IR 05000458/2023010
| ML23334A081 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 12/12/2023 |
| From: | Ami Agrawal NRC/RGN-IV/DORS |
| To: | Hansett P Entergy Operations |
| References | |
| IR 2023010 | |
| Download: ML23334A081 (26) | |
Text
December 12, 2023
SUBJECT:
RIVER BEND STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000458/2023010
Dear Phil Hansett:
On November 2, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your 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.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety. However, since the team noted that the 2021 biennial problem identification and resolution inspection, identified and documented weaknesses associated with categorization of issues documented in condition reports and with taking appropriate actions to address non-cited violations, the team reviewed actions taken since the issuance of that inspection report (05000458/2021010 (ML21064A220)). While the team noted that your staff has taken some actions to address the previously identified weakness, the team identified continued problems associated with categorization of issues documented in condition reports, and additional problems with timeliness of corrective actions. The team also noted some examples of problems with the evaluation of issues. These problems are discussed in more detail in this report and include a finding associated with evaluating operability of safety related systems for problems identified in condition reports.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety. However, the team found some examples of problems with evaluation and application of operating experience information. These problems are discussed in more detail in this report. Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found that your organization had a safety conscious work environment where individuals felt free to raise concerns without fear of retaliation through at least one of the several means available.
Two findings of very low safety significance (Green) are documented in this report. Two 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, Ami N. Agrawal, Inspection Programs
& Assessment Team Leader Inspection Programs & Assessment Team 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:
05000458/2023010 Enterprise Identifier:
I-2023-010-0006 Licensee:
Entergy Operations, Inc.
Facility:
River Bend Station Location:
St. Francisville, LA Inspection Dates:
October 16, 2023, to November 03, 2023 Inspectors:
L. Flores, Senior Resident Inspector Z. Hollcraft, Senior Reactor Operations Engineer R. Kumana, Senior Reactor Inspector E. Powell, Resident Inspector F. Ramirez Munoz, Senior Reactor Inspector Approved By:
Ami N. Agrawal, Inspection Programs & Assessment Team Leader Inspection Programs & Assessment Team Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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 Conduct Adequate Operability Evaluations Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2023010-01 Open/Closed
[P.1] -
Identification 71152B The inspectors identified a Green finding and associated non cited violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, with two examples, for the licensees failure to follow procedure EN-OP-104, Operability Determination Process, a quality related procedure. Specifically, the licensee failed to evaluate the effect on environmental qualification of the Reactor Core Isolation Cooling (RCIC) system turbine exhaust line drain pot isolation valve and American Society of Mechanical Engineers (ASME)
Class 2 code compliance of the Loop A Residual Heat Removal (RHR) drain line upstream of drain valve RHS-V207.
Failure to Implement Adequate Procedure for RCIC Steam Isolation Valve Operator Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2023010-02 Open/Closed None (NPP)71152B The inspectors documented a self-revealed Green finding and associated non-cited violation of Technical Specification 5.4.1.a for failure to establish written procedures appropriate to the circumstances covering activities recommended in Regulatory Guide 1.33, Revision 2,
Appendix A. Specifically, the licensee failed to establish adequate procedures for periodic maintenance on the reactor core isolation cooling (RCIC) system steam supply valve motor operator.
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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors sampled approximately 200 condition reports and their associated cause evaluations. The inspectors also conducted a five-year review of the residual heat removal system, which included review of failures, maintenance issues, surveillances, corrective and preventive maintenance, reliability, and maintenance rule performance. Additionally, inspectors reviewed a sample of findings and violations issued during the biennial assessment period.
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits, and self-assessments. The sample included industry operating experience communications like 10 CFR 50 Part 21 notifications and other vendor correspondence, NRC generic communications, publications from industry groups, and site evaluations. The sample also included reviews of licensee self-assessments and internal audits.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment. The team interviewed 54 individuals, observed interactions between licensee employees and management during routine meetings, interviewed the employee concerns program manager and reviewed employee concerns files.
INSPECTION RESULTS
Assessment 71152B Corrective Action Program Effectiveness Based on the samples reviewed, the team determined that the licensees corrective action program complied with regulatory requirements and self-imposed standards. The licensees performance in each of the areas of Problem Identification, Problem Prioritization and Evaluation, and Corrective Actions adequately supported nuclear safety.
Problem Identification Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety. Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety. The team determined that conditions that require generation of a condition report have been entered appropriately into the corrective action program.
Problem Prioritization and Evaluation Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team generally found that the licensee correctly characterized each condition report as to whether it represented a condition adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance. However, the inspectors noted that the last problem identification and resolution inspection report 05000458/2021010 (ML21064A220) documented a weakness associated with categorization of condition reports. In reviewing this issue, the team observed some continuing problems associated with condition report screening and categorization which are discussed below:
The inspectors reviewed condition reports categorized as non-adverse and identified multiple examples of condition reports that should have been categorized as adverse in accordance with procedure EN-LI-102, Corrective Action Program. The inspectors noted that both the previous problem identification and resolution team and the resident inspectors had identified multiple examples of incorrectly categorized condition reports in several inspection reports. In addition, the licensee's independent oversight organization identified and documented multiple examples of miscategorized condition reports in both the 2021 and 2023 corrective action program audits (QA-3-2021-RBS-1 and QA-3-2023-RBS-1), and during a review of corrective action program effectiveness performed in 2022. While the inspectors noted that the licensee had taken some actions to identify, correct, and decrease the number of miscategorized condition reports since the last problem identification and resolution inspection, the inspectors still identified 20 examples of condition reports that were incorrectly categorized during the inspection period. Of these condition reports, 14 were condition reports generated from 2020 to 2022, and six were generated in 2023. These failures to correctly categorize condition reports as adverse represented a minor violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for failure to follow procedure EN-LI-102, a quality related procedure. The inspectors determined the violation was minor because, for each of the examples identified, the failure to correctly categorize the condition reports did not adversely affect any of the associated cornerstones and the licensee documented this violation in condition report CR-RBS-2023-08126. This minor violation is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
In addition, the inspectors identified one example where the licensee inappropriately downgraded a condition report documenting a significant condition adverse to quality (SCAQ). Condition report CR-RBS-2022-05422 documented the failure of the high-pressure core spray (HPCS) diesel generator 4160 to 480 V transformer, which resulted in HPCS being inoperable and unavailable for approximately 13 days. The condition report was initially categorized as Category A (SCAQ). However, on September 22, 2022, the Performance Improvement Review Group (PRG) downgraded the condition report to Category B. This CR represented a loss of safety function because HPCS is a single train safety system. EN-LI-
includes Any condition which results in a loss of safety function as a criterion for an SCAQ. In addition, the definition includes Any condition or combination of conditions which has the potential or results in a Greater-than-Green NRC Finding. Based on the risk significance and resulting unavailability of HPCS, this should have been recognized immediately by licensee management as having the potential for a greater-than-green finding.
On January 19, 2023, the licensees performance improvement organization recognized that the condition met the definition of an SCAQ and generated condition report CR-RBS-2023-00412 to upgrade condition report CR-RBS-2022-05422 to Category A. EN-LI-102 Section 5.4 requires the PRG to determine if a condition is an SCAQ. On September 22, the PRG failed to determine that CR-RBS-2022-05422 was an SCAQ. This failure by the PRG to correctly categorize the condition as an SCAQ was a violation of 10 CFR 50, Appendix B, Criterion V, for failure to follow EN-LI-102, a quality related procedure. The inspectors determined that the violation was minor because the licensee recategorized the condition report and performed a root cause evaluation prior to the licensees closure of the condition report and the NRCs review of the issue and the licensee documented this violation in condition report CR-RBS-2023-08256. This minor violation is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
The inspectors also identified two examples of inadequate operability evaluations. These are documented in a Green NCV in the Inspection Results section of this report.
Corrective Actions Overall, the team concluded that the licensee's corrective actions supported nuclear safety.
Of the samples reviewed, the team generally found that the licensee developed effective corrective actions for the problems evaluated in the corrective action program.
However, the team identified some problems with timeliness of implementation of corrective actions. For example, the inspectors found that in some cases corrective actions closed to the work management system either did not get assigned the correct priority or were not accomplished in a reasonable amount of time given the safety significance.
For example, the inspectors reviewed the fix-it-now (FIN) teams work order backlog. This organization was tasked with important work activities that could be accomplished on a short-term basis without going through the normal work planning process. The inspectors noted that procedure EN-MA-130, Fix It Now (FIN) Team Process, section 5.1 states that work orders on the FIN backlog for more than 60 days should be returned to the normal work planning process. The inspectors found that there were 220 work orders on the FIN backlog, and all 220, or 100%, were older than 60 days. The licensee documented this issue in condition report CR-RBS-2023-08167. One example of these was work order WO-00589781.
In May 2021, condition report CR-RBS-2021-003419 was generated to document that a safety-related relay in the HPCS System Inoperative circuitry was defective. This was closed to the work management system, but work order WO-00589781 was not issued until December 2022. This work order was assigned to the FIN team but had not been completed at the time of the inspection. As a result, the work order has been assigned to FIN for over 300 days, and the condition has not been corrected for over 29 months. The inspectors determined that the condition was a condition adverse to quality, and that the failure to promptly correct it was a violation of 10 CFR 50, Appendix B, Criterion XVI. The inspectors determined that the violation was minor because the failed relay did not adversely affect the mitigating systems cornerstone and the licensee documented this violation in condition report CR-RBS-2023-08253.This minor violation is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Another example was associated with condition report CR-RBS-2018-02509, which documented an oil leak from a safety-related pump. This condition report was closed to work order WO-00500780, but the work order was incorrectly categorized as non-adverse. The licensee later cancelled this work order without correcting the condition adverse to quality.
The inspectors determined this was a violation of 10 CFR 50, Appendix B, Criterion XVI. The violation was minor because the failure to correct the condition did not adversely affect the mitigating systems cornerstone and the licensee documented this violation in condition report CR-RBS-2023-08257. This minor violation is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
In another case, the licensee had generated corrective actions in response to CR-RBS-2020-04429 related to correcting a non-conforming condition associated with the Unit 2 excavation flood control berm. Corrective action CA-26 resulted in generation of work order WO-569005 and CA-28 was initiated to obtain funding for the project. Procedure EN-WM-100, Work Order Generation, Screening and Classification, requires that work orders needed to correct a non-conforming condition should be coded G in the work management system, but WO-569005 did not get assigned the correct code. In May 2023, the work order was cancelled due to an individual mistakenly thinking it was a duplicate work order. In June 2023, CA-28 was cancelled due to funding not being available for the project. No additional actions were generated. In August 2023, licensee personnel identified that the work order covered by CA-26 and the action for CA-28 were closed. The licensee generated CR-RBS-2023-6378 to reestablish the required corrective actions. The misclassification and subsequent cancellation of the work order without adequate justification was a violation of 10 CFR 50, Appendix B, Criterion V, for failure to follow EN-WM-100, a quality-related procedure. The inspectors determined the violation was minor because the issue was identified and corrected without impacting the mitigating systems cornerstone and the licensee documented this violation in CR-RBS-2023-08254. This minor violation is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The inspectors also observed that EN-WM-100 has a vulnerability in that while work orders that have corrective actions closed to them are required to have PRG approval before being closed, work orders that are assigned to open corrective actions are not required to have PRG approval for closure. The licensee documented this observation in CR-RBS-2023-08261.
The inspectors also found that two radiation monitors (RMS-RE167 and RMS-RE171) have not been calibrated due to a lack of parts needed to repair the monitors. The inspectors noted that the station attempted to perform the required calibrations in 2022 but cancelled the work orders due to the monitors not functioning. The licensee generated condition reports CR-RBS-2022-01594 and CR-RBS-2022-02993 but has still not obtained the parts needed to restore the monitors. The inspectors did not identify a specific violation associated with corrective action due to these radiation monitors being non-safety-related, but questioned the timeliness of repair since the monitors are described in the USAR. The licensee documented this issue in condition report CR-RBS-2023-08265. In addition, the inspectors noted that the condition reports should have been categorized as adverse in accordance with EN-LI-102 but were categorized as non-adverse. This failure to categorize condition reports correctly was previously discussed earlier in this report.
The inspectors noted two examples where work that was correctly categorized and prioritized in the system was not performed in a timely manner due to the licensees outage scope process. For example, condition report CR-RBS-2021-06223 which documented a failure of a safety-related medium voltage breaker had planned actions to inspect similar breakers for extent-of-condition. Additionally, condition report CR-RBS-2021-00058 documented leak by on two safety related valves in the main steam leakage control system, and corrective actions were developed to correct the conditions. The actions to inspect the breakers and repair the valves were planned to be accomplished during the 2023 refueling outage, but the work orders were not added before the licensee froze the outage scope. Given the conditions were identified as early as 2021, the inspectors observed that the licensee had the time and opportunity to add this work into the 2023 outage plan, either before or after the initial outage scope was determined. Instead, the licensee deferred this work to 2025. The licensee documented this issue in condition report CR-RBS-2023-08262.
As part of this inspection, the team selected the plants residual heat removal system for a focused review within the corrective action program. For this system, the team performed sample selections of condition reports, looking at the adequacy of the licensee's evaluation process for determining which items are placed in the corrective action process, and the corrective actions taken. The team did not identify any concerns with this system that were not already being addressed by the station's monitoring and corrective action programs.
Assessment 71152B Use of Operating Experience The team reviewed a variety of sources of operating experience including part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups including INPO and EPRI. The team determined that, overall, River Bend Station is adequately screening and addressing issues identified through operational experience that apply to the station, and this information is being evaluated in a timely manner once it is received.
However, the inspectors noted that in some cases, the licensee uses narrow criteria to screen operating experience as applicable, or takes minimal actions to evaluate or address operating experience when additional actions might be warranted.
For example, when screening OE report NOE-HQN-2023-00326, which documented a boric acid leak resulting from poor maintenance practices on a large pump flange, the licensee considered it not applicable to River Bend Station because the plant does not use boric acid. The licensee did not consider whether the causal factors of improper maintenance were potentially applicable. After discussing this with the licensee, they generated condition report CR-HQN-2023-03545 and rescreened the report to evaluate whether the maintenance process issues were applicable to the station.
When evaluating OE report, OE-NOE-2021-00036, which documented a 10 CFR Part 21 report associated with potential non-conservatism in EPRI Software BWRVIP-235 and BWRVIP-100, the licensee screened this operating experience into category A2. After identifying during their evaluation that the Part 21 report affected River Bend Station, the licensee did not issue category A1 actions for River Bend. This is contrary to the guidance in EN-OE-100, Operating Experience Program. The licensee has written CR-HQN-2023-03616 to address this issue.
When evaluating OE report NOE-HQN-2023-00140, which documented control rod drift in a boiling water reactor due to leakage past the scram valves caused by design control issues, the licensee screened this operating experience as category B1 because they considered it an informational report. The inspectors questioned why this OE was not screened per their procedure as A1 due to the OE representing a potential condition adverse to quality, or A2 due to it describing a process issue, given that the OE occurred in a plant of similar design to River Bend Station. After discussions with the licensee, the inspectors found that they use a job aid to screen all Industry Reporting and Information System (IRIS) reports as B1, regardless of whether the OE represents a condition that may meet a higher screening level which would require a more detailed evaluation. The licensee has written CR-HQN-2023-03617 to address this concern.
In addition, the inspectors noted an example where the licensee failed to consider internal OE when maintaining their preventative maintenance strategies and procedures for aging breakers, resulting in the failure of the power supply to the A pump minimum flow control valve (MOVF064A) on February 21, 2021. The licensee's causal evaluation noted that there were twelve prior occurrences of similar breakers failing for similar reasons at River Bend Station, but they had not taken actions to update the maintenance procedures in accordance with Entergy corporate and industry guidance to prevent future failures of safety related components. As a result, the licensee did not maintain and implement adequate procedures for maintenance on safety-related breakers, which constituted a violation of Technical Specification 5.4.1. The inspectors determined that this violation was minor because the breaker failure did not result in appreciable loss of availability of the mitigating system and the licensee documented this violation in condition report CR-RBS-2023-08255. This minor violation is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Assessment 71152B Self-Assessments and Audits The inspectors reviewed a sample of River Bend Station's self-assessments and audits to assess whether performance trends were regularly identified and effectively addressed. The inspectors also reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the inspectors concluded that the licensee had an adequate departmental self-assessment and audit process.
Assessment 71152B Safety Conscious Work Environment The team conducted safety conscious work environment with 54 employees from six different disciplines that included security, operations, radiation protection, engineering, mechanical maintenance, and instrumentation and control maintenance. The purpose of these focus groups and interviews was
- (1) to evaluate the willingness of your staff to raise nuclear safety issues, either by initiating a CR or by another method,
- (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and
- (3) to evaluate your safety-conscious work environment (SCWE). The team also observed interactions between employees during routine daily plan-of-the-day meetings, condition report screening meetings, and performance improvement review group meetings. The team interviewed the employee concerns program Manager and reviewed a sample of case files that may relate to safety conscious work environment.
The team found that the licensee had a safety conscious work environment where individuals felt free to raise concerns without fear of retaliation. Most expressed positive experiences after raising issues to their supervisors and after documenting issues in condition reports, and all individuals indicated that they would not hesitate to raise safety concerns, though at least one of the several means available at the station. Based on feedback from these interviews regarding anonymous concerns, the station should consider enhancing communications with plant personnel so that it is better understood what avenues are available for employees and how anonymous concerns are processed. It is also important for management in all departments to remain a strong and reliable avenue where employees feel free to bring up safety concerns. When these avenues start to erode, it could eventually impact your staff's willingness to bring up concerns using that management avenue.
In addition, since Entergy recently transitioned to a new corrective action program software application used for writing and tracking condition reports, several employees expressed frustration that insufficient training was received during the release of the program. As a result, employees feel less comfortable writing new condition reports and it could impact employees willingness to use the corrective action program.
Failure to Conduct Adequate Operability Evaluations Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2023010-01 Open/Closed
[P.1] -
Identification 71152B The inspectors identified a Green finding and associated non cited violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, with two examples, for the licensees failure to follow procedure EN-OP-104, Operability Determination Process, a quality related procedure. Specifically, the licensee failed to evaluate the effect on environmental qualification of the Reactor Core Isolation Cooling (RCIC) system turbine exhaust line drain pot isolation valve and American Society of Mechanical Engineers (ASME) Class 2 code compliance of the Loop A Residual Heat Removal (RHR) drain line upstream of drain valve RHS-V207.
Description:
In the first example, on October 14, 2020, during a walkdown of the RCIC system, the licensee wrote condition report CR-RBS-2020-04320 documenting that a degraded conduit on the cable from a limit switch for the Reactor Core Isolation Cooling Turbine Exhaust Line Drain Pot AOV Isolation Valve, E51-AOVF005, was pulled back slightly from the junction box. The valve has an active safety function to close to isolate the drain line during RCIC operation and isolates when the RCIC steam supply valve, E51-MOVF045. The licensee documented the condition as non-adverse and affecting only the material condition of the valve. However, the licensee did not consider the environmental qualification (EQ) of the limit switch during the operability determination, nor was the condition documented as adverse to quality.
E51-AOVF005 is a Namco Limit Switch and is qualified per Environmental Qualification Assessment Report (EQAR) EQAR-016, NAMCO EA180-Series Limit Switches, Rev 6. The installation requires the use of qualified conduit thread sealant and a conduit seal for limit switches installed in EQ zones subject to pressurized steam followed by 100% relative humidity, where the E51-AOV005 limit switch is located.
EN-OP-104, Operability Determination Process, revision 16, was in effect at the time. Step 8.2.1 requires the licensee to determine whether a degraded or non-conforming condition exists, and if one does, to determine the impact of the condition on the affected components, by evaluating many different aspects of operation. Step 8.2.1.e, in part, directs the licensee to refer to Attachment 1, Operability Classification Guide, for specific guidance, where environmental qualification is discussed under Condition 25.
In the second example, on January 8, 2021, during a Residual Heat Removal (RHR) system leak test on RHR train A, a through-wall leak was discovered on a drain line upstream of drain valve RHS-V207. This piping was categorized as Class 2 under the American Society of Mechanical Engineers (ASME) code. The through-wall leak was documented in condition report CR-RBS-2021-00099. The initial operability determination declared the system operable based on the leak rate being within allowable limits. However, the licensee did not consider the effect of the through wall leak on the ability to maintain compliance with the ASME code.
EN-OP-104, Operability Determination Process, revision 16, was in effect at the time. Section 8.10.17, step 1.d, states, To determine if an ASME Class 2 or 3 SSC with a flaw is OPERABLE in an Immediate Determination, the degradation mechanism is readily apparent. In this case, with no discussion of the flaw, and given the nature of the subsequent analysis to apply an appropriate code case, the immediate operability determination should have been inoperable.
Corrective Actions: In the first example, the flex conduit was corrected on November 9, 2022, and the licensee wrote a condition report to evaluate past operability. In the second example, the licensee performed a subsequent engineering evaluation and non-destructive testing and appropriately applied an approved code case to justify operability. The flaw was subsequently repaired to restore full code compliance.
Corrective Action References: CR-RBS-2020-04320, CR-RBS-2021-00099, CR-RBS-2023-08249
Performance Assessment:
Performance Deficiency: The failure to follow procedure EN-OP-104, Operability Determination Process, is 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 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, in the first example, moisture intrusion into the RCIC system turbine exhaust line drain pot isolation valve limit switch junction box, an environmentally qualified component, can affect the availability and reliability of the component to function. In the second example, through wall leakage on ASME Class 2 RHR piping has the potential to affect the reliability and capability of the system to function.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, in the first example, moisture intrusion into the RCIC system turbine exhaust line drain pot isolation valve limit switch junction box, an environmentally qualified component, can affect the availability and reliability of the component to function. In the second example, through wall leakage on ASME Class 2 RHR piping has the potential to affect the reliability and capability of the system to function.
Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. In the first example, the licensee identified the condition as a material condition not adverse to quality and did not look at its environmental qualification in the operability determination. In the second example, the licensee did not identify that the through wall leak may have affected ASME code compliance of the drain line.
Enforcement:
Violation: Title 10 CFR 50, appendix B, criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. EN-OP-104, Operability Determination Process, revision 16, a quality related procedure, requires the licensee to determine whether a degraded or nonconforming condition exists, and if one does, to perform an evaluation that assesses all aspects of operation.
Contrary to the above, on October 14, 2020, and January 8, 2021, the licensee failed to perform an evaluation that assesses all aspects of operation when degraded or nonconforming conditions were identified, as evidenced by the following examples.
Specifically, the licensee failed to perform evaluations that assessed all aspects of operation for the reactor core isolation cooling and the residual heat removal systems when a degraded conduit on the cable from a limit switch and a through-wall leak respectively were identified.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Implement Adequate Procedure for RCIC Steam Isolation Valve Operator Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2023010-02 Open/Closed None (NPP)71152B The inspectors documented a self-revealed Green finding and associated non-cited violation of Technical Specification 5.4.1.a for failure to establish written procedures appropriate to the circumstances covering activities recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Specifically, the licensee failed to establish adequate procedures for periodic maintenance on the reactor core isolation cooling (RCIC) system steam supply valve motor operator.
Description:
On March 9, 2022, the RCIC system was started in support of Residual Heat Removal (RHR) heat exchanger testing. During the system start, operators identified that the RCIC Turbine Steam Admission Valve (E51-MOVF045), showed dual indication and did not indicate fully open as expected. The operators tripped the RCIC system and declared it inoperable.
The RCIC system provides makeup water to the core during a reactor shutdown in which feedwater flow is not available. The RCIC steam supply valve is a motor operated valve that opens and closes automatically to admit and isolate steam to the RCIC turbine. The valve motor operator has an anti-rotation torque arm on the valve stem to prevent rotation of the stem and maintain alignment of the limit switches, which indicate valve position.
The steam supply valve operator has periodic preventive maintenance and testing performed on it to maintain reliability and functionality of the valve. During investigation of the condition, the licensee identified that the torque arm had loosened and slipped off its key on the valve stem, allowing the valve stem to rotate and misalign the limit switches. This misalignment can impact the limit switch clocking and can result in the torque switch and limit switches not stopping the motor at either end of travel, challenging the ability of the valve motor to automatically start and stop, which could have prevented the system from automatically providing cooling water to the vessel.
A review of the work history identified that the torque arm was replaced in 2016 under WO-398644. Following replacement of the torque arm, the valve had a major inspection under WO-482410 on November 13, 2019. The licensee used a site-specific procedure, Model Work Order 50340454, E51-MOVF045 Static Signature Test, to perform the major inspection in 2019. The instructions in the model work order did not contain instructions to check torque arm screws for tightness.
On July 28, 2014, Entergy issued a fleet wide procedure, EN-MA-141, Limitorque Valve Operator Model SMB/SB/SBD-000 Through 5 MOV and HBC Periodic Inspection. This procedure is used for major inspections on valve operators and contains specific instructions for inspection of the valve stem torque arm, key, and stem keyway for wear or damage. The torque arm screws are checked for tightness and torqued if needed. However, this fleet wide procedure was not implemented at River Bend Station. Based on the valves work history, the torque arm screws had not been tightened since the replacement of the torque arm in 2016, which likely contributed to the separation of the torque arm from its key and resulting in the inoperability of the RCIC system.
Corrective Actions: The torque arm was re-installed on the valve stem and properly torqued.
The limit switches were reset, and testing was performed to confirm proper operation of the valve.
Corrective Action References: CR-RBS-2022-01401, CR-RBS-2019-05868, CR-RBS-2023-08251
Performance Assessment:
Performance Deficiency: The failure to establish adequate maintenance procedures on the RCIC steam supply valve operator is a performance deficiency. Specifically, the licensees site-specific model work order used to perform periodic testing on the valve operator did not contain adequate instructions to check valve stem torque arm tightness. As a result, operation of the valve caused the limit switches to misalign and show dual indication of the valve. RCIC system was tripped and declared inoperable.
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 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, this event resulted in an unplanned inoperability of the RCIC system.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined that this finding is of very low safety significance (Green), because the finding did not represent a loss of the PRA function of the RCIC system for greater than its TS allowed outage time.
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.
Enforcement:
Violation: Technical Specification 5.4.1.a, requires, in part, that procedures shall be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Step 9.a states, in part, that maintenance that can affect the performance of safety-related equipment should be performed in accordance with written procedures appropriate to the circumstances.
Contrary to the above, on November 13, 2019, for maintenance that can affect the performance of safety-related equipment (RCIC steam isolation valve), the licensee failed to properly preplan and perform the activity in accordance with written procedures appropriate to the circumstances. Specifically, Model Work Order 50340454, E51-MOVF045 Static Signature Test, did not contain adequate instructions to check the valve stem torque arm tightness for the RCIC steam isolation valve during maintenance and resulted in inoperability of the RCIC system on March 9, 2022.
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 November 2, 2023, the inspectors presented the biennial problem identification and resolution inspection results to Phil Hansett and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71152B
Calculations
G13.18.1.4*10
Design of Doors TU66-01 & TU67-149 and Evaluation of
Stresses in G-Tunnel End Wall
07/17/1991
71152B
Calculations
G13.18.8.0*004
Impact of the Construction of the ISFSI in the Unit 2
Excavation Area on the Design Basis Flood Levels for the
RBS Structures
10/05/2000
71152B
Corrective Action
Documents
CR-HQN-YYYY-
NNNNN
2019-02167,
20-02285,
23-02899
71152B
Corrective Action
Documents
CR-RBS-YYYY-
NNNNN
1997-02139,2011-02355,2014-05997,2015-02514
2018-02509,2018-05468,2018-05648,2019-05868,
2019-06924,2020-03586,2020-03649,2020-03701,
20-03710,2020-03729,2020-03873,2020-03880,
20-03889,2020-03926,2020-04147,2020-04149,
20-04150,2020-04154,2020-04160,2020-04163,
20-04167,2020-04208,2020-04210,2020-04220,
20-04221,2020-04222,2020-04242,2020-04310,
20-04320,2020-04326,2020-04338,2020-04429,
20-04444,2020-04458,2020-04543,2020-04586,
20-04591,2020-04645,2020-04832,2020-05036,
20-05039,2020-05040,2020-05391,2021-00058,
21-00099,2021-00113,2021-00278,2021-00482,
21-00494,2021-00744,2021-00794,2021-00795,
21-00848,2021-00932,2021-01186,2021-01189,
21-01220,2021-01324,2021-01998,2021-02240,
21-02260,2021-02287,2021-02356,2021-02384,
21-02443,2021-02490,2021-02495,2021-02616,
21-02626,2021-02669,2021-02694,2021-02786,
21-02862,2021-02970,2021-03006,2021-03086,
21-03120,2021-03147,2021-03221,2021-03359,
21-03419,2021-03423,2021-03512,2021-03568,
21-03618,2021-03695,2021-04305,2021-04366,
21-04464,2021-04506,2021-04827,2021-04915,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
21-05127,2021-05356,2021-05373,2021-05374,
21-05618,2021-05741,2021-05750,2021-06016,
21-06083,2021-06092,2021-06223,2021-06510,
21-06648,2021-07349,2021-07412,2021-07493,
22-00061,2022-00152,2022-00153,2022-00478,
22-00486,2022-00629,2022-00633,2022-00775,
22-00975,2022-01181,2022-01401,2022-01407,
22-01431,2022-01444,2022-01532,2022-01591,
22-01594,2022-01664,2022-01709,2022-01837,
22-02054,2022-02284,2022-02739,2022-02769,
22-02993,2022-02997,2022-03243,2022-04110,
22-05422,2022-05725,2022-07295,2023-00163,
23-00412,2023-00875,2023-01155,2023-02140,
23-02217,2023-02254,2023-02601,2023-02944,
23-02997,2023-03220,2023-03257,2023-03301,
23-03302,2023-03305,2023-03515,2023-03637,
23-03887,2023-04056,2023-04950,2023-04966,
23-04984,2023-05429,2023-05461,2023-05464,
23-05982,2023-05991,2023-05992,2023-05994,
23-06280,2023-06378,2023-06424,2023-06617,
23-06690,2023-06929,2023-07002,2023-07844,
23-07896,2023-07969,2023-08000
Corrective Action
Documents
Resulting from
Inspection
CR-HQN-YYYY-
NNNNN
23-03545,
23-03616,
23-03617
71152B
Corrective Action
Documents
Resulting from
Inspection
CR-RBS-YYYY-
NNNNN
23-07844,2023-07991,2023-08020,2023-08021,
23-08025,2023-08040,2023-08135,2023-08138,
23-08167,2023-081682023-08216,2023-08249,
23-08251,2023-08253,2023-08254,2023-08255,
23-08256,2023-08257,2023-08258,2023-08259,
23-08260,2023-08261,2023-08262,2023-08263,
23-08264,2023-08265
71152B
Engineering
0000022498
UPDATES REQUIRED TO CANCEL EQMSR AND ASSURE
05/29/2010
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Changes
PMS ARE IN PLACE
Engineering
Changes
0000031803
HVK CHILLER CONTROL DIGITAL UPGRADE (PARENT
EC)
07/18/2012
Engineering
Changes
0000091244
UNIT 2 EXCAVATION UPDATED FLOODING ANALYSIS
01/13/2022
Engineering
Changes
0000095143
CORRECT HVK CHILLER START TIMING
04/24/2023
Engineering
Changes
0000095150
CORRECT HVK-CHL1D START TIMING
04/24/2023
Engineering
Changes
0000095151
CORRECT HVK-CHL1B START TIMING
04/24/2023
Engineering
Changes
0000095152
CORRECT HVK-CHL1A START TIMING
04/24/2023
Engineering
Changes
0000095153
CORRECT HVK-CHL1C START TIMING
04/24/2023
71152B
Engineering
Changes
0000095461
UPDATE EN-IC-S-028-R FOR C41-LTN001 REFER CR-
06/20/2023
Miscellaneous
9/22/2022
Miscellaneous
21.452-000-
001N
Type 98L & 98H Back Press. & Relief Valves
2/14/1996
Miscellaneous
EQAR-002
Conax Electrical Conductor Seal Assemblies (ECSAs)
Miscellaneous
EQAR-004
EGS Quick Disconnect Bayonet Connectors
Miscellaneous
EQAR-016
Namco EA180-Series Limit Switches
Miscellaneous
JA-PI-03
OE Screening
Miscellaneous
JA-PI-121-01
Trend Codes
Miscellaneous
JA-PI-3
OE Screening
71152B
Miscellaneous
NOE-HQN-2023-
00113
Operating Experience - IRIS 554467
06/27/2023
Miscellaneous
NOE-HQN-2023-
00116
Operating Experience - IRIS 549313
06/27/2023
Miscellaneous
NOE-HQN-2023-
00140
IRIS 544275 - Control Rod Drift into the Reactor Core
07/17/2023
71152B
Miscellaneous
NOE-HQN-2023-
00155
NRC-IN-23-03 - Recent Human Performance Issues at
07/19/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
OE-NOE-YYYY-
NNNNN
20-00191, 2020-00203, 2021-00047, 2021-00046, 2020-
00144, 2021-00021, 2021-00036, 2021-00038, 2021-00111,
22-00059, 2022-00061, 2022-00064, 2022-00123, 2022-
00160
Miscellaneous
QA-10-2022-
RBS-1
Maintenance Audit
08/22/2022
Miscellaneous
QA-2/6-2023-
RBS-1
QUALITY ASSURANCE AUDIT REPORT: Combined
Chemistry, Effluents and Environmental Monitoring
09/25/2023
Miscellaneous
RBG-34558
Update to GL 89-13 Response
03/01/1991
Procedures
ARP-601-16
P601-16 Alarm Response
304
Procedures
ARP-601-21
P601-21 Alarm Response
317
Procedures
Engineering Health Reports
Procedures
EN-DC-143-02
Program Health Report Supplemental Guidance
Procedures
System Health Management
Procedures
NRC Generic Letter 89-13 Service Water Program
Procedures
Employee Concerns Program
Procedures
EN-FAP-LI-001
Performance Improvement Review Group (PRG) Process
71152B
Procedures
Corrective Action Program
Corrective Action Program
Corrective Action Program
Corrective Action Program
Corrective Action Program
Corrective Action Program
Self-Assessment and Benchmark Process
Causal Analysis Process
Fix It Now (FIN) Team Process
Limitorque Valve Operator Model SMB/SB/SBD-000 Through
MOV and HBC Periodic Inspection
Operating Experience Program
Operability Determination Process
Operability Determination Process
Operability Determination Process
71152B
Procedures
Conduct of Operations
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Nuclear Safety Culture Monitoring
Radiation Worker Expectations
EN-WM-02
Work Implementation and Closeout
Work Order Generation, Screening and Classification
On-Line Work Management Process
Work Implementation and Closeout
Fire Door Inspection
PMRQ 50037507-
STATIC SIGNATURE TEST - E51-MOVF045 (Model
50340454)
11/03/2023
71152B
Procedures
SEP-SW-RBS-
001
RBS GL89-13 Service Water & Heat Exchanger Program
71152B
Procedures
STP-000-3605
Automatic Hold-Open Fire Door Functional Test
303
Performance Improvement Deep Dive Summary Report
7/13/2022
Performance Improvement Deep Dive Summary Report
10/28/2021
QA-3-2021-RBS-
Corrective Action Program
7/1/2021
QA-3-2023-RBS-
Corrective Action Program
7/25/2023
QA-4-2022-RBS-
Engineering (Design Control) Audit Notification/Audit Plan
Memorandum
03/02/2022
QA-7-2021-RBS-
Emergency Preparedness [10CFR50.54(t)]
5/10/2021
QA-7-2023-RBS-
5/10/2023
QA-8-2023-RBS-
Engineering Programs Audit Notification/Audit Plan
Memorandum
2/15/2023
Self-Assessments
QS-2022-RBS-
003
22 Corrective Action Program Surveillance
5/5/2022
71152B
Work Orders
WO-RBS-
00323927, 00323938, 00589093, 52902287, 00390900,
00562244, 00552416, 00567590, 00594375, 00594376,
00594377, 00594378, 00594379, 52867836, 00568961,
00569699, 53022437, 52888228, 00557940, 00574435,
00568707, 00571962, 00579079, 00579080