IR 05000458/2024004
| ML25035A184 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 02/10/2025 |
| From: | Douglas Dodson NRC/RGN-IV/DORS/PBC |
| To: | Hansett P Entergy Operations |
| Makris J | |
| References | |
| IR 2024004 | |
| Download: ML25035A184 (1) | |
Text
February 10, 2025
SUBJECT:
RIVER BEND STATION - INTEGRATED INSPECTION REPORT 05000458/2024004
Dear Phil Hansett:
On December 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at River Bend Station. On January 16, 2025, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at River Bend Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at River Bend Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Douglas E. Dodson II, Chief Reactor Projects Branch C 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-2024-004-0012
Licensee:
Entergy Operations, Inc.
Facility:
River Bend Station
Location:
St. Francisville, LA
Inspection Dates:
October 1, 2024, to December 31, 2024
Inspectors:
E. Powell, Resident Inspector
C. Wynar, Senior Resident Inspector
Approved By:
Douglas E. Dodson II, Chief
Reactor Projects Branch C
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at River Bend Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Inadequate Maintenance of the Suppression Pool Cooling FLEX Pump Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2024004-01 Open/Closed
[H.1] -
Resources 71111.24 The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.155(c)(1),
Mitigation of Beyond-Design-Basis Events, for the licensees failure to maintain equipment of sufficient capacity and capability to implement strategies to maintain and restore core cooling, containment, and spent fuel cooling capabilities following a beyond-design-basis external event. Specifically, the licensee failed to torque the flexible coping strategies (FLEX)suppression pool cooling pump, FLX-P1, motor to impellor shaft coupling to the required 30 ft-lb and instead tightened the fasteners wrench tight. This rendered the pump nonfunctional.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000458/2024004-02 Maintenance Rule Optimization Deficiencies 71152A Open LER 05000458/2023-003-00 Drywell Atmosphere Radiation Monitor Particulate and Gaseous Channels Inoperable Due to Out of Tolerance Conversion Factors 71153 Closed LER 05000458/2023-004-00 Drywell Post Accident Radiation Monitor Inoperable Due to Unrecognized Surveillance Failure 71153 Closed LER 05000458/2022-004-01 High Pressure Core Spray Inoperable Due to Transformer Failure 71153 Closed LER 05000458/2023-005-01 Manual Reactor Scram Due to Lowering Feedwater Temperature Following an Automatic Isolation of Feedwater Heater String 71153 Closed
PLANT STATUS
River Bend Station began the inspection period at rated thermal power. On November 21, 2024, the unit was down powered to 95 percent for a planned control rod pattern adjustment. The unit was returned to rated thermal power on November 21, 2024. On December 6, 2024, the unit was down powered to 63 percent for a planned rod pattern adjustment and scram time testing.
The unit was returned to rated thermal power on December 7, 2024. On December 17, 2024, the unit was down powered to 93 percent for a planned rod pattern adjustment. The unit was returned to rated thermal power on December 17, 2024, and remained at or near rated thermal power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of cold weather operations less than 40 degrees Fahrenheit for the following systems:
- battery room, instrument air system, and service air system on December 16, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
(1)low pressure core spray pump room, fire area AB-6/Z-1, on October 2, 2024 (2)diesel generator A room, fire area DG-6/Z-1, on October 7, 2024 (3)standby liquid control area, fire area RC-4/Z-4, on October 8, 2024 (4)cable chase IV, fire area C-10, on November 12, 2024 (5)standby switchgear 1A room, fire area C-15, on November 12, 2024
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during a power reduction on November 21, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated crew proficiency on October 15, 2024.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
(1)planned Yellow risk during performance of STP-209-5211, Div I RSS/RCIC Turbine Speed Channel Calibration, on December 11, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)division 2 emergency diesel generator control power on December 11, 2024 (CR-RBS-2024-05306)
(2)division 3 battery room low temperature on December 21, 2024 (CR-RBS-2024-
===05965)
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
=
The inspectors evaluated the following temporary or permanent modifications:
- (1) EC-87321 and EC-54111655, SVV-C7 main steam safety and relieve valves automatic depressurization system backup compressor, on December 11, 2024
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (4 Samples)
(1)work order (WO) 54189988, circulating water system pump CWS-P1D replacement, on October 2, 2024
- (3) WO 54195452, instrument air compressor check valve repair, on November 5, 2024
- (4) WO 54195547, investigate HVC-ACU3A (chiller equipment room air handling unit)low airflow rate and correct, on December 16, 2024
Surveillance Testing (IP Section 03.01) (2 Samples)
- (1) STP-204-6304, Div II RHR Quarterly Valve Operability Test, Revision 025 on October 15, 2024
- (2) COP-0001, Sampling Via Various Balance of Plant Systems, Revision 24 on December 30, 2024
Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)
Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)
- (1) FLEX communications emergency diesel generators FLX-EG11, FLX-EG12, and FLX-EG13 load runs on October 8,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===
- (1) October 1, 2023, through September 30, 2024
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
- (1) October 1, 2023, through September 30, 2024
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
(1)evaluation of maintenance rule program on December 30, 2024
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program to identify potential trends in foreign material exclusion that might be indicative of a more significant safety issue.
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reporting determinations to ensure they complied with reporting requirements:
- (1) LER 05000458/2022-004-01, High Pressure Core Spray Inoperable Due to Transformer Failure (ADAMS Accession No. ML23319A436)
The circumstances surrounding this LER are documented in Inspection Report 05000458/2023090, dated June 26, 2023 (ML23165A102). This LER is closed.
- (2) LER 05000458/2023-003-00, Drywell Atmosphere Radiation Monitor Particulate and Gaseous Channels Inoperable Due to Out of Tolerance Conversion Factors (ML23257A257)
The circumstances surrounding this LER are documented in the IP 95001 Supplemental Inspection Report 05000458/2024040 (ML24074A476), Objectives 2 and 3. This LER is closed.
- (3) LER 05000458/2023-004-00, Drywall Post Accident Radiation Monitor Inoperable due to Unrecognized Surveillance Failure (ML23362A034)
The circumstances surrounding this LER are documented in the 95001 Supplemental Inspection Report 05000458/2024040 (ML24074A476), Objectives 2 and 3. This LER is closed.
- (4) LER 05000458/2023-005-01, Manual Reactor Scram Due to Lowering Feedwater Temperature Following an Automatic Isolation of Feedwater Heater String (ML24156A040)
The circumstances surrounding this LER are documented in Inspection Report 05000458/2024001, dated May 14, 2024 (ML24128A043). This LER is closed.
INSPECTION RESULTS
Inadequate Maintenance of the Suppression Pool Cooling FLEX Pump Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000458/2024004-01 Open/Closed
[H.1] -
Resources 71111.24 The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.155(c)(1),
Mitigation of Beyond-Design-Basis Events, for the licensees failure to maintain equipment of sufficient capacity and capability to implement strategies to maintain and restore core cooling, containment, and spent fuel cooling capabilities following a beyond-design-basis external event. Specifically, the licensee failed to torque the flexible coping strategies (FLEX)suppression pool cooling pump, FLX-P1, motor to impellor shaft coupling to the required 30 ft-lb and instead tightened the fasteners wrench tight. This rendered the pump nonfunctional.
Description:
After the events of Fukushima, the NRC issued a confirmatory order and eventually 10 CFR 50.155, requiring all sites to have a beyond-design-basis strategy for extended loss of alternating current (AC) power (ELAP), commonly referred to as FLEX. The suppression pool cooling pump, FLX-P1, is a required pump to execute this strategy to maintain suppression pool cooling to maintain containment integrity.
In October 2024, the inspectors reviewed work order (WO) 52995845 associated with preventive maintenance (PM) on the FLX-P1 pump associated with maintenance performed in July 2024. After reviewing the WO, the inspectors questioned how the system was restored after an uncoupled run. As part of the licensees PM, the licensee unbolts the coupling that connects the motor shaft to the pump's impellor shaft. Upon completion of the work, the WO states to recouple the pump and motor snug tight. However, no specified torque value or reference was included. The inspectors reviewed the pump's vendor manual, licensee document 3221.481-601-002A, "Maintenance Instructions," and the original installation document, WO 00360496, and discovered the proper fastener torque for the coupling was 30 ft-lb. Additionally, the inspectors reviewed WO 53011029 from the previous PM in July 2022 and found the pump had not been properly torqued in July 2022. When the issue was brought to the licensees attention, the licensee went out to ensure the coupling was properly torqued and discovered some of the bolts were not at 30 ft-lb. The FLX-P1 pump was declared non-functional on October 17, 2024. Although the FLX-P1 pump was non-functional, the FLX-P2 pump, which performs the same functions, was functional during the same period.
Corrective Actions: The licensee entered this issue into their corrective action program and corrected it by torquing the coupling fasteners to the required value and restored functionality on October 20, 2024.
Corrective Action References: CR-RBS-2024-05336
Performance Assessment:
Performance Deficiency: The failure to maintain equipment reliability for mitigation strategies for beyond-design-basis external events in accordance with 10 CFR 50.155 was a performance deficiency. Specifically, the licensee failed to torque the FLX-P1 pumps motor and impellor shafts together to the required torque, which adversely impacted the FLX-P1 pumps reliability and capability to perform its required functions.
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, the licensee failed to ensure required torque specifications were applied to the FLX-P1 pump, thereby preventing the pump from having sufficient capacity and capability to perform its required function.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, Section E, Flexible Coping Strategies (FLEX), and the inspectors determined the inspection finding was not associated with equipment, training, procedures, or other programmatic aspects credited for the sole purpose of satisfying the requirements of 10 CFR 50.155 for spent fuel pool instrumentation or EA-13-109 for containment venting; and the finding did not involve equipment, training, procedures, or other programmatic aspects credited in any Phase 1 or 2 FLEX strategy such that any FLEX function could not be completed in accordance with existing plant procedures within the time allotted for an exposure period of greater than 21 days.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Specifically, leaders did not ensure that procedures and other resource materials to ensure proper torque values from the vendor manual were available to support successful work performance, including emergency equipment. As a result, the licensee failed to torque the FLX-P1 pumps motor and impellor shafts together to the required torque, impacting FLX-P1 pump reliability.
Enforcement:
Violation: Title 10 CFR 50.155(c)(1) requires, in part, that equipment relied on for the mitigation strategies and guidelines required by paragraph (b)(1) of this section must have sufficient capability to perform the functions required by paragraph (b)(1) of this section.
Title 10 CFR 50.155(b)(1) requires, in part, that strategies and guidelines to mitigate beyond-design-basis external events from natural phenomena must be capable of being implemented site-wide and include, in part, maintaining or restoring core cooling, containment, and spent fuel pool cooling capabilities.
Contrary to the above, from July 2022 to October 20, 2024, the licensee failed to ensure that equipment relied on for the mitigation strategies and guidelines to mitigate beyond-design-basis external events from natural phenomena had sufficient capability to perform the function of maintaining or restoring core cooling, containment, and spent fuel pool cooling capabilities. Specifically, the licensee failed to ensure the suppression pool cooling pump, FLX-P1, equipment relied on for the mitigation strategies, had sufficient capability to perform its function of maintaining containment integrity.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Unresolved Item (Open)
Maintenance Rule Optimization Deficiencies URI 05000458/2024004-02 71152A
Description:
The inspectors identified a potential performance deficiency and violation associated with the licensee's compliance with 10 CFR 50.65(a)(2) and (a)(3). Specifically, the licensee is not tracking availability for all maintenance rule scoped systems, and the licensee has ineffective maintenance preventable functional failure (MPFF) criteria, which the licensee uses as the basis for determining reliability. To be compliant with 10 CFR 50.65(a)(3), the licensee needs to be able to evaluate if maintenance is effective through structures, systems, and component performance to determine if the objective of balancing reliability with availability is met and adjust as needed. If the licensee is neither tracking availability directly nor indirectly for all scoped systems, it is unclear how the licensee can ensure the objective of preventing failures of structures, systems, and components through maintenance is appropriately balanced against the objective of minimizing unavailability of structures, systems, and components due to monitoring or preventive maintenance. Likewise, if the licensee has unrealistic or unachievable MPFF thresholds, and licensee procedures are set up such that MPFFs are a direct indicator of reliability, it is unclear to the inspectors how the licensee can demonstrate the reliability objective is met.
Planned Closure Actions: The inspectors need more information to determine whether a violation exists and to determine whether the issue is more-than-minor. Specifically, the inspectors will review the licensees forthcoming 10 CFR 50.65(a)(3) violation in an attempt to assess the potential performance deficiency and violation to resolve this unresolved item (URI).
Licensee Actions: The licensee is currently completing a 10 CFR 50.65(a)(3) evaluation, which is currently over a year late from the required due date (NCV 05000458/2024003-01 documents a violation associated with the licensees late 10 CFR 50.65(a)(3) evaluation).
Once the inspectors have this information, the inspectors should be able to resolve the URI.
The licensee is tracking the inspectors concern in the corrective action program under CR-RBS-2024-04013, CR-RBS-2024-04624, and CR-RBS-2024-04957.
Corrective Action References: CR-RBS-2024-04013, CR-RBS-2024-04624, and CR-RBS-2024-04957 Observation: Foreign Material Exclusion Gaps 71152S Dating back to the end of 2023, the licensee generated Condition Report (CR) CR-RBS-2023-06319 to document and develop corrective actions for FME issues that occurred that year. The inspectors used this CR to inform the semiannual trend review sample to determine if there was a programmatic trend developing with the site's FME practices. During the 2024 inspection cycle, the inspectors reviewed 23 different CRs relating to site FME challenges, and the inspectors noted a weakness in the area of FME. Specifically, the inspectors identified multiple gaps in the licensee's foreign material exclusion (FME) program implementation associated with poor personnel FME practices when individuals enter zone 1 areas such as containment and with personnel not following site procedures to make themselves FME ready. The CRs documented different concerns like hard hats not having a lanyard to clothing and poor log keeping practices when recording tools that go in and out of zone 1 areas. CRs were generated by site personnel, supervision, and the Nuclear Independent Oversite group, which ultimately elevated the concern to senior management.
Other minor but important conditions the inspectors reviewed related to leaving or dropping tools in FME areas. In one instance, a caliper was found lodged in a safety-related spent fuel pool cooling pump (CR-RBS-2024-0835). The licensee does not know how the caliper ended up in the system, and known log keeping deficiencies make it more challenging for the licensee to assess these types of concerns. Although fuel was not impacted and the inspectors determined the issue was minor, this issue underscored the importance of appropriate FME controls. Additionally, during a division 2 emergency diesel generator outage, a wrench was dropped in a gear boxa level 1 zone (CR-RBS-2024-04572). This tool did not have a lanyard, which was required by EN-MA-118, Foreign Material Exclusion, Revision 18. The inspectors assessed that none of these issues adversely impacted a cornerstone objective, could have led to a more significant safety concern, or could be viewed as a precursor to a significant event, and the inspectors previously communicated these minor issues to the licensee, and the licensee documented these concerns in CR-RBS-2024-03568 and CR-RBS-2024-06241, respectively. The inspectors did not identify any other more-than-minor concerns associated with FME practices but will continue to follow up on the site's FME actions.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 16, 2025, the inspectors presented the integrated inspection results to Phil Hansett, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Severe Weather Operation
Calculations
G13.18.12.2-022
River Bend Station Combustible Loading
Procedures
ADM-0073
Temporary Services and Equipment
309
Procedures
Control of Combustibles
Procedures
Operability Determination Process
Miscellaneous
21.481-601-
2A
Maintenance Instructions Manual
Procedures
BWR Drywell Leakage
005
Miscellaneous
B881-0101
Baldor Motor Product Information Packet ECP4407T-44
Miscellaneous
G200-0113
Gould Pump 3196 Installation, Operation, and Maintenance
Manual
Procedures
Extended Loss of AC Power (ELAP)
Procedures
Maintenance Rule Scope and Basis
Procedures
Maintenance Rule Monitoring
Procedures
Maintenance Rule (a)(1) Process
Procedures
RBS-FSG-005
Initial Assessment and Flex Equipment Staging
Procedures
18