IR 05000458/2023004

Integrated Inspection Report 05000458/2023004

ML24025A032
Person / Time
Site:	River Bend
Issue date:	01/30/2024
From:	Jeffrey Josey NRC/RGN-IV/DORS/PBC
To:	Hansett P Entergy Operations
References
IR 2023004
Download: ML24025A032 (14)

Text

January 30, 2024

SUBJECT:

RIVER BEND STATION - INTEGRATED INSPECTION REPORT 05000458/2023004

Dear Phil Hansett:

On December 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at River Bend Station. On January 11, 2024, 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.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Jeffrey E. Josey, Chief Reactor Projects Branch C Division of Operating Reactor Safety Docket No. 05000458 License No. NPF-47

Enclosure:

As stated

Inspection Report

Docket Number: 05000458

License Number: NPF-47

Report Number: 05000458/2023004

Licensee: Entergy Operations, Inc.

Facility: River Bend Station

Location: St. Francisville, Louisiana

Inspection Dates: October 1, 2023, to December 31, 2023

Inspectors: R. Kopriva, Senior Project Engineer N. Okonkwo, Reactor Inspector E. Powell, Resident Inspector C. Wynar, Senior Resident Inspector

Approved By: Jeffrey E. Josey, Chief Reactor Projects Branch C Division of Operating Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at River Bend Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000458/2022010-02 Functional Testing of Fire- 71111.05 Closed rated Dampers

PLANT STATUS

River Bend Station began the inspection period at 100 percent rated thermal power. On October 12, 2023, recirculation pump A tripped, and power was reduced to approximately 64 percent power. On October 12, 2023, power was further reduced to 57 percent of rated thermal power where the unit operated in single-loop operation until October 29, 2023, when the unit was shut down to repair the recirculation pump. The unit remained shut down until November 13, 2023, when the station entered mode 2 and commenced startup procedures. On November 15, 2023, during restart, at approximately 22 percent power, the low frequency motor generator tripped causing the recirculation pump to trip and power to be reduced to approximately 20 percent where the unit operated in single-loop operations until November 18, 2023. On November 18, 2023, after the low frequency motor generator was repaired, power ascension continued, and at approximately 30 percent power a low-pressure feedwater heater string isolated resulting in operators initiating a manual reactor SCRAM. On November 20, 2023, the station entered mode 2 and commenced startup procedures. On November 24, 2023, the unit was at 92 percent power and down powered to 80 percent for a planned rod pattern adjustment and returned to 100 percent power. On November 26, 2023, the unit was at 99 percent power and down powered to 90 percent for a planned rod pattern adjustment and returned to 100 percent power. On December 13, 2023, two disconnect switches in the offsite switchyard failed resulting in a reactor SCRAM. On December 15, 2023, the station entered mode 2 and commenced startup procedures. On December 18, 2023, the unit was at 96 percent power and down powered to 85 percent for a planned rod pattern adjustment and returned to 100 percent power on December 19, 2023, where it remained for the rest of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures on December 29, 2023, for the following systems:

• ventilation unit coolers

• instrument air compressors

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk significant systems from impending severe weather during a tornado warning on November 20, 2023.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) main control room/technical support center ventilation on October 16, 2023

(2) offgas system on November 29, 2023

(3) low pressure core spray system on December 15, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) B tunnel south, fire area ET-2, on October 17, 2023

(2) fire damper unresolved item closeout on October 17, 2023

(3) residual heat removal A, fire area AB-5, on November 30, 2023

(4) division 3 emergency diesel generator, fire area DG-5/Z-1, on November 30, 2023

(5) diesel driven fire pump 1B, fire area FP-3, on November 30, 2023

(6) control room, fire area C-25, on December 20, 2023

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered on October 10, 2023, to December 7, 2023.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a senior reactor operator requalification simulator with multiple abnormal conditions tested on December 8, 2023.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (5 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:

(1) standby liquid control tank level instrument maintenance rule functional failure on November 16, 2023

(2) offgas on December 19, 2023

(3) recirculation loop A on December 28, 2023

(4) 125 Vdc backup battery charger maintenance on December 28, 2023

(5) standby service water functional failure check on December 28, 2023

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) jet pump 17 transmitter replacement on November 1, 2023

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) elevated risk during residual heat removal B shutdown cooling on November 8, 2023

(2) elevated risk during reactor core isolation cooling outage and residual heat removal A oil sample with Fancy Point work in progress on November 30, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) division 3 emergency diesel generator starting air leak on November 29, 2023 (CR-RBS-2023-08600)

(2) low pressure core spray minimum flow valve on December 11, 2023 (CR-RBS-2023-08796)

(3) ultimate heat sink comprehensive measure operability due to fire header seismic qualification on December 18, 2023 (CR-RBS-2023-01249)

(4) residual heat removal B bypass valve MOV-F048 on December 19, 2023 (CR-RBS-2023-08278)

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Engineering Change (EC) 31803, control building chilled water system digital upgrade, on November 17, 2023

(2) Engineering Report (ER) 99-0574, transfer of reactor core isolation cooling governor control panel from AB95 to CB70, on November 17, 2023

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated reactor startup/recirculation pump A trip forced outage activities from October 29, 2023, to November 19, 2023.

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (4 Samples)

(1) work order (WO) 00593537, service water normal supply header A inlet isolation valve SWP-MOV57A repair, on October 18, 2023

(2) WO 54030748, fire header rupture repair, on November 3, 2023

(3) WO 00524056, division 2 main steam isolation leakage control valve E33-MOVF028 replacement, on November 20, 2023

(4) WO 54076677, residual heat removal B heat exchanger shell side bypass valve E12-MOVF048B investigate/repair, on December 13, 2023

Surveillance Testing (IP Section 03.01) (1 Sample)

(1) COP-0044, Configuration Control of Sample Panel Valves, revision 7, on November 22, 2023

Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)

(1) WO 52995517, local leak rate testing E51-MOVF063, on December 18, 2023

Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)

(1) FLEX diesel generators FLX-EG2 and FLX-EG5 test run on October 3,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===

(1) October 1, 2022, through October 31, 2023

MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

(1) July 1, 2022, through June 30, 2023

MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1) July 1, 2022, through June 30, 2023

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)

(1) October 1, 2022, through October 31, 2023

BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)

(1) October 1, 2022, through October 31, 2023

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) failure to initiate flow through residual heat removal B heat exchanger backwash valve E12-F063B (CR-RBS-2023-06044)

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) The inspectors reviewed the licensees corrective action program and other licensee trending programs for potential adverse trends that might be indicative of a more significant safety issue. The inspectors provided an observation in the results section with further details of their review.

71153 - Follow Up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)

(1) The inspectors evaluated an unplanned 30 percent decrease in power and single loop operations resulting from the trip of recirculation pump A and licensee's response on October 12,

INSPECTION RESULTS

Unresolved Item Functional Testing of Fire-rated Dampers 71111.05 (Closed) URI 05000458/2022010-02

Description:

The inspectors opened an unresolved item (URI) (05000458/2022010-02) in inspection report 05000458/2022010 because the requirements for functional testing of fire-rated dampers in the licensees historical licensing basis did not appear to provide reasonable assurance these devices would always remain functional to meet their design basis. The URI is being closed without a performance deficiency as described below:

During the Fire Protection Team Inspection that was completed on November 3, 2022, the team reviewed work orders associated with Technical Requirement Manual (TRM)surveillances for fire-rated assemblies and determined that the licensee performed only visual inspections to assure functionality of some fire dampers that are installed in rated fire barriers. The inspectors opened a URI in inspection report 05000458/2022010 to document an issue of concern in that the licensees licensing basis did not appear to include requirements to provide reasonable assurance these devices would remain functional to meet their design basis.

The team reviewed the surveillance requirements in historical versions of technical specifications, as well as through all available revisions of the TRM after the fire protection program elements were relocated to the TRM. While the TRM specifies functional testing of some fire-rated assemblies, the inspectors learned through interactions with the Office of Nuclear Reactor Regulation (NRR/DRA/APLB) that the TRM has never included a periodic functional testing requirement for fire dampers. Rather, the only periodic check of fire dampers was included in TRM Surveillance Requirement 3.7.9.6.7 which required only a visual inspection of the fire dampers.

The team determined that fire dampers at River Bend Station were installed in accordance with the 1974 Edition of National Fire Protection Association (NFPA) 90A, Air Conditioning and Ventilating Systems, which does not contain any functional testing requirement for fire dampers. Additionally, the River Bend Station fire protection licensing bases safety evaluation report, NUREG-0989, Safety Evaluation Report Related to the Operation of River Bend Station, May 1984, (ML091380411), Section 9.5.1.4, General Plant Guidelines, page-9-40, states that the fire dampers are installed according to the manufacturer's directions. The staff at NRR/DRA/APLB noted that the manufacturers directions for installation do not prescribe periodic functional testing. The manufacturer did prescribe annual testing as part of the provided maintenance instructions, but manufacturers directions for maintenance were not included in the licensing basis. Additionally, the staff at NRR/DRA/APLB noted that NUREG-2191, Volume, 2, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, July 2017, (ML17187A204), Chapter XI.M26, Fire Protection, requires a fire barrier inspection program, including a periodic visual inspection of fire damper assemblies.

The inspectors and the staff at NRR/DRA/APLB noted that while the licensees strategy of conducting visual-only inspections of fire dampers is consistent with the licensing basis, it may not be sufficient to detect degraded conditions which could interfere with fire damper functionality during an event. The inspectors noted that industry guidance exists that suggests the need for periodic functional testing of fire dampers, including:

• Electric Power Research Institute (EPRI) Technical Report 1006756, Fire Protection Equipment Surveillance Optimization and Maintenance Guide, 2003 which provides fire damper inspection and functional testing frequencies, including functional testing of fire dampers every 18-24 months.

• EPRI TR-112170 HVAC Fans and Dampers Maintenance Guide which states that Dampers, which are important for safety operations, system isolation, and area pressurization, are typically tested for timed actuation response. Dampers should be tested for ease of operation.

• NRC generic communications expressing the importance of proper periodic functional testing of fire dampers, including NRC Information Notice 89-52, Potential Fire Damper Operational Problems (ML031180663).

The inspectors noted that the issue was entered into the licensees corrective action program as CR-RBS-2022-06030 to re-examine the stations visual inspection-only approach to rated fire dampers. The licensee subsequently closed CR-RBS-2022-06030 to CR-RBS-2022-06356 with the action to develop new preventive maintenance requirements to perform periodic fire damper functional testing.

The inspectors did not identify any findings or violations of more than minor significance because there was no standard in the license basis that clearly defined the requirement for functional testing of rated fire dampers.

Corrective Action Reference(s): CR-RBS-2022-06030 and CR-RBS-2022-06356

Observation: Deficiencies in Implementing Maintenance Rule 71152S The inspectors observed an adverse trend with the stations implementation of the maintenance rule related to use of improper scoping criteria, monitoring frequency, and not counting a maintenance rule functional failure.

Specifically, the station did not scope emergency operating procedure functions of three service water system valves: SWP-MOV504A/B, SWP-MOV505A/B, and SWP-MOV510A/B.

The station set a threshold of two for the station blackout diesel generator D battery charger, but never tested the full alignment more than twice per year. The station did not count an installed non-environmentally qualified related level instrument for the standby liquid control tank as a maintenance rule functional failure after they received a violation for it in NRC Inspection Report 2023001.

None of the issues rose to more than minor and the resident staff plans to continue to observe and document any changes to this issue.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On January 11, 2024, the inspectors presented the integrated inspection results to Phil Hansett, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures AOP-0029 Severe Weather Operation 047

OSP-0043 Freeze Protection and Temperature Maintenance 048

71111.04 Miscellaneous R-STM-0606 System Training Manual - Offgas System 10

Procedures EIP-2-018 Technical Support Center 39

R-STM-0053 Reactor Recirculation System 15

R-STM-0205 Low Pressure Core Spray (LPCS) 8

SOP-0032 Low Pressure Core Spray 029

SOP-0092 Standard Operating Procedure Offgas System 49

71111.05 Calculations G13.18.12.2-022 River Bend Station - Combustible Loading 09

Fire Plans CB-136-138 River Bend Station Operating Manual Pre-Fire Strategies - 7

Control Room Fire Area C-25

71111.12 Corrective Action CR-RBS- 2023-00149

Documents

Procedures EN-DC-204 Maintenance Rule Scope and Basis 008

EN-DC-205 Maintenance Rule Monitoring 009

EN-MA-101 Conduct of Maintenance 36

SOP-0049 125VDC System 048

Work Orders WO 00596640

WO 00558937 N64-AOVF060 Indicating Dual Position in MCR 05/12/2021

71111.13 Procedures EN-OP-119 Protected Equipment Postings 16

71111.15 Engineering Engineering Seismic Evaluation of Buried Fire Protection Lines and 0

Evaluations Report RBS-CS- HDPE Pipe from Flume to FHY-29 to FHY-10

23-00004

Miscellaneous R-STM-0204 System Training Manual - Residual Heat Removal System 14

Procedures EN-OP-104 Operability Determination Process 19

71111.18 Calculations E-192 Standby Diesel Generator Loading Calculation 10

Drawings N996-0105 Operation and Maintenance Manual for Adaptiview Chiller 0

Control Upgrade

Engineering EC-031803 HVK Chiller Control Digital Upgrade 01

Changes

Procedures AOP-0060 Loss of Control Building Ventilation 19

Inspection Type Designation Description or Title Revision or

Procedure Date

EN-LI-100 Process Applicability Determination 034

RBS-SOP-0066 Control Building HVAC Chilled Water System (SYS #410) 349

Work Orders WO-RBS- Change Package EC31805 Controls Upgrade 0

00304024

71111.24 Corrective Action CR-RBS- 2023-06608, 2023-07854

Documents

Procedures COP-0044 Configuration Control of Sample Panel Valves 7

Work Orders WO 54010164 FLX-EG2 Full Load Test 10/05/2023

WO 54010896 FLX-EG5 Full Load Test 10/05/2023

WO 54076677 Investigate/Repair E12-MOVF048B Abnormal Flow 11/04/2023

Conditions

71152A Procedures EN-LI-102 Corrective Action Program 050

2