IR 05000458/2022011
| ML22131A364 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 06/02/2022 |
| From: | Vincent Gaddy NRC/RGN-IV/DORS/EB1 |
| To: | Karenina Scott Entergy Operations |
| References | |
| IR 2022011 | |
| Download: ML22131A364 (13) | |
Text
June 02, 2022
SUBJECT:
RIVER BEND STATION - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000458/2022011
Dear Mr. Scott:
On April 21, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at River Bend Station and 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.
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 the 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Signed by Gaddy, Vincent on 06/02/22 Vincent G. Gaddy, Chief Engineering Branch 1 Division of Operating Reactor Safety Docket No. 05000458 License No. NPF-47
Enclosure:
As stated
Inspection Report
Docket Number: 05000458 License Number: NPF-47 Report Number: 05000458/2022011 Enterprise Identifier: I-2022-011-0008 Licensee: Entergy Operations, Inc Facility: River Bend Station Location: St. Francisville, LA Inspection Dates: April 04, 2022 to April 22, 2022 Inspectors: W. Cullum, Reactor Inspector D. Reinert, Reactor Inspector W. Sifre, Senior Reactor Inspector Approved By: Vincent G. Gaddy, Chief Engineering Branch 1 Division of Operating Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (programs) 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 follow the Corrective Action Procedure Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.11] - 71111.21N.
Systems NCV 05000458/2022011-01 Challenge the 02 Open Unknown The inspectors identified a Green finding and associated Non-cited violation (NCV) of 10CFR50 Appendix B, Criterion V, Procedures, when the licensee failed to follow their Corrective Action Program procedure.
Additional Tracking Items
None.
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 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
71111.21N.02 - Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements POV Review (IP Section 03)
The inspectors:
a. Determined whether the sampled POVs are being tested and maintained in accordance with NRC regulations along with the licensees commitments and/or licensing bases.
Specific Guidance b. Determined whether the sampled POVs are capable of performing their design-basis functions.
c. Determined whether testing of the sampled POVs is adequate to demonstrate the capability of the POVs to perform their safety functions under design-basis conditions.
d. Evaluate maintenance activities including a walkdown of the sampled POVs (if accessible).
- (1) Reactor Building Equipment Drain Inboard Containment Isolation Valve - Air Operated Valve DER-AOV126
- (2) Containment and Drywell Floor Drain Sump Pump Discharge Header Inboard Containment Isolation Valve - Air Operated Valve DFR-AOV101
- (3) Residual Heat Removal Pump Shutdown Cooling Inboard Isolation Valve - Motor Operated Valve E12-MOVF009
- (4) Residual Heat Removal Pump A Injection Line Shutoff Valve - Motor Operated Valve E12-MOVF027A
- (5) Low Pressure Core Spray Pimp Low Pressure Core Spray Injection Shut Off Valve -
Motor Operated Valve E21-MOVF005
- (6) High Pressure Core Spray Pump Discharge Line Main Isolation Valve - Motor Operated Valve E22-MOVF004
- (7) Reactor Core Isolation Cooling & Residual Heat Removal Systems Steam Supply Isolation Valve - Motor Operated Valve E51-MOVF063
- (8) Reactor Core Isolation Cooling Steam Supply Line Outboard Containment Isolation Valve - Motor Operated Valve E51-MOVF064
- (9) Suppression Pool Cleanup & Cooling System Suction Valve - Air Operated Valve RHS-AOV63
- (10) Standby Service Water Pump A Discharge Isolation Valve - Motor Operated Valve SWP-MOV40A
- (11) Drywell Unit Coolers Supply Header A Outboard Containment Isolation Valve - Motor Operated Valve SWP-MOV507A
- (12) Standby Cooling Tower 1 Division 2 Return Line Isolation Valve - Motor Operated Valve SWP-MOV55B
INSPECTION RESULTS
Failure to follow the Corrective Action Procedure Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.11] - 71111.21N.0 Systems NCV 05000458/2022011-01 Challenge the 2 Open Unknown The inspectors identified a Green finding and associated Non-cited violation (NCV) of 10CFR50 Appendix B, Criterion V, Procedures, when the licensee failed to follow their Corrective Action Program procedure.
Description:
The inspectors reviewed an as-found Motor-Operated Valve static test, dated March 8, 2021, of E22-MOVF004, HPCS Discharge Line Main Isolation Valve, and noted that the licensee documented negative margin in the test results. Since a negative margin falls outside of the acceptance criteria, the inspectors asked to review the condition report to assess the operability determination and corrective actions for the valve. The inspectors were informed that a condition report was not generated to document the negative margin. The site procedure EN-LI-102, Revision 47, titled, "Corrective Action Program," Section 5.2, Step 5, states, "Employees and contractors are required to initiate condition reports for adverse conditions." This procedure also defines adverse condition, in part, as "A general term which includes Conditions Adverse to Quality plus undesirable conditions related to... design basis."
Since the Motor-Operated Valve had negative margin, there was reasonable doubt as to whether the valve could perform its design basis function if called upon. Similarly, inspectors reviewed an as-left Motor-Operated valve static test, dated February 28, 2013, of E21-MOVF005, LPCS Injection Shut Off Valve, and noted that it also had negative margin. No condition report was written to document this occurrence of negative margin either. In both circumstances, the licensee used conservatisms within the calculations to determine that margin still existed and the valves were considered operable.
Corrective Actions: The licensee took action to restore margin to the affected valves. By using conservatisms in the calculations and revising assumptions, the valves were left with positive margin and, therefore, in an operable condition. The licensee entered the margin deficiencies and failure to write a condition report into their corrective action program.
Corrective Action References: CR-RBS-2022-02005, CR-RBS-2022-02241
Performance Assessment:
Performance Deficiency: The licensee failed to follow procedures for activities affecting quality as required by 10CFR50 Appendix B Criterion V, Procedures. Specifically, the licensee failed to follow Step 5 of Section 5.2 of procedure EN-LI-102, "Corrective Action Program," which states, "Employees and contractors are required to initiate a Condition Report for adverse conditions." The inspectors identified 2 examples of this performance deficiency.
First, on March 8, 2021, a Condition Report was not written to document an adverse condition when the As Found Motor-Operated Valve static test of E22-MOVF004, HPCS Discharge Line Main Isolation Valve, showed negative margin in the open direction.
Second, on February 28, 2013, a Condition Report was not written to document an adverse condition when the As Left Motor-Operated Valve static test of E21-MOVF005, LPCS Injection Shut Off Valve, showed negative margin in the open direction.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, regardless of the final operability or functionality, the as-found condition was such that there was a reasonable doubt whether E22-MOVF004 and E21-MOVF005 would have been capable of performing their functions had they been called upon since the safety-related Motor-Operated Valves had negative margin. When the licensee evaluated the as found condition, they determined that the remaining margin falls outside of the design process acceptance criteria and assumptions were revised solely to obtain favorable results.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors screened the issue using Inspection Manual Chapter 0609 Appendix A titled "The Significance Determination Process for Findings At-Power." The issue screened to Green using Exhibit 2, "Mitigating Systems Screening Questions," since the degraded condition did not represent a loss of the PRA function of a single train Technical Specification system for greater than its allowed outage time.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. The inspectors found the most recent example on March 8, 2021, is indicative of present performance. The inspectors selected this cross-cutting aspect because they found that the licensee did not stop when faced with uncertain conditions. The negative margin was resolved without entering the corrective action process. As a result, opportunities were missed to evaluate the cause and determine operability of components.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Procedures requires, in part, that the licensee prescribe and accomplish activities affecting quality by documented instructions, procedures, or drawings of a type appropriate to the circumstances. Procedure EN-LI-102, Corrective Action Program, Revision 20 Step 5.2[1](e) and Revision 42 Step 5.2.4, require, in part, that employees are required to initiate condition reports for adverse conditions.
Contrary to the above, on February 18, 2013, and March 8, 2021, the licensee failed to initiate a condition report for an adverse condition. Specifically, on February 28, 2013, a condition report was not generated to document negative margin found during an as-left static test of E21-MOVF005, LPCS Injection Shut Off Valve, and on March 8, 2021, a condition report was not generated to document negative margin found during an as-found static test of E22-MOVF004, HPCS Discharge Line Main Isolation Valve.
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 21, 2022, the inspectors presented the design basis assurance inspection (programs) inspection results to Kent Scott and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21N.02 Calculations 4221.412-000- Maximum Thrust Weak Link Seismic Calculation B
007C
71111.21N.02 Calculations 4228.212-047- Design Report 10" 600lb Gate Valve Weak Link 3
019C
71111.21N.02 Calculations 4228.212-047- Seismic Analysis Report 10" 600lb Gate Valve 2
24C
71111.21N.02 Calculations 4228.212-047- Weak Link Analysis - Seismic Qualification of Motor B
040C Operated Valves
71111.21N.02 Calculations 4228.243-105- Weak Link and Seismic Analysis SWP-MOV40A A
007A
71111.21N.02 Calculations G13.18.15.2*053 Maximum Thrust Force for Valves E12-MOVF042A, 2
2B, and 042C and E21-MOVF005
71111.21N.02 Calculations G13.18.2.3*148 G.L. 89-10 Design Basis Review for E12-MOVF004A/B 5
71111.21N.02 Calculations G13.18.2.3*157 G.L. 89-10 Design Basis Review for E12-MOVF027A/B 3
71111.21N.02 Calculations G13.18.2.3*178 GL 89-10 Design Basis Review for E21-MOVF005 5
71111.21N.02 Calculations G13.18.2.3*182 GL 89-10 Design Basis Review for E22-MOVF004 6
71111.21N.02 Calculations G13.18.2.3*206 G.L. 89-10 Design Basis Review for E51-MOVF063 & 064 5
71111.21N.02 Calculations G13.18.2.3*206 G. L. 89-10 DESIGN BASIS REVIEW FOR E51- 5
MOVF063 & F064
71111.21N.02 Calculations G13.18.2.3*282 GL 89-10 Design Basis Review for SWP-MOV40A/B/C/D 2
71111.21N.02 Calculations G13.18.2.3*290 G.L. 89-10 Design Basis Review for SWP-MOV81A/B & 4
507A/B
71111.21N.02 Calculations G13.18.2.3*316 GL 96-05 MOV Periodic Static Test Frequency 0
71111.21N.02 Calculations G13.18.2.3*325 River Bend Station NRC Generic Letter 96-05 AC MOV 2
Actuator Output Capability Calculation
71111.21N.02 Calculations G13.18.2.3*339 Air Operated Valve Program System Level Calculation for 0
Reactor Building Equipment and Floor Drain System
(System 609)
71111.21N.02 Calculations G13.18.2.3*345 Air Operated Valve Component Level Calculation for 0
Valve DFR-AOV101 and DFR-AOV102
71111.21N.02 Calculations G13.18.2.6*183 High Pressure Core Spray System Hydraulic Performance 1
71111.21N.02 Corrective Action CR-RBS- 2011-08093, 2014-03977, 2017-01907, 2019-02889,
Inspection Type Designation Description or Title Revision or
Procedure Date
Documents 2021-02048, 2021-02286, 2021-02626, 2021-07651,
1992-00673, 2017-02471, 2018-06872, 2019-04679,
21-01871, 2007-00351, 2017-00936, 2017-01811,
2018-02890, 2018-06782, 2020-04845, 2021-02049,
21-04891, 2021-07355, 2022-01833, 2014-00633,
2011-08093, 2014-03977, 2019-02373, 2021-01884
71111.21N.02 Corrective Action CR-HQN- 2022-00732, 2022-00754
Documents
Resulting from
Inspection
71111.21N.02 Corrective Action CR-RBS- 2022-02013, 2022-01977, 2022-01978, 2022-01980,
Documents 2022-02005, 2022-02061, 2022-02062, 2022-02063,
Resulting from 2022-02065, 2022-02066, 2022-02067, 2022-02069,
Inspection 2022-02070, 2022-02088, 2022-02125, 2022-02241
71111.21N.02 Engineering EC 0000039724 Adjust Limit Switch Settings for 2 MOVS, E22-MOVF004 0
Changes and G33-MOVF054
71111.21N.02 Engineering EC 60680 Provide HELB Scenario MOVs at Degraded Voltage in a 0
Changes Design Basis Calculation for E51-MOVF063, E51-
MOVF064, G33-MOVF001, & G33-MOVF004
71111.21N.02 Engineering EC 86640 Design/Seismic/Weak Link Analysis Report for 8" Gate 0
Changes Valve
71111.21N.02 Engineering MC-96-007 Motor Operated Valve Program Closure Report 0
Evaluations
71111.21N.02 Engineering VA-7230.439- Weak Link Analysis for 30-IN. Tricentric Valves 0
Evaluations 000-009A
71111.21N.02 Miscellaneous AF E22- As Found MOV Static Test Report 03/08/2021
MOVF004
71111.21N.02 Miscellaneous AR 21006476 RBS Post R21 Static Test Frequency Changes for the 08/04/2021
MOV Program
71111.21N.02 Miscellaneous E21-MOVF005- MOV Static Test Report 07/28/1992
71111.21N.02 Miscellaneous E21-MOVF005- MOV Static Test Report 09/18/1997
71111.21N.02 Miscellaneous E21-MOVF005- MOV Static Test Report 02/20/2008
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21N.02 Miscellaneous E21-MOVF005- MOV Static Test Report 02/28/2013
71111.21N.02 Miscellaneous E21-MOVF005- MOV Static Test Report 03/13/2020
71111.21N.02 Miscellaneous VTD-F130-0131 Instruction Manual for Type 667 Diaphragm Actuator 1
Sizes 30-76 and 87
71111.21N.02 Procedures CEP-APJ-001 Primary Containment Leakage Rate Testing Program 6
Plan
71111.21N.02 Procedures EN-DC-117 Post-Modification Testing and Special Instructions 15
71111.21N.02 Procedures EN-DC-304 MOV Thrust Torque Setpoint Calculations 4
71111.21N.02 Procedures EN-DC-311 MOV Periodic Verification 7
71111.21N.02 Procedures EN-DC-312 Motor Operated Valve MOV Test Data Review 9
71111.21N.02 Procedures EN-DC-331 MOV Program 7
71111.21N.02 Procedures EN-DC-334 Primary Containment Leakage Rate Testing (Appendix J) 4
71111.21N.02 Procedures EN-EP-S-003- ENS Magnesium Motor MOV Management Plan 0
MULTI
71111.21N.02 Procedures EN-LI-102 Corrective Action Program 47
71111.21N.02 Procedures EN-MA-107 Post-Maintenance Testing 0
71111.21N.02 Procedures OSP-0047 Local Leak Rate Testing Implementation 16
71111.21N.02 Procedures SEP-APJ-004 Primary Containment Leakage Rate Testing Program 6
71111.21N.02 Procedures SOP-0140 Suppression Pool Cleanup and Alternate Decay Heat 41
Removal
71111.21N.02 Procedures STP-057-3800 Local Leak Rate Test - Outage Summation 16
71111.21N.02 Procedures STP-204-6304 Div II RHR Quarterly Valve Operability Test 25
71111.21N.02 Procedures STP-209-3818 RCIC Penetration KJB-Z15 Valve Leak Rate Test 14
71111.21N.02 Work Orders WO-RBS- 00067202, 00111606, 00232968, 00361059, 00377354,
00419530, 52247989, 52763221, 52895690, 00408614,
00442627, 00523754, 00539666, 52670970, 52766967,
2800959, 52810875, 52896350, 52863845, 52863911,
00442627, 00222817, 00408614, 00178505, 00222817,
00469591, 00484868, 00494597, 00496171, 00513196,
00518871, 00518871, 00518871, 00525607, 00543336,
00553907, 00560225, 52441262, 52560099, 52560101,
Inspection Type Designation Description or Title Revision or
Procedure Date
2639670, 52639815, 52723206, 52767232, 52769527,
2771072, 52825271, 52830247, 52898905, 52902937,
2920964, 52887116,
10