr. K. Scott, Site Vice President, and other members of the licensee staff.
On November 8, 2021, the inspectors presented the heat sink performance inspection results to Mr. B. Chenard, Director, Engineering, and other members of the licensee staff.
On November 19, 2021, the inspectors presented the public radiation safety inspection results to Mr. B. Chenard, Director, Engineering, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-RBS-
1991-00123
Miscellaneous
ER-RB-2001-
0136-000
Document the Basis for the Scope and Frequency of Fire
Protection Testing
Miscellaneous
ER-RB-2004-
275-000
Summarize All RBS NFPA Code Deviations
Procedures
Fire Door Monthly Inspection - Non Cat I
Work Orders
Miscellaneous
RBS-CS-15-
00005
Maintenance Rule Structures Basis/Scoping Document
Miscellaneous
River Bend
Station
Specification No.
210.461
Pressuretight Doors, Watertight Doors, and Special Doors
Miscellaneous
Vendor Manual
210.461-
3040002C
Installation Operating and Maintenance Instructions for
Pressure Tight and Water Tight Doors
A
Procedures
Condition Monitoring of Maintenance Rule Structures
Calculations
Calculation No.
28.850-DB-1505
Steam Tunnel Heat Gain Due to Jet Impingement Wall
Calculations
Calculation No:
IA-SWP*9
Setpoint Calculation for Bistables SWP*ESX064,
SWP*ESY164, SWP*ESX167, and SWP*ESY167 Standby
Cooling Tower Hi-Low Level Alarm & Min Wtr
Calculations
Drywell and Containment Response to Small and
intermediate Break Accidents
Calculations
G13.18.2.1*061
Auxiliary Building Design Basis Heat Loads and Unit Cooler
Sizing Verification
Calculations
G13.18.2.7*51
WATHAM Analysis with Trapped Air in SSW System Drywell
Unit Coolers Piping
0A
Calculations
G13.18.3.0*3-1
Auxiliary Building Normal/Accident Electrical Heat Loads
08/26/1996
Calculations
PX-562
Waterhammer Analysis with Trapped Air in SSW System A
Header and LONSW 1/LORPCCW and LOOP Events
2A
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
PX-567
Segment Force Factor for the Component Piping of the SSW
System
2A
Corrective Action
Documents
CR-RBS-
CR-RBS-2019-04371, CR-RBS-2017-4302, CR-RBS-1999-
00137, CR-RBS-2021-04161, CR-RBS-2021-04373, CR-
RBS-2018-03888, CR-RBS-2019-02728
Corrective Action
Documents
Resulting from
Inspection
CR-RBS-
CR-RBS-2021-06720, CR-RBS-2021-06756
Drawings
215.253-809-
2
Auxiliary Building Unit Cooler Replacement Cooling Coil
C
Drawings
E-1027
- 1818 Type NSP - 2 Pass Jacket Water Cooler
01/07/1981
Drawings
River Send Station Unit 1 - Service Water Piping Standby
Cooling Tower (Plan).
Drawings
PID-08-09C
River Bend Unit 1 Engineering P&ID Diagram System 309
Diesel Generator
Engineering
Changes
ER-RB-1999-
0766-000
Raise Area Temperatures to 122 Degrees Fahrenheit for
EDC Zones AB-114-1, AB-114-3, AB-141-1, AB-141-2, AB-
141-3, AB-141-4, and AB170-2
Engineering
Evaluations
ER#: ER-RB-
1999-0690-000
Design Margin Recovery for Aux Building Unit Coolers Using
degrees Fahrenheit Max Service Water Temperature vs
degrees Fahrenheit Used in Original HVAC Design
Miscellaneous
Accessible System Walkdown Plan - Standby Service Water
(SSW/256)
10/04/2021
Miscellaneous
- R-STM-0403
System Training Manual - *Reactor Building HVAC System
Miscellaneous
Cycle 22 -
August 6, 2021
River Bend Station Closed Cooling Water Systems Strategic
Plan
Miscellaneous
ER99-0766 -
NESE908
Heat Transfer Performance of Replacement Coils for
Auxiliary Building Unit Coolers at 95°F Service Water
Temperature
05/30/2001
Miscellaneous
File Nos.:
G1.49.5, G9.5,
G9.33.4
Updated Response to Generic Letter 89-13, Service Water
System Problems Affecting Safety-Related Equipment
10/21/1998
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
LCR No:
1.ILMOS.042
Loop Calibration Report
Miscellaneous
LCR No:
1.ILMOS.009
Loop Calibration Report
Miscellaneous
Loop No:
1.ILSWP.174
Standby Cooling Tower 1 Level Loop
10/04/2017
Miscellaneous
Operability
Evaluation CR-
Evaluate Steam Tunnel Temperatures with Active Steam
Leak in Progress
06/16/2021
Miscellaneous
Operating and
Maintenance
Manual NU9-M62
Air Handling Cabinets
06/14/1982
Miscellaneous
Q3-2021 RBS
256-Service
Water Standby
Third Quarter 2021 System Health Report for Service Water
Cooling System
10/07/2021
Miscellaneous
RBC-39428
NRC Generic Letter NO, 89-13, Letter of NRCs Receipt of
GSUs First of Two Responses to Service Water System
Problems Affecting Safety-Related Equipment
03/14/1990
Miscellaneous
SDC-118, 130, &
256
System Design Criteria, Normal Service Water - System
Number 118. Standby Service Water - System Number 256.
Service Water Cooling - System Number 130
Miscellaneous
Set Point Data
Sheet No. 12210-
IA-MOS-CP100A-
MUX39-1
Plant Computer & 1Swp-MUX39 - Standby Service Water
Cooling Tower 1 (Wide Range Temperature Detection
(Temp. High))
07/27/1994
Miscellaneous
Specification No.
215.252
Specification for Containment Unit Coolers and Auxiliary
Building Unit Coolers with ASME III, Class 3 Coils
07/30/1981
Miscellaneous
Specification No.
244.700
Specification for Standby diesel Generator Systems, ASME
Code,Section III, Class 3
04/12/1985
Miscellaneous
Suppliers
Document Data
Form File No.
21.482-601-
001A
Heat Exchanger Performance at Design Conditions
11/03/1999
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
System Training
Manual - RTM -0
118
Service Water Systems
Miscellaneous
Vendor Manual
No. NU9-M62
Buffalo Forge Company, Installation and Operation
Instructions for Air Handling Cabinets for Gulf States Utilities,
River Bend Station, Unit 1
01/14/1986
Miscellaneous
Vendor Manual:
Site Manual No:
B515-0136
Howden Buffalo Service Manual, Installation and
Maintenance of Axial Flow Fans
NDE Reports
BOP-UT-09-017
Carbon Steel 8 inch Line - B Tunnel 79 foot. (Procedure
CED-NDE-0505)
10/21/2019
NDE Reports
BOP-UT-19-012
Carbon Steel 8 inch Line (Procedure CEP-NDE-0505)
10/16/2019
NDE Reports
BOP-UT-19-013
Carbon Steel 12 inch Line (Procedure CEP-NDE-0505)
10/21/2019
NDE Reports
BOP-UT-19-014
Carbon Steel 8 inch Line (Procedure CED-NDE-0505)
10/16/2019
NDE Reports
BOP-UT-19-015
Carbon Steel 8 inch Line - B Tunnel 81 foot. (Procedure
CED-NED-0505)
10/16/2019
NDE Reports
BOP-UT-19-016
Carbon Steel 8 inch Line - B Tunnel 79 foot. (Procedure
CED-NDE-0505)
10/21/2019
NDE Reports
BOP-UT-21-019
UT Thickness on HVR UC8 Accessible Coils
03/05/2021
Procedures
- STP-602-6311
- DIV 1 FUEL POOL COOLING PUMP AND VALVE
TEST
307
Procedures
River Bend Station Operating Manual Abnormal Operating
Procedure - Loss of Normal Service Water.
Procedures
River Bend Station Operating Manual Abnormal Operating
Procedure - Loss of Standby Service Water
Procedures
River Bend Station Operating Manual Abnormal Operating
Procedure - Initiation of Standby Service Water with Normal
Service Water Running.
Procedures
COP-0123
River Bend Station Operating Manual Chemistry Operation
Procedure - Chemical Treatment of the Standby Cooling
Tower
Procedures
CSP-0006
River Vend Station Operating Manual Chemistry Section
Procedure - Chemistry Surveillance and Scheduling System.
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Engineering Calculation Process
Procedures
Condition Monitoring of Maintenance Rule Structures
Procedures
System Walkdowns
Procedures
NRC Generic Letter 89-13 Service Water Program
Procedures
Heat Exchanger Performance and Condition Monitoring
Procedures
Underground Piping and Tanks Inspection and Monitoring
Program
Procedures
Work Request Generation, Screening and Classification
Procedures
Work Implementation and Closeout
Procedures
Surveillance Program
Procedures
SDC-118, 130, &
256
River Bend Station System Design Criteria, Service Water
System Design Criteria System Numbers 118, 130, & 256
Procedures
SEP-HX-RBS-00
Service Water Heat Exchanger Inspection
Procedures
SEP-HX-RBS-002
Performance Monitoring Program for the Residual Heat
Removal Heat Exchangers E12-EB001B and E12-EB001D
(DIV II)
Procedures
SEP-HX-RBS-003
Performance Monitoring Program for Residual Heat Removal
Heat Exchangers E12-EB001 A and E12-EB001C (DIV I)
Procedures
SEP-SW-RBS-
001
RBS GL89-13 Service Water Heat Exchanger Program
Procedures
STP-256-6301
Div I Standby Service Water Quarterly Valve Operability Test
Procedures
STP-256-6302
Div II Standby Service Water Quarterly Valve Operability
Test
Procedures
STP-256-6303
Standby Service Water A Loop Quarterly Pump and Valve
Operability Test
Procedures
STP-256-6304
Standby Service Water B Loop Quarterly Pump and Valve
Operability Test
307
Procedures
STP-256-6305
Div I Standby Service Water Quarterly Valve Operability Test
Procedures
STP-256-6306
Div II Standby Service Water Quarterly Valve Operability
Test
Procedures
STP-256-6801
Div I Standby Service Water Cold Shutdown Pump and
Valve Operability Test
Procedures
STP-256-6802
Div II Standby Service Water Cold Shutdown Pump and
Valve Operability Test
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
STP-403-0303
Containment Unit Cooler HVR-UC1B Flow Rate Verification
307
Procedures
Division II Standby Cooling Tower Fans Operability Test
Self-Assessments
Engineering
Report No. RBS-
CS-19-00004
2019 Maintenance Rule Structures Periodic Assessment
09/25/2019
Self-Assessments LO Tracking No.
RLO-2020-00021
Pre-NRC Self-Assessment - Heat Sink Performance. River
Bend Station
07/21/2021
Self-Assessments LO Tracking No.
LO-RLO-2019-
00144 CA2
Heat Exchanger Self-Assessment
Work Orders
Work Orders -
00323927, 00512093, 52969070, 53971325, 52971330,
2972347, 52972352, 52972852, 52980530, 52981898,
2898379, 00361644, 00546349, 52770525, 51087021,
2763985, 52896855, 52763985, 52491009, 52767256,
2782059, 52799020, 52975603, 00512093, 00361644,
00523466, 52887229-01,
Miscellaneous
Radiation Protection Instrument List
11/16/2021
Miscellaneous
USAR Table 12.3-
Area Direct Radiation Monitor Locations
Miscellaneous
USAR Table 12.3-
Airborne Process and Effluent Radiation Monitors
Miscellaneous
USAR Table 12.3-
Airborne Process and Effluent Radiation Monitors
Miscellaneous
USAR, Chapter
Radioactive Waste Management
Miscellaneous
Metrology Data for 11/15/2021
11/16/2021
Miscellaneous
Daily Operating Logs
Data Sheet 1, Page 8 of 19
11/16/2021
Miscellaneous
USAR, Chapter
Radioactive Waste Management
Procedures
RWS-0336
Setup and Operation of the RDS-1000 Dewatering Unit
Radiation
Surveys
4114 Special Nuclear Material Storage Room, RadWaste
106'
06/08/2021
Radiation
Liner 200L-21003 Characterization in the RadWaste 106'
06/15/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Surveys
Processing Area
Radiation
Surveys
4100 RadWaste 106' (Monthly Survey)
10/30/2021
Radiation
Surveys
28 RadWaste 90' Vendor Transfer Header
11/11/2021
Radiation Work
Permits (RWPs)
211234
RadWaste Liner Processing and Support Activities
Shipping Records
LWS Bead Resin / 200L-21003
UN 3321 Radioactive Material, Low Specific Activity (LSA-II),
11/17/2021
Corrective Action
Documents
CR-RBS-
21-00644
Corrective Action
Documents
CR-RBS-
2017-02678, 2019-03671
Procedures
Corrective Action Program
Procedures
Emergency and Transient Response Support Procedure
Procedures
Remote Shutdown System Control Circuit Operability Test
Procedures
SOP-0009
Reactor Feedwater System (SYS#107)
JJ
JE
FR
HG
VG
RK
MH
DATE
RIVER BEND STATION - INTEGRATED INSPECTION REPORT 05000458/2021004
January 25,
22