IR 05000458/2018001
| ML18128A246 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 05/08/2018 |
| From: | Jason Kozal NRC/RGN-IV/DRP/RPB-C |
| To: | Maguire W Entergy Operations |
| Kozal J | |
| References | |
| IR 2018001 | |
| Download: ML18128A246 (33) | |
Text
May 8, 2018
SUBJECT:
RIVER BEND STATION - NRC INTEGRATED INSPECTION REPORT 05000458/2018001
Dear Mr. Maguire:
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your River Bend Station, Unit 1. On April 25, 2018, 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.
NRC inspectors documented two findings of very low safety significance (Green) in this report.
One of these findings involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the violation or significance of the NCV, 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 the 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 the 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Jason W. Kozal, Chief Project Branch C Division of Reactor Projects
Docket No. 50-458 License No. NPF-47
Enclosure:
Inspection Report 05000458/2018001 w/ Attachments:
1. Documents Reviewed 2. O
Inspection Report
Docket Number:
05000458
License Number:
Report Number:
Enterprise Identifier: I-2018-001-0009
Licensee:
Entergy Operations, Inc.
Facility:
River Bend Station
Location:
Saint Francisville, Louisiana
Inspection Dates:
January 1, 2018 to March 31, 2018.
Inspectors:
J. Sowa, Senior Resident Inspector
B. Parks, Resident Inspector
M. OBanion, Acting Resident Inspector
J. Drake, Senior Reactor Inspector
C. Young, Senior Project Engineer
L. Carson II, Senior Health Physicist
Approved By:
J. Kozal, Chief, Branch C
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at River Bend Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. Findings and violations being considered in the NRCs assessment are summarized in the table below.
List of Findings and Violations
Failure to Implement Procedure for Storage of Material in the Pools Cornerstone Significance Cross-cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000458/2018001-01 Closed
[H.4] -
Human Performance,
Teamwork 71124.02 -
Occupational As Low As Reasonably Achievable (ALARA)
Planning and Controls The inspectors identified a non-cited violation of Technical Specification 5.4.1.a for the licensees failure to implement written procedures for activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978. Specifically, the licensee failed to implement radioactive material control Procedure ADM-0071, Fuel Pools Material Control,
Revision 8, for the storage and movement of spent Tri-Nuke filters.
Installation of an Incorrectly Specified Relay Causes Plant Transient and Reactor Scram Cornerstone Significance Cross-cutting Aspect Report Section Initiating Events Green FIN 05000458/2018001-02 Closed
[H.5] -
Human Performance,
Work Management 71152 -
Problem Identification and Resolution The inspectors reviewed two examples of a self-revealed finding for the licensees installation of an incorrectly specified relay in 1) the control circuitry for the feedwater level control system and 2) the turbine generator voltage regulator circuitry. In each instance, the incorrectly specified relay failed in service, causing a plant transient and automatic reactor scram.
Additional Tracking Items
Type Issue number Title Report Section Status LER 05000458/2017-007-00 Automatic Reactor Scram Due to Failure of Main Generator Voltage Regulator Mode Transfer Relay 71153 Closed LER 05000458/2017-008-00 Automatic Reactor Scram Due to Failure of Main Feedwater Regulator Transfer Relay 71153 Closed
PLANT STATUS
River Bend Station began the inspection period at rated thermal power. On January 8, 2018, the unit was shut down for a planned maintenance outage. A reactor startup was performed on January 30, 2018. The unit was shut down to conduct a forced outage on February 1, 2018, due to an unexpected trip of the B reactor recirculation pump. A reactor startup was performed on February 9, 2018. The unit was shut down to conduct a forced outage on March 1, 2018, due to a pipe leak associated with the main condenser. A reactor startup was performed on March 6, 2018. The unit was returned to rated thermal power on March 20, 2018. The unit 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 plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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
71111.04Equipment Alignment Partial Walkdown
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Division I residual heat removal system on January 25, 2018
- (2) Division II residual heat removal system on January 25, 2018
- (3) Control building heating, ventilation, and air conditioning (HVAC) system on March 15, 2018
Complete Walkdown (1 Sample)
The inspectors evaluated system configurations during a complete walkdown of the standby service water system on March 8, 2018.
===71111.05AQFire Protection Annual/Quarterly
Quarterly Inspection===
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Residual heat removal pump A room, fire area AB-5 on January 25, 2018
- (2) Residual heat removal pump B room, fire area AB-3 on January 25, 2018
- (3) Standby service water pump A room, fire area PH-1/Z-1on March 12, 2018
- (4) Standby service water pump B room, fire area PH-2/Z-1 on March 12, 2018
71111.06Flood Protection Measures Internal Flooding
The inspectors evaluated internal flooding mitigation protections in the standby service water pump rooms, SW-01 on January 12, 2018.
Cables (1 Sample)
The inspectors evaluated cable submergence protection in:
- (1) Electrical manhole 1EMH607 on January 16, 2018
- (2) Electrical manhole 1EMH613 on January 16, 2018
71111.11Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification
The inspectors observed and evaluated licensed operator requalification training on February 6, 2018.
Operator Performance (1 Sample)
The inspectors observed and evaluated the operators performance during a plant shutdown for a planned maintenance outage on January 7, 2018.
===71111.12Maintenance Effectiveness
Routine Maintenance Effectiveness===
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Functional failure review of standby service water on January 16, 2018
- (2) Functional failure review of the 120 VAC system on February 19, 2018
- (3) Functional failure review of the reactor recirculation system associated with the failure of the B recirculation pump to upshift to fast speed on March 1, 2018
71111.13Maintenance Risk Assessments and Emergent Work Control
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Yellow shutdown risk condition with containment access hatch open on January 8, 2018
- (2) Yellow risk condition due to fuel movement and Division III emergency diesel generator inoperability while in Mode 5 on January 24, 2018
- (3) Yellow risk condition due to high pressure core spray pump inoperability during remote shutdown panel surveillance testing on February 23, 2018
- (4) Yellow risk condition due to residual heat removal pump B discharge flow inoperability during maintenance and testing on March 15, 2018
71111.15Operability Determinations and Functionality Assessments
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) E31-N604F main steam line tunnel temperature exceeded allowable values per surveillance test requirements on January 3, 2018
- (2) Jacket water leaks associated with Division I emergency diesel generator on January 5, 2018
- (3) Unexpected system response during Division II standby service water surveillance testing on January 15, 2018
- (4) Residual heat removal shutdown cooling outboard isolation valve E12-MOVF008 over-torqued on February 19, 2018
- (5) Division I inverter DNB-INV01A1 system output voltage exceeded max allowable voltage on March 20, 2018
71111.18Plant Modifications
The inspectors evaluated the following permanent modification:
- (1) Division I standby diesel generator exhaust manifold piping to eliminate a vulnerability to flaw formation and leakage after Division I emergency diesel generator shroud replacement on January 19, 2018
71111.19Post Maintenance Testing
The inspectors evaluated the following post maintenance tests:
- (1) STP-209-6310, Revision 39, RCIC Pump and Valve Quarterly Operability and Flow Test, following maintenance on the reactor core isolation cooling governor valve on January 5, 2018
- (2) STP-504-4504, Revision 18, RPS/Control Rod Block - IRM D Channel Functional Test and LSFT, following replacement of intermediate range monitor D control relay H13-P672-Z2K18 on January 13, 2018
- (3) STP-309-0206, Revision 29, Division I Diesel Generator 184 Day Operability Test, following maintenance on Division I emergency diesel generator on January 22, 2018
- (4) STP-309-0203, Revision 329, Division III Diesel Generator Operability Test, following replacement of the Division III emergency diesel generator voltage regulator on January 24, 2018
- (5) STP-504-4503, Revision 20, RPS/Control Rod Block - IRM C Channel Functional Test and LSFT, following maintenance on intermediate range monitor C on January 30, 2018
- (6) SOP-0030, Revision 33, High Pressure Core Spray System (Sys 203), following maintenance on high pressure core spray motor supply breaker on February 22, 2018
- (7) STP-256-6603, Revision 21, Division I Standby Service Water Quarterly Valve Operability Test, following maintenance and repairs to standby service water valve SWP-MOV96A on March 5, 2018
71111.20Refueling and Other Outage Activities
- (1) The inspectors evaluated a planned maintenance outage implemented to remove damaged fuel assemblies. Inspection activities occurred from January 8, 2018, to January 31, 2018.
- (2) The inspectors evaluated forced outage activities from February 1, 2018, to February 9, 2018. The forced outage occurred due to a failure of the B reactor recirculation pump to shift to fast speed. Station personnel conducted a forced outage and replaced the 13.8 kV transformer associated with the B reactor recirculation pump.
- (3) The inspectors evaluated forced outage activities from March 1, 2018, to March 7, 2018. The forced outage occurred due to a leak from a crack on piping associated with the main condenser. Station personnel conducted a forced outage and repaired the leak.
===71111.22Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine===
- (1) STP-203-1302, Revision 25, E22-S001BAT Quarterly Surveillance, on January 18, 2018
- (2) STP-057-3801, Revision 012, Containment Equipment Hatch Leak Rate Test, on January 27, 2018
- (3) OSP-0604, Revision 2, Remote Shutdown System Control Circuit Operability Test, on February 26, 2018
In-service (2 Samples)
- (1) STP-204-1300, Revision 18, LPCI Pump A Start Time Delay Channel Calibration and Channel Functional Test, on January 2, 2018
- (2) STP-256-6301, Revision 23, Division I Standby Service Water Quarterly Valve Operability Test, on January 6, 2018
Reactor Coolant System Leak Detection (1 Sample)
- (1) STP-000-0001, Revision 082, Daily Operating Logs, on January 4, 2018
Containment Isolation Valve (1 Sample)
- (1) STP-057-7705, Revision 012, Primary Containment Airlocks Seal Leakage Rate Test, on January 28, 2018
===71114.06Drill Evaluation
Drill/Training Evolution===
The inspectors evaluated a simulator-based emergency preparedness drill on March 13,
RADIATION SAFETY
71124.02Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls Radiological Work Planning
The inspectors evaluated the licensees radiological work planning by reviewing the following activities:
- (1) RWP 2017-1220, Pre/Post Outage Prep Including Support
- (3) RWP 2017-1426, Motor Operated Valve and In-Vessel Testing
- (4) RWP 2017-1436, Installation/Removal of Temporary Installation Main Steam Tunnel
- (5) RWP 2017-1753, RWCU Hx Room Flow Accelerated Corrosion (FAC) Piping Replacement
- (6) RWP 2017-1800, RF-19 Refuel Floor Outage Activities
- (7) RWP 2018-1327, Separator Repair Following SHZAM Bolt Disengagement
Verification of Dose Estimates and Exposure Tracking Systems (1 Sample)
The inspectors evaluated dose estimates and exposure tracking.
Implementation of ALARA and Radiological Work Controls (1 Sample)
The inspectors reviewed ALARA practices and radiological work controls by reviewing the following activities:
- (1) RWP 2017-1220, Pre/Post Outage Prep Including Support
- (3) RWP 2017-1426, Motor Operated Valve and In-Vessel Testing
- (4) RWP 2017-1436, Installation/Removal of Temporary Installation Main Steam Tunnel
- (6) RWP 2017-1800, RF-19 Refuel Floor Outage Activities
- (7) RWP 2018-1327, Separator Repair Following SHZAM Bolt Disengagement
Radiation Worker Performance (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance.
71124.04 - Occupational Dose Assessment
Source Term Characterization (1 Sample)
The inspectors evaluated the licensees source term characterization.
External Dosimetry (1 Sample)
The inspectors evaluated the licensees external dosimetry program.
Internal Dosimetry (1 Sample)
The inspectors evaluated the licensees internal dosimetry program.
Special Dosimetric Situations (1 Sample)
The inspectors evaluated the licensees performance for special dosimetric situations.
OTHER ACTIVITIES - BASELINE
71151Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
- (1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (01/01/2017 - 12/31/2017)
- (2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (01/01/2017 - 12/31/2017)
- (3) IE04: Unplanned Scrams with Complications (USwC) Sample (01/01/2017 - 12/31/2017)
71152Problem Identification and Resolution Annual Follow-up of Selected Issues
The inspectors reviewed the licensees implementation of its corrective action program related to the following issue:
- (1) Relay failures in the feedwater level control system and the turbine generator voltage regulator control system resulted in reactor scrams
71153Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports
The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:
- (1) Licensee Event Report 05000458/2017-007-00, Automatic Reactor Scram Due to Failure of Main Generator Voltage Regulator Mode Transfer Relay on August 21, 2017
- (2) Licensee Event Report 05000458/2017-008-00, Automatic Reactor Scram Due to Failure of Main Feedwater Regulator Transfer Relay on October 12,
INSPECTION RESULTS
Failure to Implement Procedure for Storage of Material in the Pools Cornerstone Significance Cross-cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000458/2018001-01 Closed
[H.4] - Human Performance, Teamwork
71124.02 - Occupational
As Low As Reasonably Achievable (ALARA)
Planning and Controls The inspector identified a non-cited violation of Technical Specification 5.4.1.a, for the licensees failure to implement written procedures for activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978. Specifically, the licensee failed to implement radioactive material control Procedure ADM-0071, Fuel Pools Material Control, Revision 8, for the storage and movement of spent Tri-Nuke filters.
Description:
The inspector reviewed condition reports (CRs) that documented incidents associated with the movement and storage of highly radioactive materials in the various pools at River Bend Station (RBS) in 2017. Four radiological occurrences involved unplanned and unanticipated movements of spent Tri-Nuke filters around the separator and upper inclined fuel transfer storage (IFTS) pools.
- January 5, 2017, CR-RBS-2017-0100: Radiation Protection (RP) was notified that a spent Tri-Nuke filter was found floating on the surface of the separator pool.
Surveys of the filter and surrounding area were performed by RP technicians.
Dose rates on the filter measured 2.2 Roentgen/hour (R/hr) on contact and 0.85 R/hr at 30 centimeters (cm).
- April 3, 2017, CR-RBS-2017-03011: A used Tri-Nuke filter measuring 1.3 R/hr and 0.350 R/hr at 30 cm was discovered floating in the reactor building (RB)-186 separator pool.
- April 24, 2017, CR-RBS-2017-03424: While performing video surveillance of the refueling pool on RB-186, a Tri-Nuke filter was discovered floating on the surface of the separator pool. The filter had a dose rate of 11 R/hr on contact and 6 R/hr at 30 cm.
- During the week of April 27, 2017, the licensee transferred the 30 Tri-Nuke filters from the separator pool to the IFTS. However, one of the Tri-Nuke filters (0.300 R/hr) had been damaged when falling into the bottom of the IFTS pool. It was eventually recovered and stored.
The inspector examined the circumstances that caused the Tri-Nuke filters to become buoyant and float around the separator pool resulting in unintended radiological hazards. Two CRs from 2015 (CR-RBS-2015-07893 and CR-RBS-2015-08050) identified concerns with air intrusion from a leaky spent fuel cooling system valve. Also, two CRs from 2017 (CR-RBS-2017-01881 and CR-RBS-2017-03424) identified that the leaky valve caused spent Tri-Nuke filters to float. The licensee eventually determined the solution to the problem was to transfer the spent Tri-Nuke filters to the upper IFTS pool. However, the inspector determined that the licensee was not supposed to leave the spent Tri-Nukes in the separator and upper IFTS pools unless designed storage racks were in place or an engineering change request (ECR) evaluation allowed the practice.
The movement and storage of radioactive material in and around the pools at RBS are implemented through the following procedures:
- EN-RP-121, Revision 13, Radioactive Material Control
- EN-RP-123, Revision 1, Radiological Controls of Highly Radioactive Objects
- ADM-0071, Revision 8, Fuel Pools Material Control
The inspector determined that the purpose of Entergy Corporate Procedures EN-RP-121 and EN-RP-123 was to prevent the unauthorized movement and removal of radioactive materials around the site and from pools. These procedures required that licensee personnel receive proper authorization from reactor engineering and radiation protection management for movement and storage of radioactive materials in pools and the around pools. Based on the documents and procedures reviewed by the inspector, the licensee did not specify storage requirements or equipment for these filters to prevent them from floating to the top of the pools and becoming radiological hazards.
The inspector reviewed RBS site-specific Procedure ADM-0071, Revision 8, which described the requirements established for the control of miscellaneous material stored in fuel pools. At RBS, radioactive materials are stored in the following seven pools: spent fuel pool, cask pool, lower IFTS, upper IFTS, upper containment pool, dryer storage pool, and separator pool.
ECR RBS-ER-97-504, Fuel Pool Inventory Identification, Justification, and Evaluation, dated September 30, 1997, stated that the purpose of ADM-0071 was to provide a means to adequately control, regulate, and inventory non-special nuclear material stored in the spent fuel pool and upper containment pools. Items may not be stored in the spent fuel storage upper containment pools, which includes the separator pool, without design engineering approval. Additionally, items that are not stainless steel or in a stainless steel container are not to be stored without being verified radiation resistant and not detrimental to the fuel pool water quality.
Section 7.3 of Procedure ADM-0071 provided instructions for storing or moving material within the same pool or to another pool location. Section 7.3.7 required that the pool material inventory POOL MATERIAL CONTROL FORM be completed and updated after approval of the material storage/move by the reactor engineering manager and radiation protection superintendent. The form required specific information about proposed items to be stored, such as the radiation surveys taken, work order used, storage container location, special requirements, radiation exposure duration, and applicable ECR evaluations. At the time of this inspection, the licensee did not have any pool material control forms completed for the 30 Tri-Nuke filters that were placed into the separator pool and subsequently transferred to the IFTS in 2017. In particular, there was no pool material control forms signed by the reactor engineering manager and radiation protection superintendent approving the proper storage and movement of these Tri-Nuke filters for either location.
Procedure ADM-0071 allowed miscellaneous items such as Tri-Nuke filters to be stored in the separator and IFTS pools if an ECR evaluation and engineering approval on the storage method were done. The inspector queried whether any ECRs had been performed for storage of the Tri-Nuke filters. Only two were available for the inspectors review. The two ECRs (ECR RBS-ER-97-504 and ECR 33163) revealed that the licensee had not made specific provisions or performed evaluations for the storage of Tri-Nuke filters in the separator or upper IFTS pools.
The inspector determined that licensees procedures did not adequately address securing highly radioactive material in pools such as Tri-Nuke filters to prevent radioactive material from floating to the pool surface and thereby becoming radiation hazards to personnel, as had occurred three times in early 2017. Further, the failure to follow the requirements of Procedure ADM-0071 resulted in bypassing the performance of an evaluation to ensure proper movement and storage of the filters.
Corrective Actions: Immediate safety concerns with filters becoming buoyant due to the air intrusion in the separator pool were addressed when the licensee transferred the 30 Tri-Nuke filters to the IFTS pool in late April 2017. Procedure compliance issues are being addressed through an action item in CR-RBS-2018-00523.
Corrective Action References: CR-RBS-2018-00523
Performance Assessment:
Performance Deficiency: The licensees failure to implement written procedures for activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978, as required by Technical Specification 5.4.1.a, was a performance deficiency. Specifically, the licensee failed to implement radioactive material control Procedure ADM-0071, Fuel Pools Material Control, Revision 8, for the storage and movement of spent Tri-Nuke filters.
Screening: The performance deficiency was more than minor because it adversely affected the programs and process (exposure control) attribute of the Occupational Radiation Safety Cornerstone and its objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material. Specifically, allowing highly radioactive material (Tri-Nuke filters) to be moved and stored in an unsafe, unevaluated, unapproved manner resulted in unanticipated dose rates and unplanned worker exposures to radiation.
Significance: The inspectors assessed the significance of the finding using NRC Inspection Manual Chapter 0609, Appendix, C, Occupational Radiation Safety Significance Determination Process, and determined that the finding was of very low safety significance (Green) because it did not:
- (1) involve ALARA planning or work controls,
- (2) did not involve an overexposure,
- (3) did not have a substantial potential to be an overexposure, and
- (4) the ability to assess dose was not compromised.
Cross-cutting Aspect: The finding has a cross-cutting aspect in the area of human performance, associated with teamwork, because individuals and work groups failed to communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety was maintained. Specifically, the communication and coordination of activities between construction projects, health physics, and nuclear engineering failed to prevent radiological issues associated with the storage and movement of Tri-Nuke filters.
Enforcement:
Violation: Technical Specification 5.4.1.a requires, in part, that procedures be written, implemented, and established for those areas recommended in Regulatory Guide 1.33, Appendix A, Revision 2, 1978. Section 7(b) of Regulatory Guide 1.33, Appendix A, requires procedures for control of radioactive materials to minimize potential releases to the environment and control personnel exposure associated with solid radioactive waste.
Licensee Procedure ADM-0071, Fuel Pools Material Control, Revision 8, Section 7.1, requires that if material must be stored in a pool or previously stored material must be moved from one pool to a different pool or to a different area in the same pool, Section 7.3 must be completed. Section 7.3.7 requires that the pool material inventory POOL MATERIAL CONTROL FORM be updated after approval of the material storage/move by the reactor engineering manager and radiation protection superintendent.
Contrary to the above, beginning in 2017 and to present, the licensee stored material in a pool and moved previously stored material from one pool to a separate pool without completing Section 7.3 of Procedure ADM-0071. Specifically, the licensee stored 30 Tri-Nuke filters in the separator pool without completing the pool material Inventory form and, in April 2017, moved the filters to the incline fuel transfer storage pool without completing/
updating a pool material Inventory POOL MATERIAL CONTROL FORM and obtaining the required approvals.
As of January 26, 2018, the licensee had not fully implemented Section 7.3 of Procedure ADM-0071 by updating the form and obtaining written approval from the radiation protection superintendent and reactor engineering manager for the movement and safe storage of the 30 Tri-Nuke filters in the incline fuel transfer storage pool.
Disposition: This violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy.
Installation of an Incorrectly Specified Relay Causes Plant Transient and Reactor Scram Cornerstone Significance Cross-cutting Aspect Report Section Initiating Events Green FIN 05000458/2018001-02 Closed
[H.5] - Human Performance, Work Management
71152 - Problem
Identification and Resolution The inspectors reviewed two examples of a self-revealed finding for the licensees installation of an incorrectly specified relay in 1) the control circuitry for the feedwater level control system and 2) the turbine generator voltage regulator circuitry. In each instance, the incorrectly specified relay failed in service, causing a plant transient and automatic reactor scram.
Description:
Example 1: On August 18, 2017, with the plant operating at 100 percent power, an automatic scram occurred. At the time of the scram, operators were performing a scheduled surveillance test that called for a planned shift of the controlling channel of the feedwater level control system from channel B to channel A. Immediately after the shift, feedwater regulating valves went full open and recirculation pumps downshifted to slow speed. The combination of these events caused an automatic scram to occur on high flow-biased thermal power.
The cause of the scram was a failure of the feedwater level select relay, C33A-K12. The failure of this relay caused the interpreted level in the feedwater level control system to go to zero, which in turn caused a full open demand on the feedwater regulating valves and a downshift of recirculation pumps from fast to slow speed on a perceived low level condition in the reactor vessel.
A subsequent investigation determined that the feedwater level select relay failed due to a degradation in the electrical contacts on the relay. The degradation caused a sharp increase in resistance across the contacts, which in turn led to a substantial reduction in the current passing through these contacts to the rest of the feedwater level control circuit. With the current substantially reduced, the circuit incorrectly perceived a low vessel level condition.
The failed relay was a General Electric Agastat GPI type relay. Operating experience at River Bend Station and at other sites in the industry has established that this type of relay is prone to intermittent failure. When used in low current applications such as those associated with the feedwater level control circuit, there is a potential for oxidation to build up on the contacts of the relay, which will create resistance across the relay and impair its ability to pass current. In light of this operating experience, the licensee issued part interchangeability evaluation (PIE) 411 in March 1993. PIE 411 called for a GPIA type relay with gold-plated contacts to be used for C33A-K12 in lieu of the silver-plated GPI type relay that had traditionally been used.
The inspectors determined that PIE-411 was a self-imposed licensee standard. The licensee complied with this standard until February 2017, when the gold-plated relay installed in the system was incorrectly replaced with a silver-plated relay. Given that the silver-plated relay was being used in a low current application, it built up resistance over time and eventually failed, causing the scram.
Example 2: On June 23, 2017, with the plant operating at 100 percent power, an automatic scram occurred. At the time of the scram, operators were performing a scheduled surveillance test that called for a planned shift of the turbine generator voltage regulator control from automatic to manual. Immediately after the shift, the main generator tripped which caused a subsequent reactor scram.
The cause of the scram was a failure of the voltage regulator transfer circuit relay, EXS-PNL1-43A. The failure of this relay caused an open circuit in both the manual and automatic voltage regulators and complete loss of control of the Alterrex Excitation System.
When neither the manual nor the automatic voltage regulator is connected to the Alterrex Excitation System, there is no excitation field applied. The result is a turbine trip on loss of excitation.
A subsequent investigation determined that the main generator voltage regulator mode transfer relay failed due to a degradation in the electrical contacts on the relay. The degradation caused a sharp increase in resistance across the contacts, which in turn led to a substantial reduction in the current passing through these contacts to the rest of the voltage regulator control circuit. With the current substantially reduced, the circuit could not be completed for either the manual or automatic control system of the turbine voltage regulator.
The failed relay was a General Electric DC operated 4-pole double throw miniature 43A relay provided as part of the turbine generator package and is part of the Alterrex exciter transfer panel assembly. Operating experience at River Bend Station and at other sites in the industry has established that this type of relay is prone to intermittent failure. The station generated engineering change 40442 in 2012 to replace the 43A relay with a different model documenting obsolescence of this relay as well as operating experience related to intermittent failures of this type of relay. In light of this operating experience, the licensee cancelled engineering change 40442 for unknown reasons and did not replace the 43A relay with a different style.
Corrective Actions: The licensee installed the correctly specified relay in the feedwater level control system and an upgraded vendor recommended relay in the turbine voltage regulator control system. The licensee also completed an extent of condition review on similar relays.
Corrective Action References: Condition Reports CR-RBS-2017-06118 and CR-RBS-2017-04961
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees installation of an incorrectly specified relay in 1) the control circuitry for the feedwater level control system and 2) the control circuitry for the main generator voltage regulator were two examples of a performance deficiency.
Screening: The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power. The finding was determined to be of very low safety significance (Green) because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigating equipment would not be available.
Cross-cutting Aspect: The finding has a cross-cutting aspect in the area of human performance associated with work management because the licensee failed to implement a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On January 26, 2018, the inspectors presented the radiation safety inspection results to Mr. W. Maguire, Site Vice President, and other members of the licensee staff.
On April 25, 2018, the inspectors presented the quarterly resident inspector inspection results to Mr. W. Maguire, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
71111.04 - Equipment Alignment
Condition Reports (CR-RBS-)
2017-05292
2017-07460
2017-07880
2018-00615
2018-00992
Drawings
Number
Title
Revision
PID-09-10E
Engineering P&I Diagram, System 256, Service
Water - Standby
PID-22-09A
Engineering P&I Diagram, System 402, HVAC -
Control Building
Procedures
Number
Title
Revision
R-STM-0118
Service Water Systems
R-STM-0402
HVAC - Control Building and Diesel Generator
Building
SOP-0031
338
SOP-0042
Standby Service Water System (Sys #256)
SOP-0058
Control Building HVAC System (Sys #402)
71111.05 - Fire Protection
Procedures
Number
Title
Revision
AB-070-502
RHR Pump A Room, Fire Area AB-5
AB-070-505
RHR Pump B Room, Fire Area AB-3
Control of Combustibles
Standby Cooling Pump A Room, Fire Area PH-1/Z-1 3
Standby Cooling Pump B Room, Fire Area PH-2/Z-1 3
STP-250-4533
FPM-PNL6 Fire Detection Channel Functional and
Operational Tests for Zone SD72, SD73, and SD89
(A&B)
71111.06 - Flood Protection Measures
Condition Reports (CR-RBS-)
2018-00200
2018-00367
2018-00369
Procedure
Number
Title
Revision
PN-317
Max Flood Elevations for Moderate Energy Line
Cracks in Cat I Structures
Work Orders
0052802383
0052802384
71111.11 - Licensed Operator Requalification Program and Licensed Operator
Performance
Procedures
Number
Title
Revision
GOP-0002
Power Decrease/Plant Shutdown
078
RSMS-OPS-HIT1
Licensed Operator Requalification
71111.12 - Maintenance Effectiveness
Condition Reports (CR-RBS-)
2017-00629
2017-01579
2017-01668
2017-01703
2017-01739
2017-01748
2017-01749
2017-03871
2017-04048
2017-04514
2017-05273
2017-05939
2017-06767
2017-06977
2017-06998
2017-07017
2017-07200
2017-07410
2017-07454
2017-07820
2017-07880
2017-07950
2018-00825
2018-01363
Procedures
Number
Title
Revision
Maintenance Rule Scope and Basis
Maintenance Rule Monitoring
Maintenance Rule (A)(1) Process
Procedures
Number
Title
Revision
SOP-0042
Standby Service Water System (Sys #256)
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Condition Report (CR-RBS-)
2018-00505
Procedures
Number
Title
Revision
ADM-0096
Risk Management Program Implementation and
On-Line Maintenance Risk Assessment
26
On Line Risk Assessment
Shutdown Operations Protection Plan (SOPP)
036
71111.15 - Operability Determinations and Functionality Assessments
Condition Reports (CR-RBS-)
2016-05866
2017-04048
2017-04097
2017-04302
2017-05033
2017-07111
2017-07162
2017-07199
2017-07219
2017-07532
2017-08048
2018-00194
2018-00402
Miscellaneous
Number
Title
Revision
SWP-SOV523B Reasonable Expectation of
Operability Input for CR-RBS-2016-05866
Procedures
Number
Title
Revision
Log Report - Normal Switchgear, Control, and
Diesel Generator Buildings
108
STP-000-0001
Daily Operating Logs
STP-256-6608
Division II Standby Service Water 2 Year Position
Indication Verification Test
STP-309-0201
Division I Diesel Generator Operability Test
71111.18 - Plant Modifications
Calculation
Number
Title
Revision
G13.18.2.4-108
LPI, Inc. Evaluation of Standby Diesel Generator
Exhaust Manifold Stiffeners
Condition Reports (CR-RBS-)
2015-04817
2016-06841
2016-07753
2017-07111
2017-07532
2017-08048
Drawing
Number
Title
Revision
PID-08-09B
Engineering P&I Diagram System 309 Diesel
Generator
Procedure
Number
Title
Revision
SOP-0053
Standby Diesel Generator and Auxiliaries
(Sys #309)
057
71111.19 - Post-Maintenance Testing
Condition Reports (CR-RBS-)
2017-07237
2017-07728
Miscellaneous
Number
Title
Revision/Date
E22-S004 ACB2
Vendor Overhaul Breaker
Work Orders
00469400
00476322
00479296
Procedures
Number
Title
Revision
CMP-EM-203-1001
Inspection and Maintenance of 4.16 KV
Magne-Blast Circuit Breakers
STP-209-0201
RCIC Discharge Piping Fill and Valve Lineup
Verification
Work Orders
228397
00478865
00492550
00493155
00493741
2650988
2769345
2779858
71111.20 - Refueling and Other Outage Activities
Procedures
Number
Title
Revision
GOP-0001
Plant Startup
099
GOP-0002
Power Decrease/Plant Shutdown
078
71111.22 - Surveillance Testing
Condition Reports (CR-RBS-)
2015-02736
2018-00290
Drawing
Number
Title
Revision
GE-828E534AA
Elementary Diagram Residual Heat Removal
Sheet 8
Procedures
Number
Title
Revision
SOP-0018
Normal Service Water System
SOP-0042
Standby Service Water System
Work Orders
00492725
2785880
2787021
71114.06 - Drill Evaluation
Miscellaneous
Number
Title
Revision
RDRL-EP-1201
Site Drill Scenario
71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and
Controls
Audits and Self-Assessments
Number
Title
Date
LO-RLO-2017-0055
Pre-NRC Self-Assessment Radiation Safety -
December 4, 2017
LO-RLO-2016-0145
Pre-NRC Self-Assessment Radiation Safety -
January 17, 2017
Condition Reports (CR-RBS-)
2015-07893
2015-08050
2017-00100
2017-00707
2017-00868
2017-01250
2017-01355
2017-01731
2017-01881
2017-01927
2017-03011
2017-03237
2017-03266
2017-03424
2017-03598
2017-03788
2017-04856
2017-04941
2017-05499
2017-01372
2017-01422
Miscellaneous
Number
Title
Date
RF-19 Water Movement Plan
January 2017
CFR Part 20.1101(c) Report for 2016
June 2017
ADM-0071
Post Material Inventory Report Post RF-19
May 31, 2017
Relocate Tri-Nuke filters from the Separator Pool
the IFTS
April 11, 2017
Procedures
Number
Title
Revision
ADM-0071
Fuel Pools Material Control
Radiation Worker Expectations
Access Control for Radiologically Controlled Areas
Procedures
Number
Title
Revision
Radiological Control
Radiological Work Permits
Radiological Survey Documentation
Radiation Protection Posting
Hot Spot Program
ALARA Program
EN-RP-110-03
Collective Radiation Exposure (CRE) Guidelines
EN-RP-110-04
Radiation Protection Risk Assessment Process
EN-RP-110-06
Outage Dose Estimating and Tracking
EN-RP-115-01
BRAC Survey Instructions
Radioactive Material Control
Radiological Controls for Highly Radioactive
Objects
Source Control
Radiological Diving
GMP-0111
Tri-Nuclear Filter Operations
Radiation Surveys
Number
Title
Date
RB +186 Upper Pool HCA Handrail
January 5, 2017
RB +186 Upper Pool and Carousel Area
March 5, 2017
RB +186 Upper Pool 354 R/hr. Tri-Nuke Filter
April 5, 2017
RB +186 Upper Pool 11 R/hr. Tri-Nuke Filter
April 21, 2017
RB +186 Upper Pool 24 Tri-Nuke Filters
April 21, 2017
Radiation Work Permits/ALARA Reviews
Number
Title
Revision
2017-1220
Pre/Post Outage Prep Including Support
2017-1296
RWCU Pump Replacement and Support Activities
2017-1426
Motor Operated Valve and In-Vessel Testing
Radiation Work Permits/ALARA Reviews
Number
Title
Revision
2017-1436
Installation/Removal of Temporary Installation Main
Steam Tunnel
2017-1753
RWCU HX Room FAC Piping Replacement
2017-1800
RF-19 Refuel Floor Outage Activities
2018-1327
Separator Repair Following SHZAM Bolt
Disengagement
71124.04 - Occupational Dose Assessment
Audits and Self-Assessments
Number
Title
Date
LO-RBS-2017-00055 Pre-NRC Assessment IP71124.04
Occupational Dose
October 27, 2017
Condition Reports (CR-RBS-)
2016-05858
2017-08105
2017-00707
2017-00868
2017-00910
2017-03788
2017-05176
2017-05489
Miscellaneous
Number
Title
Date
2017
Multi-Pack TLD Results
2017
2018
NVLAP Accreditation Report
2018
Procedures
Number
Title
Revision
Air Sampling
Dosimetry Administration
Personnel Monitoring
Dose Assessment
Special Monitoring Requirements
Prenatal Monitoring
Dosimeter of Legal Record QA
Whole Body Counting / In-Vitro Bioassay
Procedures
Number
Title
Revision
Electronic Alarming Dosimeter
EN-RP-317-09
Electronic Alarming Dosimeter Calibration
Self-Reading Dosimeter Calibration Records
Number
Title
Date
2017-B2-28-
CALDAT-05667
Self-Reading Dosimeter
September 18, 2017
2017-B2-28-
CALDAT-05713
Self-Reading Dosimeter
September 30, 2017
2017-B2-28-
CALDAT-05736
Self-Reading Dosimeter
September 30, 2017
2017-B2-28-
CALDAT-05836
Self-Reading Dosimeter
September 26, 2017
2017-B2-28-
CALDAT-06692
Self-Reading Dosimeter
December 15, 2017
71151 - Performance Indicator Verification
Procedures
Number
Title
Revision
Performance Indicator Process
Regulatory Assessment Performance Indicator
Guideline
71152 - Problem Identification and Resolution
Condition Reports (CR-RBS-)
2017-06118
2017-04961
71153 - Follow-up of Events and Notices of Enforcement Discretion
Condition Report (CR-RBS-)
2017-06118
Miscellaneous
Number
Title
Revision
PIE-411
Part Interchangeability Evaluation 411
Procedure
Number
Title
Revision
Conduct of Maintenance
The following items are requested for the
Occupational Radiation Safety Inspection
at River Bend Station
January 22-25, 2018
Integrated Report 2018001
Inspection areas are listed in the attachments below.
Please provide the requested information on or before January 12, 2018.
Please submit this information using the same lettering system as below. For example, all
contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled
1-A, applicable organization charts in file/folder 1-B, etc.
If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at
least 30 days later than the onsite inspection dates, so the inspectors will have access to the
information while writing the report.
In addition to the corrective action document lists provided for each inspection procedure listed
below, please provide updated lists of corrective action documents at the entrance meeting.
The dates for these lists should range from the end dates of the original lists to the day of the
entrance meeting.
If more than one inspection procedure is to be conducted and the information requests appear
to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which
file the information can be found.
If you have any questions or comments, please contact Louis Carson at (817) 200-1221 or
Louis.Carson@nrc.gov.
PAPERWORK REDUCTION ACT STATEMENT
This letter does not contain new or amended information collection requirements subject
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
collection requirements were approved by the Office of Management and Budget,
control number 3150-0011.
2.
Occupational ALARA Planning and Controls (71124.02)
Date of last inspection:
January 21, 2016
A.
List of contacts and telephone numbers for ALARA program personnel
B.
Applicable organization charts
C.
Copies of audits, self-assessments, and LERs, written since date of last inspection,
focusing on ALARA
D.
Procedure index for ALARA Program
E.
Please provide specific procedures related to the following areas noted below.
Additional specific procedures may be requested by number after the inspector reviews
the procedure indexes.
1. ALARA Program
2. ALARA Committee
3. Radiation Work Permit (RWP) Preparation
F.
A summary list of corrective action documents (including corporate and sub-tiered
systems) written since date of last inspection, related to the ALARA program. In addition
to ALARA, the summary should also address RWP violations, electronic dosimeter
alarms, and RWP dose estimates
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that
the inspector can perform word searches.
G.
List of work activities greater than 1 rem, since date of last inspection,
Include original dose estimate and actual dose.
H.
Site dose totals and 3-year rolling averages for the past 3 years (based on dose of
record)
I.
Outline of source term reduction strategy
J.
If available, provide a copy of the ALARA outage report for the most recently completed
outages for each unit
K.
Please provide your most recent Annual ALARA Report.
4. Occupational Dose Assessment (Inspection Procedure 71124.04)
Date of Last Inspection:
January 21, 2016
A.
List of contacts and telephone numbers for the following areas:
1. Dose Assessment personnel
B.
Applicable organization charts
C.
Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs
written since date of last inspection, related to:
1. Occupational Dose Assessment
D.
Procedure indexes for the following areas:
1. Occupational Dose Assessment
E.
Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures will be requested by number after the inspector reviews
the procedure indexes.
1. Radiation Protection Program
2. Radiation Protection Conduct of Operations
3. Personnel Dosimetry Program
4. Radiological Posting and Warning Devices
5. Air Sample Analysis
6. Performance of High Exposure Work
7. Declared Pregnant Worker
8. Bioassay Program
F.
List of corrective action documents (including corporate and sub-tiered systems) written
since date of last inspection, associated with:
1. National Voluntary Laboratory Accreditation Program (NVLAP)
2. Dosimetry (TLD/OSL, etc.) problems
3. Electronic alarming dosimeters
4. Bioassays or internally deposited radionuclides or internal dose
5. Neutron dose
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that
the inspector can perform word searches.
G.
List of positive whole body counts since date of last inspection, names redacted if
desired
H.
Part 61 analyses/scaling factors
I.
The most recent National Voluntary Laboratory Accreditation Program (NVLAP)
accreditation report or, if dosimetry is provided by a vendor, the vendors most recent
results
SUNSI Review:
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: CHY/rdr
Yes No
Publicly Available
Sensitive
OFFICE
SRI:DRP/C
RI:DRP/C
ARI:DRP/C
SPE:DRP/C
C:DRS/EB1
C:DRS/EB2
NAME
JSowa
BParks
MOBanion
CYoung
TFarnholtz
JDrake
SIGNATURE
/RA/
/RA/
/RA-E/
/RA/
/RA/
/RA/
DATE
4/23/18
4/30/18
4/24/18
4/27/18
4/23/18
4/23/18
OFFICE
C:DRS/OB
C:DRS/PSB2
TL:IPAT
BC:DRP/C
NAME
VGaddy
HGepford
GGeorge
JKozal
SIGNATURE
/RA/
/RA/
/RA/
/RA/
DATE
4/14/18
4/23/18
4/24/18
5/08/18
May 8, 2018
Mr. William
- F. Maguire, Site Vice President
Entergy Operations, Inc.
River Bend Station
5485 U.S. Highway 61N
St. Francisville, LA 70775
SUBJECT:
RIVER BEND STATION - NRC INTEGRATED INSPECTION
REPORT 05000458/2018001
Dear Mr. Maguire:
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at your River Bend Station, Unit 1. On April 25, 2018, 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.
NRC inspectors documented two findings of very low safety significance (Green) in this report.
One of these findings involved a violation of NRC requirements. The NRC is treating this
violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement
Policy.
If you contest the violation or significance of the NCV, you should provide a response within
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 the 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 the River Bend Station.
W. Maguire
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 10 CFR 2.390, Public Inspections, Exemptions, Requests for
Withholding.
Sincerely,
/RA/
Jason
- W. Kozal, Chief
Project Branch C
Division of Reactor Projects
Docket No. 50-458
License No. NPF-47
Enclosure:
Inspection Report 05000458/2018001
w/ Attachments:
1. Documents Reviewed
2. Occupational Radiation Safety Inspection
Request for Information
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number:
05000458
License Number:
Report Number:
Enterprise Identifier: I-2018-001-0009
Licensee:
Entergy Operations, Inc.
Facility:
River Bend Station
Location:
Saint Francisville, Louisiana
Inspection Dates:
January 1, 2018 to March 31, 2018.
Inspectors:
- J. Sowa, Senior Resident Inspector
- B. Parks, Resident Inspector
- M. OBanion, Acting Resident Inspector
- J. Drake, Senior Reactor Inspector
- C. Young, Senior Project Engineer
- L. Carson II, Senior Health Physicist
Approved By:
- J. Kozal, Chief, Branch C
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at River Bend Station in accordance with
the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for
overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information. Findings and
violations being considered in the NRCs assessment are summarized in the table below.
List of Findings and Violations
Failure to Implement Procedure for Storage of Material in the Pools
Cornerstone
Significance
Cross-cutting
Aspect
Report
Section
Occupational
Radiation
Safety
Green
Closed
[H.4] -
Human
Performance,
Teamwork
71124.02 -
Occupational
As Low As
Reasonably
Achievable
(ALARA)
Planning and
Controls
The inspectors identified a non-cited violation of Technical Specification 5.4.1.a for the
licensees failure to implement written procedures for activities referenced in Appendix A of
Regulatory Guide 1.33, Revision 2, dated February 1978. Specifically, the licensee failed to
implement radioactive material control Procedure ADM-0071, Fuel Pools Material Control,
Revision 8, for the storage and movement of spent Tri-Nuke filters.
Installation of an Incorrectly Specified Relay Causes Plant Transient and Reactor Scram
Cornerstone
Significance
Cross-cutting
Aspect
Report
Section
Initiating
Events
Green
Closed
[H.5] -
Human
Performance,
Work
Management
71152 -
Problem
Identification
and
Resolution
The inspectors reviewed two examples of a self-revealed finding for the licensees installation
of an incorrectly specified relay in 1) the control circuitry for the feedwater level control system
and 2) the turbine generator voltage regulator circuitry. In each instance, the incorrectly
specified relay failed in service, causing a plant transient and automatic reactor scram.
Additional Tracking Items
Type
Issue number
Title
Report
Section
Status
Due to Failure of Main
Generator Voltage Regulator
Mode Transfer Relay
Closed
Due to Failure of Main
Feedwater Regulator
Transfer Relay
Closed
PLANT STATUS
River Bend Station began the inspection period at rated thermal power. On January 8, 2018,
the unit was shut down for a planned maintenance outage. A reactor startup was performed on
January 30, 2018. The unit was shut down to conduct a forced outage on February 1, 2018,
due to an unexpected trip of the B reactor recirculation pump. A reactor startup was performed
on February 9, 2018. The unit was shut down to conduct a forced outage on March 1, 2018,
due to a pipe leak associated with the main condenser. A reactor startup was performed on
March 6, 2018. The unit was returned to rated thermal power on March 20, 2018. The unit
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 plant status activities described in
IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem
Identification and Resolution. 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
71111.04Equipment Alignment
Partial Walkdown (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Division I residual heat removal system on January 25, 2018
(2) Division II residual heat removal system on January 25, 2018
(3) Control building heating, ventilation, and air conditioning (HVAC) system on
March 15, 2018
Complete Walkdown (1 Sample)
The inspectors evaluated system configurations during a complete walkdown of the standby
service water system on March 8, 2018.
71111.05AQFire Protection Annual/Quarterly
Quarterly Inspection (4 Samples)
The inspectors evaluated fire protection program implementation in the following selected
areas:
(1) Residual heat removal pump A room, fire area AB-5 on January 25, 2018
(2) Residual heat removal pump B room, fire area AB-3 on January 25, 2018
(3) Standby service water pump A room, fire area PH-1/Z-1on March 12, 2018
(4) Standby service water pump B room, fire area PH-2/Z-1 on March 12, 2018
71111.06Flood Protection Measures
Internal Flooding (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the standby service
water pump rooms, SW-01 on January 12, 2018.
Cables (1 Sample)
The inspectors evaluated cable submergence protection in:
(1) Electrical manhole 1EMH607 on January 16, 2018
(2) Electrical manhole 1EMH613 on January 16, 2018
71111.11Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 Sample)
The inspectors observed and evaluated licensed operator requalification training on
February 6, 2018.
Operator Performance (1 Sample)
The inspectors observed and evaluated the operators performance during a plant shutdown for
a planned maintenance outage on January 7, 2018.
71111.12Maintenance Effectiveness
Routine Maintenance Effectiveness (3 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated
with the following equipment and/or safety significant functions:
(1) Functional failure review of standby service water on January 16, 2018
(2) Functional failure review of the 120 VAC system on February 19, 2018
(3) Functional failure review of the reactor recirculation system associated with the failure of
the B recirculation pump to upshift to fast speed on March 1, 2018
71111.13Maintenance Risk Assessments and Emergent Work Control (4 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent
work activities:
(1) Yellow shutdown risk condition with containment access hatch open on January 8, 2018
(2) Yellow risk condition due to fuel movement and Division III emergency diesel generator
inoperability while in Mode 5 on January 24, 2018
(3) Yellow risk condition due to high pressure core spray pump inoperability during remote
shutdown panel surveillance testing on February 23, 2018
(4) Yellow risk condition due to residual heat removal pump B discharge flow inoperability
during maintenance and testing on March 15, 2018
71111.15Operability Determinations and Functionality Assessments (5 Samples)
The inspectors evaluated the following operability determinations and functionality
assessments:
(1) E31-N604F main steam line tunnel temperature exceeded allowable values per
surveillance test requirements on January 3, 2018
(2) Jacket water leaks associated with Division I emergency diesel generator on
January 5, 2018
(3) Unexpected system response during Division II standby service water surveillance
testing on January 15, 2018
(4) Residual heat removal shutdown cooling outboard isolation valve E12-MOVF008
over-torqued on February 19, 2018
(5) Division I inverter DNB-INV01A1 system output voltage exceeded max allowable voltage
on March 20, 2018
71111.18Plant Modifications (1 Sample)
The inspectors evaluated the following permanent modification:
(1) Division I standby diesel generator exhaust manifold piping to eliminate a vulnerability to
flaw formation and leakage after Division I emergency diesel generator shroud
replacement on January 19, 2018
71111.19Post Maintenance Testing (7 Samples)
The inspectors evaluated the following post maintenance tests:
(1) STP-209-6310, Revision 39, RCIC Pump and Valve Quarterly Operability and Flow
Test, following maintenance on the reactor core isolation cooling governor valve on
January 5, 2018
(2) STP-504-4504, Revision 18, RPS/Control Rod Block - IRM D Channel Functional Test
and LSFT, following replacement of intermediate range monitor D control relay
H13-P672-Z2K18 on January 13, 2018
(3) STP-309-0206, Revision 29, Division I Diesel Generator 184 Day Operability Test,
following maintenance on Division I emergency diesel generator on January 22, 2018
(4) STP-309-0203, Revision 329, Division III Diesel Generator Operability Test, following
replacement of the Division III emergency diesel generator voltage regulator on
January 24, 2018
(5) STP-504-4503, Revision 20, RPS/Control Rod Block - IRM C Channel Functional Test
and LSFT, following maintenance on intermediate range monitor C on January 30, 2018
(6) SOP-0030, Revision 33, High Pressure Core Spray System (Sys 203), following
maintenance on high pressure core spray motor supply breaker on February 22, 2018
(7) STP-256-6603, Revision 21, Division I Standby Service Water Quarterly Valve
Operability Test, following maintenance and repairs to standby service water valve
SWP-MOV96A on March 5, 2018
71111.20Refueling and Other Outage Activities (3 Samples)
(1) The inspectors evaluated a planned maintenance outage implemented to remove
damaged fuel assemblies. Inspection activities occurred from January 8, 2018, to
January 31, 2018.
(2) The inspectors evaluated forced outage activities from February 1, 2018, to
February 9, 2018. The forced outage occurred due to a failure of the B reactor
recirculation pump to shift to fast speed. Station personnel conducted a forced outage
and replaced the 13.8 kV transformer associated with the B reactor recirculation
pump.
(3) The inspectors evaluated forced outage activities from March 1, 2018, to
March 7, 2018. The forced outage occurred due to a leak from a crack on piping
associated with the main condenser. Station personnel conducted a forced outage
and repaired the leak.
71111.22Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine (3 Samples)
(1) STP-203-1302, Revision 25, E22-S001BAT Quarterly Surveillance, on
January 18, 2018
(2) STP-057-3801, Revision 012, Containment Equipment Hatch Leak Rate Test, on
January 27, 2018
(3) OSP-0604, Revision 2, Remote Shutdown System Control Circuit Operability Test, on
February 26, 2018
In-service (2 Samples)
(1) STP-204-1300, Revision 18, LPCI Pump A Start Time Delay Channel Calibration and
Channel Functional Test, on January 2, 2018
(2) STP-256-6301, Revision 23, Division I Standby Service Water Quarterly Valve
Operability Test, on January 6, 2018
Reactor Coolant System Leak Detection (1 Sample)
(1) STP-000-0001, Revision 082, Daily Operating Logs, on January 4, 2018
Containment Isolation Valve (1 Sample)
(1) STP-057-7705, Revision 012, Primary Containment Airlocks Seal Leakage Rate Test,
on January 28, 2018
71114.06Drill Evaluation
Drill/Training Evolution (1 Sample)
The inspectors evaluated a simulator-based emergency preparedness drill on
March 13, 2018.
RADIATION SAFETY
71124.02Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls
Radiological Work Planning (1 Sample)
The inspectors evaluated the licensees radiological work planning by reviewing the
following activities:
(1) RWP 2017-1220, Pre/Post Outage Prep Including Support
(2) RWP 2017-1296, RWCU Pump Replacement and Support Activities
(3) RWP 2017-1426, Motor Operated Valve and In-Vessel Testing
(4) RWP 2017-1436, Installation/Removal of Temporary Installation Main Steam Tunnel
(5) RWP 2017-1753, RWCU Hx Room Flow Accelerated Corrosion (FAC) Piping
Replacement
(6) RWP 2017-1800, RF-19 Refuel Floor Outage Activities
(7) RWP 2018-1327, Separator Repair Following SHZAM Bolt Disengagement
Verification of Dose Estimates and Exposure Tracking Systems (1 Sample)
The inspectors evaluated dose estimates and exposure tracking.
Implementation of ALARA and Radiological Work Controls (1 Sample)
The inspectors reviewed ALARA practices and radiological work controls by reviewing the
following activities:
(1) RWP 2017-1220, Pre/Post Outage Prep Including Support
(2) RWP 2017-1296, RWCU Pump Replacement and Support Activities
(3) RWP 2017-1426, Motor Operated Valve and In-Vessel Testing
(4) RWP 2017-1436, Installation/Removal of Temporary Installation Main Steam Tunnel
(5) RWP 2017-1753, RWCU HX Room FAC Piping Replacement
(6) RWP 2017-1800, RF-19 Refuel Floor Outage Activities
(7) RWP 2018-1327, Separator Repair Following SHZAM Bolt Disengagement
Radiation Worker Performance (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance.
71124.04 - Occupational Dose Assessment
Source Term Characterization (1 Sample)
The inspectors evaluated the licensees source term characterization.
External Dosimetry (1 Sample)
The inspectors evaluated the licensees external dosimetry program.
Internal Dosimetry (1 Sample)
The inspectors evaluated the licensees internal dosimetry program.
Special Dosimetric Situations (1 Sample)
The inspectors evaluated the licensees performance for special dosimetric situations.
OTHER ACTIVITIES - BASELINE
71151Performance Indicator Verification (3 Samples)
The inspectors verified licensee performance indicators submittals listed below:
(1)
IE01: Unplanned Scrams per 7000 Critical Hours Sample (01/01/2017 - 12/31/2017)
(2)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (01/01/2017 -
2/31/2017)
(3)
IE04: Unplanned Scrams with Complications (USwC) Sample (01/01/2017 -
2/31/2017)
71152Problem Identification and Resolution
Annual Follow-up of Selected Issues (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issue:
(1) Relay failures in the feedwater level control system and the turbine generator voltage
regulator control system resulted in reactor scrams
71153Follow-up of Events and Notices of Enforcement Discretion
Licensee Event Reports (2 Samples)
The inspectors evaluated the following licensee event reports which can be accessed at
https://lersearch.inl.gov/LERSearchCriteria.aspx:
(1) Licensee Event Report 05000458/2017-007-00, Automatic Reactor Scram Due to
Failure of Main Generator Voltage Regulator Mode Transfer Relay on August 21, 2017
(2) Licensee Event Report 05000458/2017-008-00, Automatic Reactor Scram Due to
Failure of Main Feedwater Regulator Transfer Relay on October 12, 2017
INSPECTION RESULTS
Failure to Implement Procedure for Storage of Material in the Pools
Cornerstone
Significance
Cross-cutting
Aspect
Report Section
Occupational
Radiation Safety
Green
Closed
[H.4] - Human
Performance,
Teamwork
71124.02 -
Occupational
As Low As
Reasonably
Achievable
(ALARA)
Planning and
Controls
The inspector identified a non-cited violation of Technical Specification 5.4.1.a, for the
licensees failure to implement written procedures for activities referenced in Appendix A of
Regulatory Guide 1.33, Revision 2, dated February 1978. Specifically, the licensee failed to
implement radioactive material control Procedure ADM-0071, Fuel Pools Material Control,
Revision 8, for the storage and movement of spent Tri-Nuke filters.
Description:
The inspector reviewed condition reports (CRs) that documented incidents associated with the
movement and storage of highly radioactive materials in the various pools at River Bend
Station (RBS) in 2017. Four radiological occurrences involved unplanned and unanticipated
movements of spent Tri-Nuke filters around the separator and upper inclined fuel transfer
storage (IFTS) pools.
January 5, 2017, CR-RBS-2017-0100: Radiation Protection (RP) was notified that
a spent Tri-Nuke filter was found floating on the surface of the separator pool.
Surveys of the filter and surrounding area were performed by RP technicians.
Dose rates on the filter measured 2.2 Roentgen/hour (R/hr) on contact and
0.85 R/hr at 30 centimeters (cm).
April 3, 2017, CR-RBS-2017-03011: A used Tri-Nuke filter measuring 1.3 R/hr and
0.350 R/hr at 30 cm was discovered floating in the reactor building (RB)-186
separator pool.
April 24, 2017, CR-RBS-2017-03424: While performing video surveillance of the
refueling pool on RB-186, a Tri-Nuke filter was discovered floating on the surface of
the separator pool. The filter had a dose rate of 11 R/hr on contact and 6 R/hr at
cm.
During the week of April 27, 2017, the licensee transferred the 30 Tri-Nuke filters
from the separator pool to the IFT
- S. However, one of the Tri-Nuke filters
(0.300 R/hr) had been damaged when falling into the bottom of the IFTS pool. It
was eventually recovered and stored.
The inspector examined the circumstances that caused the Tri-Nuke filters to become buoyant
and float around the separator pool resulting in unintended radiological hazards. Two CRs
from 2015 (CR-RBS-2015-07893 and CR-RBS-2015-08050) identified concerns with air
intrusion from a leaky spent fuel cooling system valve. Also, two CRs from 2017
(CR-RBS-2017-01881 and CR-RBS-2017-03424) identified that the leaky valve caused spent
Tri-Nuke filters to float. The licensee eventually determined the solution to the problem was to
transfer the spent Tri-Nuke filters to the upper IFTS pool. However, the inspector determined
that the licensee was not supposed to leave the spent Tri-Nukes in the separator and upper
IFTS pools unless designed storage racks were in place or an engineering change request
(ECR) evaluation allowed the practice.
The movement and storage of radioactive material in and around the pools at RBS are
implemented through the following procedures:
EN-RP-121, Revision 13, Radioactive Material Control
EN-RP-123, Revision 1, Radiological Controls of Highly Radioactive Objects
ADM-0071, Revision 8, Fuel Pools Material Control
The inspector determined that the purpose of Entergy Corporate Procedures EN-RP-121 and
EN-RP-123 was to prevent the unauthorized movement and removal of radioactive materials
around the site and from pools. These procedures required that licensee personnel receive
proper authorization from reactor engineering and radiation protection management for
movement and storage of radioactive materials in pools and the around pools. Based on the
documents and procedures reviewed by the inspector, the licensee did not specify storage
requirements or equipment for these filters to prevent them from floating to the top of the pools
and becoming radiological hazards.
The inspector reviewed RBS site-specific Procedure ADM-0071, Revision 8, which described
the requirements established for the control of miscellaneous material stored in fuel pools. At
RBS, radioactive materials are stored in the following seven pools: spent fuel pool, cask pool,
lower IFTS, upper IFTS, upper containment pool, dryer storage pool, and separator pool.
ECR RBS-ER-97-504, Fuel Pool Inventory Identification, Justification, and Evaluation, dated
September 30, 1997, stated that the purpose of ADM-0071 was to provide a means to
adequately control, regulate, and inventory non-special nuclear material stored in the spent
fuel pool and upper containment pools. Items may not be stored in the spent fuel storage
upper containment pools, which includes the separator pool, without design engineering
approval. Additionally, items that are not stainless steel or in a stainless steel container are
not to be stored without being verified radiation resistant and not detrimental to the fuel pool
water quality.
Section 7.3 of Procedure ADM-0071 provided instructions for storing or moving material within
the same pool or to another pool location. Section 7.3.7 required that the pool material
inventory POOL MATERIAL CONTROL FORM be completed and updated after approval of
the material storage/move by the reactor engineering manager and radiation protection
superintendent. The form required specific information about proposed items to be stored,
such as the radiation surveys taken, work order used, storage container location, special
requirements, radiation exposure duration, and applicable ECR evaluations. At the time of this
inspection, the licensee did not have any pool material control forms completed for the 30 Tri-
Nuke filters that were placed into the separator pool and subsequently transferred to the IFTS
in 2017. In particular, there was no pool material control forms signed by the reactor
engineering manager and radiation protection superintendent approving the proper storage
and movement of these Tri-Nuke filters for either location.
Procedure ADM-0071 allowed miscellaneous items such as Tri-Nuke filters to be stored in the
separator and IFTS pools if an ECR evaluation and engineering approval on the storage
method were done. The inspector queried whether any ECRs had been performed for storage
of the Tri-Nuke filters. Only two were available for the inspectors review. The two ECRs
(ECR RBS-ER-97-504 and ECR 33163) revealed that the licensee had not made specific
provisions or performed evaluations for the storage of Tri-Nuke filters in the separator or upper
IFTS pools.
The inspector determined that licensees procedures did not adequately address securing
highly radioactive material in pools such as Tri-Nuke filters to prevent radioactive material from
floating to the pool surface and thereby becoming radiation hazards to personnel, as had
occurred three times in early 2017. Further, the failure to follow the requirements of
Procedure ADM-0071 resulted in bypassing the performance of an evaluation to ensure proper
movement and storage of the filters.
Corrective Actions: Immediate safety concerns with filters becoming buoyant due to the air
intrusion in the separator pool were addressed when the licensee transferred the 30 Tri-Nuke
filters to the IFTS pool in late April 2017. Procedure compliance issues are being addressed
through an action item in CR-RBS-2018-00523.
Corrective Action References: CR-RBS-2018-00523
Performance Assessment:
Performance Deficiency: The licensees failure to implement written procedures for activities
referenced in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978, as
required by Technical Specification 5.4.1.a, was a performance deficiency. Specifically, the
licensee failed to implement radioactive material control Procedure ADM-0071, Fuel Pools
Material Control, Revision 8, for the storage and movement of spent Tri-Nuke filters.
Screening: The performance deficiency was more than minor because it adversely affected
the programs and process (exposure control) attribute of the Occupational Radiation Safety
Cornerstone and its objective to ensure the adequate protection of the worker health and
safety from exposure to radiation from radioactive material. Specifically, allowing highly
radioactive material (Tri-Nuke filters) to be moved and stored in an unsafe, unevaluated,
unapproved manner resulted in unanticipated dose rates and unplanned worker exposures to
radiation.
Significance: The inspectors assessed the significance of the finding using NRC Inspection
Manual Chapter 0609, Appendix, C, Occupational Radiation Safety Significance
Determination Process, and determined that the finding was of very low safety significance
(Green) because it did not: (1) involve ALARA planning or work controls, (2) did not involve
an overexposure, (3) did not have a substantial potential to be an overexposure, and (4) the
ability to assess dose was not compromised.
Cross-cutting Aspect: The finding has a cross-cutting aspect in the area of human
performance, associated with teamwork, because individuals and work groups failed to
communicate and coordinate their activities within and across organizational boundaries to
ensure nuclear safety was maintained. Specifically, the communication and coordination of
activities between construction projects, health physics, and nuclear engineering failed to
prevent radiological issues associated with the storage and movement of Tri-Nuke filters.
Enforcement:
Violation: Technical Specification 5.4.1.a requires, in part, that procedures be written,
implemented, and established for those areas recommended in Regulatory Guide 1.33,
Appendix A, Revision 2, 1978. Section 7(b) of Regulatory Guide 1.33, Appendix A, requires
procedures for control of radioactive materials to minimize potential releases to the
environment and control personnel exposure associated with solid radioactive waste.
Licensee Procedure ADM-0071, Fuel Pools Material Control, Revision 8, Section 7.1,
requires that if material must be stored in a pool or previously stored material must be moved
from one pool to a different pool or to a different area in the same pool, Section 7.3 must be
completed. Section 7.3.7 requires that the pool material inventory POOL MATERIAL
CONTROL FORM be updated after approval of the material storage/move by the reactor
engineering manager and radiation protection superintendent.
Contrary to the above, beginning in 2017 and to present, the licensee stored material in a
pool and moved previously stored material from one pool to a separate pool without
completing Section 7.3 of Procedure ADM-0071. Specifically, the licensee stored 30 Tri-Nuke
filters in the separator pool without completing the pool material Inventory form and, in
April 2017, moved the filters to the incline fuel transfer storage pool without completing/
updating a pool material Inventory POOL MATERIAL CONTROL FORM and obtaining the
required approvals.
As of January 26, 2018, the licensee had not fully implemented Section 7.3 of
Procedure ADM-0071 by updating the form and obtaining written approval from the radiation
protection superintendent and reactor engineering manager for the movement and safe
storage of the 30 Tri-Nuke filters in the incline fuel transfer storage pool.
Disposition: This violation is being treated as a non-cited violation consistent with
Section 2.3.2.a of the NRC Enforcement Policy.
Installation of an Incorrectly Specified Relay Causes Plant Transient and Reactor Scram
Cornerstone
Significance
Cross-cutting
Aspect
Report
Section
Green
Closed
[H.5] - Human
Performance,
Work
Management
71152 -
Problem
Identification
and
Resolution
The inspectors reviewed two examples of a self-revealed finding for the licensees installation
of an incorrectly specified relay in 1) the control circuitry for the feedwater level control system
and 2) the turbine generator voltage regulator circuitry. In each instance, the incorrectly
specified relay failed in service, causing a plant transient and automatic reactor scram.
Description:
Example 1: On August 18, 2017, with the plant operating at 100 percent power, an automatic scram occurred. At the time of the scram, operators were performing a scheduled
surveillance test that called for a planned shift of the controlling channel of the feedwater level
control system from channel B to channel
- A. Immediately after the shift, feedwater regulating
valves went full open and recirculation pumps downshifted to slow speed. The combination
of these events caused an automatic scram to occur on high flow-biased thermal power.
The cause of the scram was a failure of the feedwater level select relay, C33A-K12. The
failure of this relay caused the interpreted level in the feedwater level control system to go to
zero, which in turn caused a full open demand on the feedwater regulating valves and a
downshift of recirculation pumps from fast to slow speed on a perceived low level condition in
the reactor vessel.
A subsequent investigation determined that the feedwater level select relay failed due to a
degradation in the electrical contacts on the relay. The degradation caused a sharp increase
in resistance across the contacts, which in turn led to a substantial reduction in the current
passing through these contacts to the rest of the feedwater level control circuit. With the
current substantially reduced, the circuit incorrectly perceived a low vessel level condition.
The failed relay was a General Electric Agastat GPI type relay. Operating experience at
River Bend Station and at other sites in the industry has established that this type of relay is
prone to intermittent failure. When used in low current applications such as those associated
with the feedwater level control circuit, there is a potential for oxidation to build up on the
contacts of the relay, which will create resistance across the relay and impair its ability to pass
current. In light of this operating experience, the licensee issued part interchangeability
evaluation (PIE) 411 in March 1993. PIE 411 called for a GPIA type relay with gold-plated
contacts to be used for C33A-K12 in lieu of the silver-plated GPI type relay that had
traditionally been used.
The inspectors determined that PIE-411 was a self-imposed licensee standard. The licensee
complied with this standard until February 2017, when the gold-plated relay installed in the
system was incorrectly replaced with a silver-plated relay. Given that the silver-plated relay
was being used in a low current application, it built up resistance over time and eventually
failed, causing the scram.
Example 2: On June 23, 2017, with the plant operating at 100 percent power, an automatic scram occurred. At the time of the scram, operators were performing a scheduled
surveillance test that called for a planned shift of the turbine generator voltage regulator
control from automatic to manual. Immediately after the shift, the main generator tripped
which caused a subsequent reactor scram.
The cause of the scram was a failure of the voltage regulator transfer circuit relay,
EXS-PNL1-43A. The failure of this relay caused an open circuit in both the manual and
automatic voltage regulators and complete loss of control of the Alterrex Excitation System.
When neither the manual nor the automatic voltage regulator is connected to the Alterrex
Excitation System, there is no excitation field applied. The result is a turbine trip on loss of
excitation.
A subsequent investigation determined that the main generator voltage regulator mode
transfer relay failed due to a degradation in the electrical contacts on the relay. The
degradation caused a sharp increase in resistance across the contacts, which in turn led to a
substantial reduction in the current passing through these contacts to the rest of the voltage
regulator control circuit. With the current substantially reduced, the circuit could not be
completed for either the manual or automatic control system of the turbine voltage regulator.
The failed relay was a General Electric DC operated 4-pole double throw miniature 43A relay
provided as part of the turbine generator package and is part of the Alterrex exciter transfer
panel assembly. Operating experience at River Bend Station and at other sites in the
industry has established that this type of relay is prone to intermittent failure. The station
generated engineering change 40442 in 2012 to replace the 43A relay with a different model
documenting obsolescence of this relay as well as operating experience related to intermittent
failures of this type of relay. In light of this operating experience, the licensee cancelled
engineering change 40442 for unknown reasons and did not replace the 43A relay with a
different style.
Corrective Actions: The licensee installed the correctly specified relay in the feedwater level
control system and an upgraded vendor recommended relay in the turbine voltage regulator
control system. The licensee also completed an extent of condition review on similar relays.
Corrective Action References: Condition Reports CR-RBS-2017-06118 and
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees installation of an
incorrectly specified relay in 1) the control circuitry for the feedwater level control system and
2) the control circuitry for the main generator voltage regulator were two examples of a
performance deficiency.
Screening: The performance deficiency was more than minor, and therefore a finding,
because it was associated with the equipment performance attribute of the Initiating Events
Cornerstone and adversely affected the cornerstone objective to limit the likelihood of events
that upset plant stability and challenge critical safety functions during shutdown as well as
power operations.
Significance: The inspectors assessed the significance of the finding using Inspection
Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-
Power. The finding was determined to be of very low safety significance (Green) because
the finding did not contribute to both the likelihood of a reactor trip and the likelihood that
mitigating equipment would not be available.
Cross-cutting Aspect: The finding has a cross-cutting aspect in the area of human
performance associated with work management because the licensee failed to implement a
process of planning, controlling, and executing work activities such that nuclear safety is the
overriding priority.
Enforcement: Inspectors did not identify a violation of regulatory requirements associated
with this finding.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On January 26, 2018, the inspectors presented the radiation safety inspection results to
Mr.
- W. Maguire, Site Vice President, and other members of the licensee staff.
On April 25, 2018, the inspectors presented the quarterly resident inspector inspection results to
Mr.
- W. Maguire, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
71111.04 - Equipment Alignment
Condition Reports (CR-RBS-)
2017-05292
2017-07460
2017-07880
2018-00615
2018-00992
Drawings
Number
Title
Revision
PID-09-10E
Engineering P&I Diagram, System 256, Service
Water - Standby
PID-22-09A
Engineering P&I Diagram, System 402, HVAC -
Control Building
Procedures
Number
Title
Revision
R-STM-0118
Service Water Systems
R-STM-0402
HVAC - Control Building and Diesel Generator
Building
SOP-0031
338
SOP-0042
Standby Service Water System (Sys #256)
SOP-0058
Control Building HVAC System (Sys #402)
71111.05 - Fire Protection
Procedures
Number
Title
Revision
AB-070-502
RHR Pump A Room, Fire Area AB-5
AB-070-505
RHR Pump B Room, Fire Area AB-3
Control of Combustibles
Standby Cooling Pump A Room, Fire Area PH-1/Z-1 3
Standby Cooling Pump B Room, Fire Area PH-2/Z-1 3
STP-250-4533
FPM-PNL6 Fire Detection Channel Functional and
Operational Tests for Zone SD72, SD73, and SD89
(A&B)
71111.06 - Flood Protection Measures
Condition Reports (CR-RBS-)
2018-00200
2018-00367
2018-00369
Procedure
Number
Title
Revision
PN-317
Max Flood Elevations for Moderate Energy Line
Cracks in Cat I Structures
Work Orders
0052802383
0052802384
71111.11 - Licensed Operator Requalification Program and Licensed Operator
Performance
Procedures
Number
Title
Revision
GOP-0002
Power Decrease/Plant Shutdown
078
RSMS-OPS-HIT1
Licensed Operator Requalification
71111.12 - Maintenance Effectiveness
Condition Reports (CR-RBS-)
2017-00629
2017-01579
2017-01668
2017-01703
2017-01739
2017-01748
2017-01749
2017-03871
2017-04048
2017-04514
2017-05273
2017-05939
2017-06767
2017-06977
2017-06998
2017-07017
2017-07200
2017-07410
2017-07454
2017-07820
2017-07880
2017-07950
2018-00825
2018-01363
Procedures
Number
Title
Revision
Maintenance Rule Scope and Basis
Maintenance Rule Monitoring
Maintenance Rule (A)(1) Process
Procedures
Number
Title
Revision
SOP-0042
Standby Service Water System (Sys #256)
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Condition Report (CR-RBS-)
2018-00505
Procedures
Number
Title
Revision
ADM-0096
Risk Management Program Implementation and
On-Line Maintenance Risk Assessment
26
On Line Risk Assessment
Shutdown Operations Protection Plan (SOPP)
036
71111.15 - Operability Determinations and Functionality Assessments
Condition Reports (CR-RBS-)
2016-05866
2017-04048
2017-04097
2017-04302
2017-05033
2017-07111
2017-07162
2017-07199
2017-07219
2017-07532
2017-08048
2018-00194
2018-00402
Miscellaneous
Number
Title
Revision
SWP-SOV523B Reasonable Expectation of
Operability Input for CR-RBS-2016-05866
Procedures
Number
Title
Revision
Log Report - Normal Switchgear, Control, and
Diesel Generator Buildings
108
STP-000-0001
Daily Operating Logs
STP-256-6608
Division II Standby Service Water 2 Year Position
Indication Verification Test
STP-309-0201
Division I Diesel Generator Operability Test
71111.18 - Plant Modifications
Calculation
Number
Title
Revision
G13.18.2.4-108
LPI, Inc. Evaluation of Standby Diesel Generator
Exhaust Manifold Stiffeners
Condition Reports (CR-RBS-)
2015-04817
2016-06841
2016-07753
2017-07111
2017-07532
2017-08048
Drawing
Number
Title
Revision
PID-08-09B
Engineering P&I Diagram System 309 Diesel
Generator
Procedure
Number
Title
Revision
SOP-0053
Standby Diesel Generator and Auxiliaries
(Sys #309)
057
71111.19 - Post-Maintenance Testing
Condition Reports (CR-RBS-)
2017-07237
2017-07728
Miscellaneous
Number
Title
Revision/Date
E22-S004 ACB2
Vendor Overhaul Breaker
Work Orders
00469400
00476322
00479296
Procedures
Number
Title
Revision
CMP-EM-203-1001
Inspection and Maintenance of 4.16 KV
Magne-Blast Circuit Breakers
STP-209-0201
RCIC Discharge Piping Fill and Valve Lineup
Verification
Work Orders
228397
00478865
00492550
00493155
00493741
2650988
2769345
2779858
71111.20 - Refueling and Other Outage Activities
Procedures
Number
Title
Revision
GOP-0001
Plant Startup
099
GOP-0002
Power Decrease/Plant Shutdown
078
71111.22 - Surveillance Testing
Condition Reports (CR-RBS-)
2015-02736
2018-00290
Drawing
Number
Title
Revision
GE-828E534AA
Elementary Diagram Residual Heat Removal
Sheet 8
Procedures
Number
Title
Revision
SOP-0018
Normal Service Water System
SOP-0042
Standby Service Water System
Work Orders
00492725
2785880
2787021
71114.06 - Drill Evaluation
Miscellaneous
Number
Title
Revision
RDRL-EP-1201
Site Drill Scenario
71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and
Controls
Audits and Self-Assessments
Number
Title
Date
LO-RLO-2017-0055
Pre-NRC Self-Assessment Radiation Safety -
December 4, 2017
LO-RLO-2016-0145
Pre-NRC Self-Assessment Radiation Safety -
January 17, 2017
Condition Reports (CR-RBS-)
2015-07893
2015-08050
2017-00100
2017-00707
2017-00868
2017-01250
2017-01355
2017-01731
2017-01881
2017-01927
2017-03011
2017-03237
2017-03266
2017-03424
2017-03598
2017-03788
2017-04856
2017-04941
2017-05499
2017-01372
2017-01422
Miscellaneous
Number
Title
Date
RF-19 Water Movement Plan
January 2017
CFR Part 20.1101(c) Report for 2016
June 2017
ADM-0071
Post Material Inventory Report Post RF-19
May 31, 2017
Relocate Tri-Nuke filters from the Separator Pool
the IFTS
April 11, 2017
Procedures
Number
Title
Revision
ADM-0071
Fuel Pools Material Control
Radiation Worker Expectations
Access Control for Radiologically Controlled Areas
Procedures
Number
Title
Revision
Radiological Control
Radiological Work Permits
Radiological Survey Documentation
Radiation Protection Posting
Hot Spot Program
ALARA Program
EN-RP-110-03
Collective Radiation Exposure (CRE) Guidelines
EN-RP-110-04
Radiation Protection Risk Assessment Process
EN-RP-110-06
Outage Dose Estimating and Tracking
EN-RP-115-01
BRAC Survey Instructions
Radioactive Material Control
Radiological Controls for Highly Radioactive
Objects
Source Control
Radiological Diving
GMP-0111
Tri-Nuclear Filter Operations
Radiation Surveys
Number
Title
Date
RB +186 Upper Pool HCA Handrail
January 5, 2017
RB +186 Upper Pool and Carousel Area
March 5, 2017
RB +186 Upper Pool 354 R/hr. Tri-Nuke Filter
April 5, 2017
RB +186 Upper Pool 11 R/hr. Tri-Nuke Filter
April 21, 2017
RB +186 Upper Pool 24 Tri-Nuke Filters
April 21, 2017
Radiation Work Permits/ALARA Reviews
Number
Title
Revision
2017-1220
Pre/Post Outage Prep Including Support
2017-1296
RWCU Pump Replacement and Support Activities
2017-1426
Motor Operated Valve and In-Vessel Testing
Radiation Work Permits/ALARA Reviews
Number
Title
Revision
2017-1436
Installation/Removal of Temporary Installation Main
Steam Tunnel
2017-1753
RWCU HX Room FAC Piping Replacement
2017-1800
RF-19 Refuel Floor Outage Activities
2018-1327
Separator Repair Following SHZAM Bolt
Disengagement
71124.04 - Occupational Dose Assessment
Audits and Self-Assessments
Number
Title
Date
LO-RBS-2017-00055 Pre-NRC Assessment IP71124.04
Occupational Dose
October 27, 2017
Condition Reports (CR-RBS-)
2016-05858
2017-08105
2017-00707
2017-00868
2017-00910
2017-03788
2017-05176
2017-05489
Miscellaneous
Number
Title
Date
2017
Multi-Pack TLD Results
2017
2018
NVLAP Accreditation Report
2018
Procedures
Number
Title
Revision
Air Sampling
Dosimetry Administration
Personnel Monitoring
Dose Assessment
Special Monitoring Requirements
Prenatal Monitoring
Dosimeter of Legal Record QA
Whole Body Counting / In-Vitro Bioassay
Procedures
Number
Title
Revision
Electronic Alarming Dosimeter
EN-RP-317-09
Electronic Alarming Dosimeter Calibration
Self-Reading Dosimeter Calibration Records
Number
Title
Date
2017-B2-28-
CALDAT-05667
Self-Reading Dosimeter
September 18, 2017
2017-B2-28-
CALDAT-05713
Self-Reading Dosimeter
September 30, 2017
2017-B2-28-
CALDAT-05736
Self-Reading Dosimeter
September 30, 2017
2017-B2-28-
CALDAT-05836
Self-Reading Dosimeter
September 26, 2017
2017-B2-28-
CALDAT-06692
Self-Reading Dosimeter
December 15, 2017
71151 - Performance Indicator Verification
Procedures
Number
Title
Revision
Performance Indicator Process
Regulatory Assessment Performance Indicator
Guideline
71152 - Problem Identification and Resolution
Condition Reports (CR-RBS-)
2017-06118
2017-04961
71153 - Follow-up of Events and Notices of Enforcement Discretion
Condition Report (CR-RBS-)
2017-06118
Miscellaneous
Number
Title
Revision
PIE-411
Part Interchangeability Evaluation 411
Procedure
Number
Title
Revision
Conduct of Maintenance
The following items are requested for the
Occupational Radiation Safety Inspection
at River Bend Station
January 22-25, 2018
Integrated Report 2018001
Inspection areas are listed in the attachments below.
Please provide the requested information on or before January 12, 2018.
Please submit this information using the same lettering system as below. For example, all
contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled
1-A, applicable organization charts in file/folder 1-B, etc.
If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at
least 30 days later than the onsite inspection dates, so the inspectors will have access to the
information while writing the report.
In addition to the corrective action document lists provided for each inspection procedure listed
below, please provide updated lists of corrective action documents at the entrance meeting.
The dates for these lists should range from the end dates of the original lists to the day of the
entrance meeting.
If more than one inspection procedure is to be conducted and the information requests appear
to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which
file the information can be found.
If you have any questions or comments, please contact Louis Carson at (817) 200-1221 or
Louis.Carson@nrc.gov.
PAPERWORK REDUCTION ACT STATEMENT
This letter does not contain new or amended information collection requirements subject
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
collection requirements were approved by the Office of Management and Budget,
control number 3150-0011.
2.
Occupational ALARA Planning and Controls (71124.02)
Date of last inspection:
January 21, 2016
A.
List of contacts and telephone numbers for ALARA program personnel
B.
Applicable organization charts
C.
Copies of audits, self-assessments, and LERs, written since date of last inspection,
focusing on ALARA
D.
Procedure index for ALARA Program
E.
Please provide specific procedures related to the following areas noted below.
Additional specific procedures may be requested by number after the inspector reviews
the procedure indexes.
1. ALARA Program
2. ALARA Committee
3. Radiation Work Permit (RWP) Preparation
F.
A summary list of corrective action documents (including corporate and sub-tiered
systems) written since date of last inspection, related to the ALARA program. In addition
to ALARA, the summary should also address RWP violations, electronic dosimeter
alarms, and RWP dose estimates
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that
the inspector can perform word searches.
G.
List of work activities greater than 1 rem, since date of last inspection,
Include original dose estimate and actual dose.
H.
Site dose totals and 3-year rolling averages for the past 3 years (based on dose of
record)
I.
Outline of source term reduction strategy
J.
If available, provide a copy of the ALARA outage report for the most recently completed
outages for each unit
K.
Please provide your most recent Annual ALARA Report.
4. Occupational Dose Assessment (Inspection Procedure 71124.04)
Date of Last Inspection:
January 21, 2016
A.
List of contacts and telephone numbers for the following areas:
1. Dose Assessment personnel
B.
Applicable organization charts
C.
Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs
written since date of last inspection, related to:
1. Occupational Dose Assessment
D.
Procedure indexes for the following areas:
1. Occupational Dose Assessment
E.
Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures will be requested by number after the inspector reviews
the procedure indexes.
1. Radiation Protection Program
2. Radiation Protection Conduct of Operations
3. Personnel Dosimetry Program
4. Radiological Posting and Warning Devices
5. Air Sample Analysis
6. Performance of High Exposure Work
7. Declared Pregnant Worker
8. Bioassay Program
F.
List of corrective action documents (including corporate and sub-tiered systems) written
since date of last inspection, associated with:
1. National Voluntary Laboratory Accreditation Program (NVLAP)
2. Dosimetry (TLD/OSL, etc.) problems
3. Electronic alarming dosimeters
4. Bioassays or internally deposited radionuclides or internal dose
5. Neutron dose
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that
the inspector can perform word searches.
G.
List of positive whole body counts since date of last inspection, names redacted if
desired
H.
Part 61 analyses/scaling factors
I.
The most recent National Voluntary Laboratory Accreditation Program (NVLAP)
accreditation report or, if dosimetry is provided by a vendor, the vendors most recent
results
SUNSI Review:
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: CHY/rdr
Yes No
Publicly Available
Sensitive
OFFICE
SRI:DRP/C
RI:DRP/C
ARI:DRP/C
SPE:DRP/C
C:DRS/EB1
C:DRS/EB2
NAME
JSowa
BParks
MOBanion
CYoung
TFarnholtz
JDrake
SIGNATURE
/RA/
/RA/
/RA-E/
/RA/
/RA/
/RA/
DATE
4/23/18
4/30/18
4/24/18
4/27/18
4/23/18
4/23/18
OFFICE
C:DRS/OB
C:DRS/PSB2
TL:IPAT
BC:DRP/C
NAME
VGaddy
HGepford
GGeorge
JKozal
SIGNATURE
/RA/
/RA/
/RA/
/RA/
DATE
4/14/18
4/23/18
4/24/18
5/08/18