IR 05000458/2023012
| ML23236A496 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 09/01/2023 |
| From: | Vincent Gaddy NRC/RGN-IV/DORS/EB1 |
| To: | Hansett P Entergy Operations |
| References | |
| IR 2023012 | |
| Download: ML23236A496 (24) | |
Text
September 01, 2023
SUBJECT:
RIVER BEND STATION - COMPREHENSIVE ENGINEERING TEAM INSPECTION REPORT 05000458/2023012
Dear Phil Hansett:
On August 3, 2023, 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.
Three 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 or a finding not associated with a regulatory requirement 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, 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:
Report Number:
Enterprise Identifier:
I-2023-012-0002
Licensee:
Entergy Operations, Inc.
Facility:
River Bend Station
Location:
St. Francisville, LA
Inspection Dates:
July 17, 2023 to August 3, 2023
Inspectors:
J. Braisted, Senior Reactor Inspector
D. Bryen, Reactor Inspector
W. Cullum, Senior Reactor Inspector
C. Franklin, Reactor Inspector
R. Kumana, Senior Reactor Inspector
D. Reinert, Senior Reactor Inspector
F. Thomas, Reactor Inspector
Approved By:
Vincent G. Gaddy, Chief
Engineering Branch 1
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a comprehensive engineering team 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 Procedure for Work Performed on Safety-Related 480 VAC Electrical Equipment Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000458/2023012-01 Open/Closed
[H.12] - Avoid Complacency 71111.21M The inspectors identified a Green finding involving the licensee's failure to initiate condition reports for observed elevated temperatures on safety-related switchgear in accordance with station procedure EN-DC-310.
Failure to Follow Instructions for Standby Service Water Flow Balance Testing Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2023012-02 Open/Closed
[H.5] - Work Management 71111.21M The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," with five examples, of the licensees failure to work order test instructions.
Failure to Maintain Test Records Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2023012-03 Open/Closed None (NPP)71111.21M The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVII, "Quality Assurance Records," for two examples of the licensees failure to maintain test records for the standby service water flow balance.
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
===71111.21M - Comprehensive Engineering Team Inspection The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:
Structures, Systems, and Components (SSCs) (IP section 03.01)===
- (1) Containment Unit Cooler A Return Header Inboard Containment Isolation Valve, SWP-MOV503A
Updated final safety analysis report, technical specifications, and technical specifications bases document
Motor-operated valve program document, environmental qualification reports, inservice testing plan, and standby service water system design criteria
Calculations for maximum expected differential and line pressure, torque and thrust setpoints, and the seismic/weak-link analysis
Standby service water system piping and instrumentation diagram and the motor-operated valve electrical schematic diagram
Valve and actuator vendor manuals for installation, operation, and maintenance
Inservice testing records including procedures and results for position indication, leakage, opening, and closing
Diagnostic testing records including procedures and results
Maintenance work order history records of visual inspections, packing adjustments, lubrications, and overhaul
Corrective action program documents
Visual inspection of the as-built configuration and material condition
- (2) Containment Unit Cooler A, HVR-UC1A
Updated safety analysis report, technical specifications, and technical specifications bases document
Environmental qualification reports and reactor plant ventilation system design criteria
Calculations for accident environmental conditions in containment, air intake free area of the unit cooler, and the maximum temperature of containment after a loss of offsite power Standby service water system piping and instrumentation diagram
Vendor manuals for installation, operation, and maintenance of the cooling coils and fan
Surveillance test records of air flow and standby service water system flow balancing
Maintenance work order history records of visual inspections
Corrective action program documents
Visual inspection of the as-built configuration and material condition
- (3) Division 1 Diesel Generator Room Standby Exhaust Fan, HVP-FN02A
Updated safety analysis report, technical specifications, and technical specifications bases document
Diesel generator building ventilation system design criteria
Calculations for electrical power supply for motor and controls, heat removal and ventilation attributes, damper design for normal and extreme conditions
Vendor manuals for installation, operation, and maintenance of the fan and dampers
Maintenance work order history records of visual inspections and cleaning/lubrication
Corrective action program documents
Visual inspection of the as-built configuration and material condition
- (4) Reactor Core Isolation Cooling Pump Injection Isolation Valve, E51-MOVF013
Updated final safety analysis report, technical specifications, and technical specifications bases document
Motor-operated valve program document, environmental qualification reports, inservice testing plan, and reactor core isolation cooling system design criteria
Calculations for maximum expected differential and line pressure, torque and thrust setpoints, and the seismic/weak-link analysis
RCIC system piping and instrumentation diagram and the motor-operated valve electrical schematic diagram
Valve and actuator vendor manuals for installation, operation, and maintenance
Inservice testing records including procedures and results for position indication, leakage, opening, and closing
Diagnostic testing records including procedures and results
Maintenance work order history records of visual inspections, packing adjustments, lubrications, and overhaul
Corrective action program document
- (5) Division 1 Diesel Generator, EGS-EG1A
Updated final safety analysis report, technical specifications, and technical specifications bases document.
Diesel generator lube oil and jacket water system design criteria.
Calculations for electrical loading and environmental conditions.
Vendor manuals for installation, operation, and maintenance of the diesel engine and generator.
Diesel generator operating logs
Diesel generator reliability program procedures and records.
Maintenance work order history records.
Corrective action program documents.
Visual inspection of the as-built configuration and material condition.
- (6) Division 1 Diesel Fuel Oil Transfer Pump, EGF-P1A
Updated final safety analysis report, technical specifications, and technical specifications bases document
Design basis documents
System operating procedures
Corrective action program documents.
Visual inspection of component during walkdown
Surveillance testing records including procedures and results
- (7) Diesel Generator Loading & Sequencing
Updated final safety analysis report, technical specifications, and technical specifications bases document
Design calculations and associated engineering changes
Surveillance testing records including procedures and results
- (8) Standby Service Water Pump 2B, SWP-P2B
Updated final safety analysis report, technical specifications, and technical specifications bases document
Vendor pump curves
Design basis calculations for standby service water system flow
Net positive suction head requirements
Pump runout condition calculations
Preventative maintenance tasks
Vendor manuals and recommendations
Corrective action program documents
Standby service water system piping and instrumentation diagrams
Visual inspection of the as-built configuration and material condition
- (9) Reactor Core Isolation Cooling Turbine Steam Supply Isolation Valve, E51-MOVF045
Updated final safety analysis report, technical specifications, and technical specifications bases documents
Motor-operated valve design calculations and program guidance
Motor-operated valve weak link analysis including seismic
Visual inspection of the as-built configuration and material condition
RCIC system piping and instrumentation diagram
Preventative maintenance tasks
Corrective action program documents
- (10) Division 1 Standby 480V Switchgear 2A, EJS-SWG2A
Updated final safety analysis report, technical specifications, and technical specifications bases document.
Visual inspection of switchgear for as-built configuration and material condition
Environmental conditions for equipment
Voltage analysis and short circuit calculations
Protection settings and coordination study
Vendor manual for conformance with manufacturer instructions for installation and maintenance
Preventive maintenance and periodic verification testing
Component maintenance history
Schematic and wiring drawings
System health report
Corrective action program documents
- (11) Division 2 Standby 480V Transformer 2B, EJS-X2B
Updated final safety analysis report, technical specifications, and technical specifications bases document.
Electrical drawings
Component maintenance history and corrective action program documents
Procedures for transformer inspection, maintenance, and testing
Thermography procedure and results
Voltage analysis and short circuit calculations
Visual inspection of switchgear for as-built configuration and material condition
Environmental conditions for equipment
System health report
Vendor manual and plant design drawings
Modifications (IP section 03.02) (4 Samples)
- (1) EC 80652, Permanent Shielding AB-07/10-93 & RB-9B
- (2) EC 93930, Raise the Level of the Main Turbine Level 8 Trip to Ensure no Overlap with RPS
- (3) EC 92964, Standby Diesel Generator Fuel Line Replacement
- (4) EC 94914, Gear Ratio Change for G33-MOVF053 10 CFR 50.59 Evaluations/Screening (IP section 03.03) (19 Samples)
- (1) EC 84684, Replace Minimum Flow Feedwater Regulating Valve C (FWR-FV2C) Steel Piston Ring with Graphite Piston Ring to Prevent Valve Sticking
- (2) EC 88823, Evaluation of Temperature Difference in HPCS Room while HPCS Is Running and HVR-UC5 Is Running per CR-RBS-2020-03649 CA 0004
- (3) EC 88938, Evaluation of River Bend Spent Fuel Cooling Heat Exchangers (SFC-E1A and SFC-E1B) Degraded Performance Documented in CR-RBS-2020-2064 (SFC-E1A) And CR-RBS-2020-3877 (SFC-E1B)
- (6) EC 85966, Equivalent Replacement Valve for EG1-V137
- (7) EC 92964, Standby Diesel Generator Fuel Line Replacement
- (8) EC 86722, Tornado Missile Risk Evaluator (TRME)
- (9) EC 89710, Removal of Ovation Point TCS Push Button Trip from Scan
- (13) EC 94914, Gear Ratio Change for G33-MOVF053
- (14) EC 0000093476, RBS Appendix J Program Scope Reduction
- (15) EC 0000089499, E12-MOVF021 Equivalency
- (16) EC 0000084643, Replace SWP-MOV40C With Tricentric Butterfly
- (17) EC 75637, Replace 2 J11 Gould Relays with 3 Allen Bradley Relays
- (18) EC 75802, Replace 5 Obsolete Gould J11 Relays in EJS-SWG1A
- (19) EC 94412, Nuclear Instrumentation Cable Splice Evaluation
Operating Experience Samples (IP section 03.04) (3 Samples)
- (1) NOE-2021-0083, IRIS 498875 - Reactor Feedwater Pump Turbine Trip and Eight Percent Power Reduction
- (2) NOE-2022-00185, Part 21 60-Day Final Report Notification: GNF3 Raised Water Rod
- (3) NOE-2019-00168, NRC Information Notice 2019-02 Emergency Diesel Generator Excitation System Diode Failures
INSPECTION RESULTS
Failure to Follow Procedure for Work Performed on Safety-Related 480 VAC Electrical Equipment Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000458/2023012-01 Open/Closed
[H.12] - Avoid Complacency 71111.21M The inspectors identified a Green finding involving the licensee's failure to initiate condition reports for observed elevated temperatures on safety-related switchgear in accordance with station procedure EN-DC-310.
Description:
The purpose of the licensees predictive maintenance program is to improve plant safety, equipment availability, and reliability through early detection and analysis of equipment problems and degradation prior to equipment failure. The inspectors reviewed thermography data in work order (WO) 52952270 that was recorded as part of the Predictive Maintenance Program and noted that there were several instances where temperature rises for certain components met the action level criteria identified in the work orders and in procedure EN-DC-310, "Predictive Maintenance Program." Specifically, the inspectors reviewed the last several performances of the Division 2 thermography work orders and noted a progressively increasing trend in the temperature rise above ambient for EJS-SWG2B, standby 480 VAC Switchgear 2B, and EHS-MCC15B, standby 480 VAC motor control center 15B.
"Attachment 3, Data Evaluation," of EN-DC-310 defines the action levels to be used to classify anomalous temperature rises for 480 VAC equipment. Attachment 3, sections 2.7 through 2.9, state that a condition report and work request should be initiated for all conditions identified as level 1 or above.1 It also states, in part, that emphasis should be placed on observed trends and that severity of temperature indication must be determined by evaluation. Furthermore, when degraded conditions are indicated, the predictive maintenance team will take appropriate actions to ascertain the validity of the data and notify the system engineer and other appropriate personnel of the condition.
The thermography data from the reviewed work orders indicate that action levels up to level 3 have been reached. Level 3, denoted as Action, is defined as a temperature rise in excess of 50 degrees Fahrenheit (F) above an established reference temperature.
Section 6.7 of procedure EN-DC-310, "Predictive Maintenance Program," titled "Equipment Health Classification" indicates that the equipment health classification of Action suggests that accelerated degradation is expected, and that the following actions be taken:
1. Contact Operations, System Engineer and/or Component Engineer.
2. Compare the inspection results with other predictive maintenance trending information.
3. Ensure a Condition Report and Work Request/ECR or EC has been initiated to resolve
issue.
4. Recommend scheduling an emergent Work Request into the normal scheduling process.
According to the licensee, none of the above actions were taken. Thus, inspectors expressed concern that there could be a progressing degraded condition on safety-related components that has not been identified or evaluated.
Standby 480V Switchgear 2B contains several Square D MasterPact circuit breakers. Vendor Manual S345-148, page 9 of 479, indicates an operating temperature range of -22 degrees F and +140 degrees F for the Square D MasterPact circuit breakers. With maximum switchgear surface temperatures exceeding 140 degrees F, the inspectors expressed concern that these circuit breakers could be exposed to temperatures more than their established operating range for longs periods of time.
Based on interviews with engineering program personnel, there were no condition reports that could be found associated with the action level 1 or above temperature conditions, and there was no available documentation to indicate that any evaluation of observed trends or any corrective actions taken to address degraded conditions.
Corrective Actions: The licensee initiated condition reports to enter this concern into their corrective action program and to further review thermography data and other predictive maintenance trending information Division 2 Class 1E 480 VAC equipment for indications of accelerated degradation.
Corrective Action References: CR-RBS-2023-05997 and CR-RBS-2023-06233
Performance Assessment:
Performance Deficiency: The licensee failed to follow station procedures for work performed on safety-related equipment. Specifically, the licensee failed to write a condition report for observed temperature rise conditions that met procedure action levels on safety-related switchgear EJS-SWG2B and motor control center EHS-MCC15B in accordance with procedure EN-DC 310, "Predictive Maintenance Program."
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the licensee failed to identify a deficient and deviating condition of significant temperature rise on EJS-SWG2B, standby 480 VAC Switchgear 2B, and EHS-MCC15B, standby 480 VAC motor control center 15B. If not addressed, this temperature rise could potentially lead to the degradation and failure of other internal components (i.e., relays and circuit breakers). Section 6.7 of the procedure EN-DC-310, titled Equipment Health Classification (Pages 19 and 20) indicates that the equipment health classification of Action means that accelerated degradation is expected.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Exhibit 2
- Mitigating Systems Screening Questions, Item A. Mitigating SSCs and PRA Functionality (except Reactivity Control Systems), specified that if the finding affected the design or qualification of a mitigating SSC, but it maintained its operability or PRA functionality then it screens to Green. The progressive increase in temperature rise on standby 480V switchgear 2B standby 480V motor control center 15B had not resulted in any known equipment failures.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, licensee personnel failed to question the anomalous measured data or compare the measurements with historical trends.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
Failure to Follow Instructions for Standby Service Water Flow Balance Testing Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2023012-02 Open/Closed
[H.5] - Work Management 71111.21M The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," with five examples, of the licensees failure to work order test instructions.
Description:
While reviewing documentation for the standby service water system flow balance tests, the inspectors identified five examples of the licensees failure to follow the test instructions.
Specifically:
The inspectors reviewed work order (WO) 323927 from the Division 2 standby service water system flow balance test conducted in December 2017. Step 4.3.4 stated Compare the collected data with acceptance criteria specified in Attachment 1, Flow Acceptance Criteria. Contrary to this step, the inspectors noted the following three issues:
The range of flow transmitter SWP-FT69B used to measure flow for HVK Chiller 1B and 1D is 0 to 670 gallons per minute (gpm). The maximum acceptable flow rate for HVK-CHL1B/D is 756 gpm. Therefore, the flow transmitters range is not suitable for the test. The acceptance criteria was not verified.
An alarm was used to demonstrate flow rate to ES001, the high-pressure core spray diesel generator cooler, was not below 700 gpm. However, no definitive value was taken for the ES001 flow rate. The minimum flow rate for ES001 is 800 gpm. The flow rate exceeding 700 gpm is not confirmation that it met the acceptance criteria.
The acceptance criteria for radiation monitors RMS-RE11A/B and RMS-RE15A/B is to verify flow exists. No flow measurement was taken for these components and a licensee technician annotated the work order package to indicate that these components were omitted from testing. Therefore, the acceptance criteria was not met.
Similarly, in the Division 1 standby service water system flow balance test WO 512093 conducted in March 2019, step 4.3.4 stated Compare the collected data with acceptance criteria specified in Attachment 1, Flow Acceptance Criteria. Contrary to this step four component flow rates were recorded with readings outside the acceptance criteria. However, all of the readings were marked acceptable in the work order.
In another instance, the Division 1 standby service water system flow balance test WO 323938 in November 2020, step 4.1.1.4 again stated Compare the collected data with acceptance criteria specified in Attachment 1, Flow Acceptance Criteria. The licensee recorded low flow for LSV-C3A, the penetration valve leakage control compressor. The licensee had previously determined the minimum acceptable flow rate to be 40 gpm and the flow rate recorded was 39.9 gpm. Licensee engineers approved of the deviation citing expected measurement and test equipment error, but no formal past operability determination was performed as required by the licensee procedure EN-LI-108, Event Notification and Reporting.
The inspectors also noted that WO 323938 for performance of the standby service water flow balance test in October 2019 contained a component / plant impact assessment statement which described many issues the licensee has encountered during historic performances of the standby service water flow balance tests. The challenges described include ownership of the work activity, resources, work schedule conflicts, radiological concerns, emergent work, procedural adequacy, and control of test instructions. It is unclear if any of these issues have been previously addressed in the corrective action program.
Corrective Actions: The licensee entered each procedural compliance issue into the corrective action program and performed operability evaluations to verify that the deficient flows had not rendered the affected components incapable of performing their required safety functions.
Corrective Action References: CR-RBS-2023-05991, CR-RBS-2023-05992, CR-RBS-2023-05994, CR-RBS-2023-05982, and CR-RBS-2023-06196
Performance Assessment:
Performance Deficiency: The licensee failed to follow a quality-related procedure in accordance with 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings." Specifically, the inspectors identified five examples of the failure to compare collected test data with established acceptance criteria.
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, the failure to perform a past operability evaluation on LSV-C3A created a doubt as to the past operability of the component. As a result, the component could have insufficient heat removal during a design basis accident.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Exhibit 2
- Mitigating Systems Screening Questions, Item A. Mitigating SSCs and PRA Functionality (except Reactivity Control Systems), specified that if the finding affected the design or qualification of a mitigating SSC, but it maintained its operability or PRA functionality then it screens to Green. The licensee was able to demonstrate that, through an updated methodology for calculating uncertainty, the component would have maintained positive margin and, therefore, remained operable. Specifically, the standby service water train would have maintained its function although one component may not have the required flow.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. This cross-cutting aspect was chosen because it reflects the station's difficulty in assigning priority and resources to complete this work activity.
Enforcement:
Violation: 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"
requires, in part, "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
Contrary to the above, from December 2017 until November 2020, the licensee did not accomplish activities affecting quality in accordance with prescribed procedures. Specifically, the licensee did not compare collected test data with established acceptance criteria in accordance with work instructions for conducting standby service water system flow balance test work instructions.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Maintain Test Records Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2023012-03 None (NPP)71111.21M Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVII, "Quality Assurance Records," for two examples of the licensees failure to maintain test records for the standby service water flow balance.
Description:
While reviewing documentation for the standby service water pumps, inspectors requested the work orders for recently completed standby service water flow balance tests. The flow balance test is conducted to verify that all components cooled by the safety-related standby service water flow loops receive appropriate flows. Upon retrieval of the work order packages, it was discovered that two of the work orders did not contain the completed paperwork and the flow data was missing.
Specifically:
Work order 51695027 for the performance of Division 1 standby service water flow balance testing in 2014 did not contain the completed test data. In the work order package 51008285 for Division 2 standby service water flow balance testing in 2008 the completed work order could not be located.
Although the completed data was not retained, the work orders contained statements that indicated the work was performed and no preventative maintenance tasks were missed.
However, it is unknown if all the results were acceptable since the data is missing.
Corrective Actions: The licensee wrote condition reports to document the missing records.
Corrective Action References: CR-RBS-2023-05938 and CR-RBS-2023-05911
Performance Assessment:
Performance Deficiency: The licensee's failure to maintain quality records for standby service water flow balance tests in accordance with 10 CFR Part 50, Appendix B, Criterion XVII, "Quality Assurance Records," was a performance deficiency.
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, subsequent standby service water flow balance testing found that several components were outside of the acceptance criteria, which called into question whether the 2008 and 2014 testing had satisfactory results. This is consistent with IMC 0612 Appendix E Minor Examples 1.a and 1.b.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Exhibit 2
- Mitigating Systems Screening Questions, Item A. Mitigating SSCs and PRA Functionality (except Reactivity Control Systems), specified that if the finding affected the design or qualification of a mitigating SSC, but it maintained its operability or PRA functionality then it screens to Green. Even though subsequent testing reveal that several components were outside the acceptance criteria, the licensee was able to demonstrate through analysis that operability was maintained.
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 missing data in the work orders are from 2008 and 2014. The subject work activities have been performed more recently and those records were retained.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion XVII, " Quality Assurance Records,"
requires, in part, " Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include at least the following: Operating logs and the results of reviews, inspections, tests, audits, monitoring or work performance, and materials analysis. Inspection and test records shall, as a minimum identify the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted. Records shall be identifiable and retrievable.
Contrary to the above, in 2008 and 2014, the licensee did not ensure that sufficient records were maintained to furnish evidence of activities affecting quality. Specifically, standby service water flow balance work orders 51695027 and 51008285 did not contain completed test data.
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 August 3, 2023, the inspectors presented the comprehensive engineering team inspection results to Phil Hansett and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
28.212-047-
008D
Seismic Analysis 6" Forged Bolted Bonnet Gate Valve
ASME Class 150-600 lb. Carbon Steel Nuclear Class 1, 2 &
Calculations
28.212-047-
016C
Design Report 6" - 900LB PS Gates Valve
Calculations
28.212-047-
053A
Weak Link Calculation for 6" Class 150 Forged Carbon Steel
Bolted Bonnet Motor Operated Butt Welded End Gate Valve
Calculations
28.212-
047.040C
Weak Link Analysis - Seismic Qual of M.O. Valves
B
Calculations
28.201-007-
001A
Selection Procedures & Switch Setting Charts
300
Calculations
E-176
Standby Load Center, MCC, and 120 Volt Panel Short
Circuit Calculation
Calculations
E-178
Voltage Drop Calculation for Standby 480 & 120/240 Volt
Distribution System
07/27/1987
Calculations
E-192
Standby Diesel Generator Loading Calculation
Calculations
E-200
Overcurrent Device Setpoints
Calculations
E-219
480 VAC Normal & Standby Motor Control Centers, Load
Tabulation
Calculations
E-222
Load Tabulation for 480VAC Normal and Standby Load
Centers
Calculations
E-222-E22-S002
E-222-E22-S002, 480VAC Standby Motor Control Center
Load Tabulation Including Cable Verification
Calculations
G13.18.10.2*025
Temporary Lead Shielding on Line on RHR System
Calculations
G13.18.12.2-022
River Bend Station - Combustible Loading
Calculations
G13.18.13.2*086
Effects of Maximum Safeguards Operation on the Ultimate
Heat Sink (Standby Cooling Tower)
Calculations
G13.18.14.0*042
Standby Service Water Performance With Only One Pump
Calculations
G13.18.14.0*112
Hydraulic Analysis of Flow-Balanced Service Water System
Calculations
G13.18.14.0*116-
Volume of Water in the Service Water System
Calculations
G13.18.14.0-30
Service Water Pump Trip Pressure Transient
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
G13.18.2.1*083
Diesel Generator Building Design Basis Calculation -
Summer Condition
Calculations
G13.18.2.1*086
Diesel Generator Building Design Basis Calculation - Winter
Condition
Calculations
G13.18.2.1*089
Determine Air Intake Free Area for Containment Unit
Coolers HVR-UC1A/B/C
Calculations
G13.18.2.1-084
Diesel Generator Building Calculation for Fan Total
Pressure
Calculations
G13.18.2.3*286
GL 89-10 Design Basis Review for SWP-MOV503A/B
Calculations
G13.18.2.3*304
Computer Model Pressures and Flowrates Generated for
the Service Water System in Support of GL 89-10
Calculations
G13.18.2.3*325
River Bend Station NRC Generic Letter 96-05 AC MOV
Actuator Output Capability Calculation
Calculations
G13.18.2.3-198
G.L. 89-10 Design Basis Review for E51-MOVF013
Calculations
G13.18.2.4*047
Standby Service Water Division 1 and 2 Small Bore Cross
Tie Sizing - Flow rate and Orifice Sizing
Calculations
G13.18.3.6*016
Degraded Voltage Calculation for Class IE Buses and 480V
Motor Operated Valves
Calculations
G13.18.4.6-002
Normal Service Water System Heat Loads
Calculations
G13.18.4.6-005
Size New Service Water Pumps
Calculations
PB-268
Maximum Temperature of Containment Outside of the
Drywell During Loss of Offsite Power
0A
Calculations
Standby Service Water Pump Capacity Verification
Calculations
Z-78-2011A
Pipe Support
Corrective Action
Documents
Condition Report
(CR-RBS-)
20-02064, 2020-03877, 2020-03649, 2017-05785, 2021-
2445, 2023-03268, 2017-01527, 2022-05725, 2022-03801,
22-03133, 2022-04193, 2023-01877, 2023-05943, 1997-
01784, 2014-00752, 2022-03172, 2023-06037, 2021-02926,
21-01712, 2022-06400, 2019-06442, 2015-03407, 2018-
05468, 2018-05478, 2018-05479, 2021-00626, 2022-01853,
23-03237, 2023-03409, 2022-01845, 2020-05179, 2022-
04193, 2023-02005
Corrective Action
Condition Report
23-05104, 2023-05863, 2023-05868, 2023-05869, 2023-
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Resulting from
Inspection
(CR-RBS-)
05875, 2323-05902, 2023-05905, 2023-05908, 2023-05909,
23-05911, 2023-05927, 2023-05934, 2023-05936, 2023-
05938, 2023-05943, 2023-05944, 2023-05945, 2023-05946,
23-05948, 2023-05949, 2023-05950, 2023-05973, 2023-
05976, 2023-05979, 2023-05982, 2023-05985, 2023-05986,
23-05991, 2023-05992, 2023-05994, 2023-05997, 2023-
06037, 2023-06059, 2023-06101, 2023-06105, 2023-06172,
23-06196, 2023-06204, 2023-06214, 2023-06231, 2023-
233
Drawings
EE-001A
Main One Line Diagram, Key Drawing, Power Distribution
Drawings
EE-001AB
480V One Line Diagram, Standby Bus, EJS-LDC1B & EJS-
LDC2B
Drawings
EE-001AC
Start Up Electrical Distribution Chart
Drawings
ESK-06HVR09
Elementary Diagram, 480V Switchgear, Containment Unit
Cooler, HVR-UC1A
Drawings
ESK-07HVC25,
Sheet 1
Elementary Diagram, 120VAC Control Circuit, Remote
Shutdown, Transfer Relays
Drawings
ESK-07HVK03,
Sheet 1
Elementary Diagram, 120VAC Control CKT [Circuit],
Remote Shutdown Transfer Relays
Drawings
ESK-07HVR20,
Sheet 1
Elementary Diagram, 120VAC Control Circuit, Remote
Shutdown Transfer Relays
Drawings
PID-09-10A
Engineering P & I Diagram System 118 Service Water -
Normal
Drawings
PID-09-10C
Engineering P & I Diagram System 118 Service Water
Normal
Drawings
PID-09-10D
Engineering P & I Diagram System 118 Service Water -
Normal
Drawings
PID-09-10F
Engineering P & I Diagram System 118 Service Water
Normal
Drawings
PID-09-10G
Engineering P * I Diagram SWP Corrosion Coupon and
Monitoring Rack System118 "C" Tunnel EL. 67'-6"
Drawings
PID-09-10H
Engineering P & I Diagram System 118 Service Water -
Normal
Drawings
PID-22-07A
Engineering P & I Diagram System 405 HVAC - Diesel
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Generators
Drawings
PID-22-14D
Engineering P&I Diagram, System 410, HVAC-Chilled Water
Drawings
PID-27-06A
Engineering P & I Diagram System 209 Reactor Core
Isolation Cooling
Drawings
PID-27-07A
Engineering P & I Diagram System 204 Residual Heat
Removal - LPCI
Engineering
Changes
Prepare Markup of Calculation E-192 and G13.18.3.6*019 to
Generator Frequency Analytical Limits
Engineering
Changes
Diesel Generator Margin Recovery Governor Setpoint
Change
Engineering
Changes
Div 2 Diesel Generator Margin Recovery Governor Setpoint
Change
Engineering
Changes
Diesel Generator Margin Recovery Calculation Updates
Engineering
Changes
Div 1 Diesel Generator Margin Recovery Governor Setpoint
Change
Engineering
Changes
Replace 2 J11 Gould Relays with 3 Allen Bradley 700-
P400A1 W/ 700-PLL11A1 Relays in EJS-SWG2A
000
Engineering
Changes
Replace 5 Obsolete Gould J11 Relays in EJS-SWG1A
000
Engineering
Changes
Update to Hydrogen Igniter Vendor Equivalency Evaluation
000
Engineering
Changes
Permanent Shields AB-07/10-93 & RB-9B
Engineering
Changes
RBS Appendix J Program Scope Reduction EC Evaluation
000
Engineering
Changes
Equivalent Replacement Valve for EGA-V137 Check Valve
for Diesel Generator Air Start System
000
Engineering
Changes
Evaluate Temperature Differ in HPCS Room While HPCS Is
Running and HVR-UC5 Is Running per CR-RBS-2020-
03649 CA 0004
Engineering
Changes
Document Updates for Hydrogen Igniter Replacement
001
Engineering
Evaluation Due to External Flood In-Leakage to Annulus
000
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Changes
Area Under PMF Event
Engineering
Changes
Raise the Level of the Main Turbine Level 8 Trip to Ensure
No Overlap with RPS
000
Engineering
Changes
NI [Nuclear Instrument] Cable Splice Evaluation
000
Engineering
Changes
Level 8 Turbine Trip Setpoint Change
000
Engineering
Changes
Replace SWP-MOV40C With Tricentric Butterfly
Engineering
Changes
E12-MOVF021 Equivalency
Engineering
Changes
RBS Appendix J Program Scope Reduction Evaluation
Engineering
Changes
Gear Ratio Change for G33-MOVF053
Engineering
Evaluations
RBS-CS-15-
00009
RBS Fukushima Flooding Hazard Re-Evaluation - Local
Intense Precipitation
000
Miscellaneous
1.ILEGT.008
Diesel Generator Jacket Circ Pump and Heater
Miscellaneous
200.010
Structural Design Criteria for River Bend Station - Unit 1
Miscellaneous
215.252
Containment Unit Coolers and Auxiliary Building Unit
Coolers With ASME III, Class 3 Coils
Miscellaneous
244.700
Standby Diesel Generator Systems
Miscellaneous
242.526-082
ITE Motor Control Center Instruction Manual
06/26/1985
Miscellaneous
242.533-265-
003
Installation and Operating Instruction Manual, 480V Standby
Load Centers
06/01/1983
Miscellaneous
242.533-265-
003B
Installation and Operating Instruction Manual, 480V Standby
Load Centers
06/01/1983
Miscellaneous
242.562-082-
001A
Instruction Manual, Installation, Operation and Maintenance
of Motor Control Centers
301
Miscellaneous
A160-0159
Heavy Duty Industrial Relays, 700-P-Series, Allen Bradley
000
Miscellaneous
B515-0102
Buffalo Forge Axial Fan Service Manual
Miscellaneous
B515-0121
Buffalo Forge Installation and Operation Instructions for Air
Handling Cabinets
Miscellaneous
B515-0136
Installation and Maintenance of Axial Flow Fans
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
EA-RA-92-0001-
M
Conformance of River Bend Station Blackout Rule (10 CFR 50.63) and NUMARC 87-00
Miscellaneous
EDS-ME-017
Lead Shielding
Miscellaneous
EQAR-007
Raychem Heat Shrink & Tubing Kits
Miscellaneous
EQAR-024
Westinghouse Medium Duty Motors
Miscellaneous
EQAR-027
Limitorque Motorized Valve Actuators with Class RH
Insulated AC Motors
Miscellaneous
SDC-203
Safety Related 4.16KV Electrical Distribution System Design
Criteria
Miscellaneous
SDC-209
Reactor Core Isolation Cooling System Design Criteria;
System Number 209
Miscellaneous
SDC-303
Safety Related 480 V Electrical Distribution System Design
Criteria, System Number 303
Miscellaneous
SDC-309
Standby Diesel Generator Division I & II Diesel Generator
Building Ventilation System, System Design Criteria
Miscellaneous
SEP-RBS-IST-1
RBS Inservice Testing Bases Document
Miscellaneous
SWP-MOV503A-
MOV TEST REPORT
08/27/2018
Miscellaneous
V085-0138
Velan IOM for Manual Operated Bolted Bonnet Gate, Globe,
Stop Check and Check Valves
Miscellaneous
VTD-C634-0112
Transamerica Delaval Instruction Manual for Model DSR-48
Diesel Engine/Generator
Miscellaneous
VTD-G080-0105
General Electric Instructions Type AKD-6 Low Voltage
Switchgear
Miscellaneous
VTD-S322-0100
Southern Transformer Guide for Installation and
Maintenance of Dry-Type Transformers
Procedures
Procedures
Primary Containment Control
Procedures
Station Blackout
Procedures
CMP-EM-000-
1009
Masterpact Circuit Breaker Clean and Inspect
013
Procedures
CMP-EM-000-
1013
480 Volt Switchgear Clean and Inspect
003
Procedures
EN-DC-115-01
Industry Standard Design Process (IP-ENG-001)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Post Modification Testing and Special Instructions
Procedures
Emergency Diesel Generator Reliability Program
Procedures
Predictive Maintenance Program
Procedures
Motor Operated Valve (MOV) Test Data Review
Procedures
Process Applicability Determination
Procedures
CFR 50.59 Evaluations
Procedures
Corrective Action Program
049
Procedures
Primary Containment Control
Procedures
Electrical Bus Outages
313
Procedures
Emergency and Transient Response Support Procedure
Procedures
PEP-0026
Diesel Generator Operating Logs
Procedures
RBNP-001
Development, Control and Maintenance of RBS Procedures
Procedures
SOP-0047
480 VAC System
Procedures
SOP-0053
Standby Diesel Generator and Auxiliaries
347
Procedures
SOP-0059
Containment HVAC System (Sys #403)
Procedures
SOP-0061
Diesel Generator Building Ventilation
016
Procedures
STP 309-601
Div I ECCS Test
Procedures
STP 309-6301
STP 309-6301
Procedures
STP-107-3806
Feedwater Penetration KJB-Z3A Valve Leak Rate Test
Procedures
STP-203-6305
HPCS Quarterly Pump and Valve Operability Test
Procedures
STP-209-6800
RCIC Cold Shutdown Valve Operability Test
304
Procedures
STP-256-3828
Service Water Return Train A Penetration KJB-Z53A Valve
Leak Rate Test
Procedures
STP-256-6301
Div I Standby Service Water Quarterly Valve Operability
Test
Procedures
STP-256-6803
Div I Service Water Cold Shutdown Valve Operability Test
305
Procedures
STP-309-0201
Division I Diesel Generator Operability Test
Procedures
STP-403-0301
Containment Unit Cooler HVR-UC1A Flow Rate Verification
Procedures
STP-501-4202
FWS/Main Turbine Trip System - Reactor Vessel Water
Level - High Level 8, Channel Calibration and LSFT (C33-
N004B, C33-K624B, C33-R606B, C33-K650-3)
Work Orders
Work Order (WO-
)
23000570, 00512093, 52898848, 53023404, 52977233,
2974530, 52921774, 52703603, 00309004, 00391911,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2957179, 52920239, 52952387, 53007316, 51023678,
53036390, 52864225, 52907504, 52864224, 53016063,
53023928, 52446190, 52337985, 52580647, 52952270,
2903062, 52690220, 00323927, 00323938, 00512093,
51695027, 52847647, 52857807, 52907862, 52791882,
00593803, 00593992, 52795062, 52717386, 00449735,
2888418, 52684098, 00518175, 52634167, 00449812,
2684215, 52684213, 52684214, 00449786, 00421255,
00449682, 00449729, 00570792, 52684178, 52724430,
2839770, 52618184, 52684178, 52890204, 52980190,
53016051