RBG-47615, Reply to a Notice of Violation; EA-15-043
| ML15280A008 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 09/25/2015 |
| From: | Clark J Entergy Operations |
| To: | Document Control Desk, NRC Region 1 |
| References | |
| EA-15-043, RBF1-15-0153, RBG-47615S | |
| Download: ML15280A008 (8) | |
Text
Entergy Operations, Inc.
SEntergy-- River Bend Station 5485 U.S. Highway 61 N St. Francisv!ile, LA 70775 Tel 225-381-4177 Joseph A. Clark Manager-Licensing September 25, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 RBG-47615S RBFI 0153
Subject:
Reply to a Notice of Violation; EA-15-043 River Bend Station - Unit 1 Docket No. 50-458 License No. NPF-47
Reference:
Letter, Marc L. Dapas to EricforW.a White Olson, Finding "River Bend Stationof- Violation; Final Significance Determination and Notice NRC Special Inspection Report 05000458/2015009" dated September 10, 2015 Entergy Operations, Inc. (Entergy) is providing a Reply to a Notice of Violation (NOV), EA-15-043, pursuant to the provisions of 10 CFR 2.201. The NOV resulted from a Special Inspection conducted January 26 through June 29, 2015. Entergy has reviewed Inspection Report (IR) 201 5-009 and prepared a reply which is included in Attachment 1 to this letter.
Commitments in this letter are summarized in Attachment 2.
Should you have any _quetiop* regqarding this reply, please contact me at (225) 381-4177.
w Attachments:
- 1) Reply to a Notice of Violation: EA-1 5-043, Inspection Report 05000458/2015009
- 2) List of Commitments
-<lE,
Reply to Notice of Violation: EA-15-043 RBG-4761 5 Page 2 of 2 cc: Marc L. Dapas Regional Administrator U.S. Nuclear Regulatory Commission Region IV 1600 E. Lamar Blvd.
Arlington, TX 76011-4511 NRC Resident Inspector P0 Box 1050 St. Francisville, LA 70775 Ms. Tradie Lowrey Public Utility Commission of Texas 1701 N. Congress Ave.
Austin, TX 78711-3326 Mr. Alan Wang, Project Manager U.S. Nuclear Regulatory Commission MS O-8B1 11555 Rockville Pike Rockville, MD 20852-2738
Attachment 1 RBG-4761 5 Reply to a Notice of Violation: EA-15-043, Inspection Report 05000458/2015009
Attachment 1 Reply to a Notice Inspection of Violation:
Report EA-15-043, 05000458/2015009 Statement of Violation 10 CFR Part 55.46(c)(1), "Plant-Referenced Simulators," requires, in part, that a simulator
"...must demonstrate expected plant response to operator input and to normal, transient, and accident conditions to which the simulator has been designed to respond."
Contrary to the above, as of January 30, 2015, the simulator failed to demonstrate expected plant response to operator input and to normal, transient, and accident conditions to which the simulator has been designed to respond. Specifically, the River Bend Station's simulator failed to correctly model leakage flow rates across the feedwater regulating valves; failed to provide the correct alarm response for a loss of a reactor protection system motor generator set; and failed to correctly model the behavior of the startup feedwater regulating valve controller. These simulator modeling issues led to negative training of operators. This subsequently complicated the operators' response to a reactor scram in the actual plant on December 25, 2014.
This violation is associated with a White Significance Determination Process finding.
Reasons for the violation Entergy agrees that a performance deficiency exists and has performed a Root Cause Evaluation. The Root Cause shows that there are programmatic gaps in the plant processes to identify and communicate differences between the simulator and the operating characteristics of the reference plant. The root cause resulted from plant equipment issues not being elevated for incorporation into the simulator model. In addition, there was no process for capturing post transient alarms and submitting them to training for evaluation.
This is supported by:
- Failing to recognize, through the Corrective Action Process (CAP), the impact on operator's ability to regulate water level
- No process exists for capturing alarms received during a plant transient and submitting to training for evaluation
- Conditions were not identified as an Operator workaround or burden
- The checklist in Training Policy 97-02, "Training Simulator Configuration Control,"
does not contain a review of the Operator workaround or burden list for impact on Training.
- Removal of ten demineralizers from service resulted in the inability to obtain post SCRAM feedwater level trends which are used during Post Event Simulator Testing (PEST) to validate simulator configuration Corrective steps that have been taken and the results achieved
- 1. Simulator Deficiency Requests were completed to correct the following simulator fidelity issues:
- Feedwater Regulating Valves modeled with no leakage
- Startup Feedwater Regulating valve does not operate the same as it does in the plant (plant has up to an 8-minute delay in opening)
- High drywell pressure and Reactor Pressure Vessel (RPV) High pressure alarms do not actuate on a loss of RPS bus
- 2. Training was developed and administered to the oPerating crews on the changes implemented in the Simulator.
- 3. GOP-0005, "Power Maneuvering" was revised to include actions to freeze Emergency Response Information System (ERIS) / Safety Parameter Display System (SPDS)
Transient Recording and Analysis (TRA) data and collect alarm typer data for Simulator evaluation following a transient.
- 4. Defined "transient" to set boundaries for evaluation to support revision to GOP-0005, "Power Maneuvering".
- 5. Revised OSP-0022, "Operations General Administrative Guidelines" to include guidelines for:
- a. Capturing post transient alarms
- b. Submitting post transient alarms to training for evaluation
- c. Submitting all EN-OP-i117, "Operations Assessment Resources" transient snapshot assessments to Training for evaluation
- 6. Revised Training Policy 97-02, "Training Simulator Configuration Control", to include a review of the Operations Aggregate Index.
- 7. Reviewed Surveillance Test Procedures (STPs) performed during Simulator Annual Operating test for completeness. Based on the review, the following STPs were added:
- a. STP-601 -6301, "RWCU Valve Operability"
- b. STP-000-6304, "Auxiliary Building and Annulus Pressure Control Quarterly Operability" Results were evaluated and approved by the Simulator Review Board.
- 8. Performed a snapshot assessment of equipment issues that could lead to Simulator differences and result in potential negative training. Assessment included licensed operator interviews and a review of the Operation's Aggregate Index.
- 9. Reinforced the requirements for Operation's Senior Reactor Operators to initiate a Training Evaluation Action Request (TEAR) for simulator support to run the transient on the Simulator to evaluate accuracy against real plant response per EN-OP-i117, "Operations Assessment Resources."
The results of these actions are:
- Simulator correctly models plant for identified issues,
- Operators are adequately trained on the changes made to the Simulator, and
- Process is in place for operators to capture transient information for training evaluation.
Corrective steps that will be taken
- 1. Develop case study on the lessons learned for not identifying the Feedwater Regulating Valve seat leakage as an operator workaround. Case study will be presented to the Condition Review Group (CRG) members, all Operations Instructors, and at Supervisor training. Corrective action is due 9/28/1 5.
Date when full compliance will be achieved River Bend is currently in full compliance with the regulations based on the completed corrective actions discussed above. Additional actions are being taken to address the Extent of Condition. These actions will be completed by September 28, 2015.
Attachment 2 RBG-4761 5 List of Commitments
List of Commitments Type (Check one) Scheduled One-Time Continuing Completion Date Commitment Action Compliance (if required)
Develop case study on the lessons learned for not identifying the Feedwater Regulating Valve seat leakage as an operator workaround. Case study will be presented to X 9/28/15 the Condition Review Group (CRG) members, all Operations Instructors, and at Supervisor training.
Entergy Operations, Inc.
SEntergy-- River Bend Station 5485 U.S. Highway 61 N St. Francisv!ile, LA 70775 Tel 225-381-4177 Joseph A. Clark Manager-Licensing September 25, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 RBG-47615S RBFI 0153
Subject:
Reply to a Notice of Violation; EA-15-043 River Bend Station - Unit 1 Docket No. 50-458 License No. NPF-47
Reference:
Letter, Marc L. Dapas to EricforW.a White Olson, Finding "River Bend Stationof- Violation; Final Significance Determination and Notice NRC Special Inspection Report 05000458/2015009" dated September 10, 2015 Entergy Operations, Inc. (Entergy) is providing a Reply to a Notice of Violation (NOV), EA-15-043, pursuant to the provisions of 10 CFR 2.201. The NOV resulted from a Special Inspection conducted January 26 through June 29, 2015. Entergy has reviewed Inspection Report (IR) 201 5-009 and prepared a reply which is included in Attachment 1 to this letter.
Commitments in this letter are summarized in Attachment 2.
Should you have any _quetiop* regqarding this reply, please contact me at (225) 381-4177.
w Attachments:
- 1) Reply to a Notice of Violation: EA-1 5-043, Inspection Report 05000458/2015009
- 2) List of Commitments
-<lE,
Reply to Notice of Violation: EA-15-043 RBG-4761 5 Page 2 of 2 cc: Marc L. Dapas Regional Administrator U.S. Nuclear Regulatory Commission Region IV 1600 E. Lamar Blvd.
Arlington, TX 76011-4511 NRC Resident Inspector P0 Box 1050 St. Francisville, LA 70775 Ms. Tradie Lowrey Public Utility Commission of Texas 1701 N. Congress Ave.
Austin, TX 78711-3326 Mr. Alan Wang, Project Manager U.S. Nuclear Regulatory Commission MS O-8B1 11555 Rockville Pike Rockville, MD 20852-2738
Attachment 1 RBG-4761 5 Reply to a Notice of Violation: EA-15-043, Inspection Report 05000458/2015009
Attachment 1 Reply to a Notice Inspection of Violation:
Report EA-15-043, 05000458/2015009 Statement of Violation 10 CFR Part 55.46(c)(1), "Plant-Referenced Simulators," requires, in part, that a simulator
"...must demonstrate expected plant response to operator input and to normal, transient, and accident conditions to which the simulator has been designed to respond."
Contrary to the above, as of January 30, 2015, the simulator failed to demonstrate expected plant response to operator input and to normal, transient, and accident conditions to which the simulator has been designed to respond. Specifically, the River Bend Station's simulator failed to correctly model leakage flow rates across the feedwater regulating valves; failed to provide the correct alarm response for a loss of a reactor protection system motor generator set; and failed to correctly model the behavior of the startup feedwater regulating valve controller. These simulator modeling issues led to negative training of operators. This subsequently complicated the operators' response to a reactor scram in the actual plant on December 25, 2014.
This violation is associated with a White Significance Determination Process finding.
Reasons for the violation Entergy agrees that a performance deficiency exists and has performed a Root Cause Evaluation. The Root Cause shows that there are programmatic gaps in the plant processes to identify and communicate differences between the simulator and the operating characteristics of the reference plant. The root cause resulted from plant equipment issues not being elevated for incorporation into the simulator model. In addition, there was no process for capturing post transient alarms and submitting them to training for evaluation.
This is supported by:
- Failing to recognize, through the Corrective Action Process (CAP), the impact on operator's ability to regulate water level
- No process exists for capturing alarms received during a plant transient and submitting to training for evaluation
- Conditions were not identified as an Operator workaround or burden
- The checklist in Training Policy 97-02, "Training Simulator Configuration Control,"
does not contain a review of the Operator workaround or burden list for impact on Training.
- Removal of ten demineralizers from service resulted in the inability to obtain post SCRAM feedwater level trends which are used during Post Event Simulator Testing (PEST) to validate simulator configuration Corrective steps that have been taken and the results achieved
- 1. Simulator Deficiency Requests were completed to correct the following simulator fidelity issues:
- Feedwater Regulating Valves modeled with no leakage
- Startup Feedwater Regulating valve does not operate the same as it does in the plant (plant has up to an 8-minute delay in opening)
- High drywell pressure and Reactor Pressure Vessel (RPV) High pressure alarms do not actuate on a loss of RPS bus
- 2. Training was developed and administered to the oPerating crews on the changes implemented in the Simulator.
- 3. GOP-0005, "Power Maneuvering" was revised to include actions to freeze Emergency Response Information System (ERIS) / Safety Parameter Display System (SPDS)
Transient Recording and Analysis (TRA) data and collect alarm typer data for Simulator evaluation following a transient.
- 4. Defined "transient" to set boundaries for evaluation to support revision to GOP-0005, "Power Maneuvering".
- 5. Revised OSP-0022, "Operations General Administrative Guidelines" to include guidelines for:
- a. Capturing post transient alarms
- b. Submitting post transient alarms to training for evaluation
- c. Submitting all EN-OP-i117, "Operations Assessment Resources" transient snapshot assessments to Training for evaluation
- 6. Revised Training Policy 97-02, "Training Simulator Configuration Control", to include a review of the Operations Aggregate Index.
- 7. Reviewed Surveillance Test Procedures (STPs) performed during Simulator Annual Operating test for completeness. Based on the review, the following STPs were added:
- a. STP-601 -6301, "RWCU Valve Operability"
- b. STP-000-6304, "Auxiliary Building and Annulus Pressure Control Quarterly Operability" Results were evaluated and approved by the Simulator Review Board.
- 8. Performed a snapshot assessment of equipment issues that could lead to Simulator differences and result in potential negative training. Assessment included licensed operator interviews and a review of the Operation's Aggregate Index.
- 9. Reinforced the requirements for Operation's Senior Reactor Operators to initiate a Training Evaluation Action Request (TEAR) for simulator support to run the transient on the Simulator to evaluate accuracy against real plant response per EN-OP-i117, "Operations Assessment Resources."
The results of these actions are:
- Simulator correctly models plant for identified issues,
- Operators are adequately trained on the changes made to the Simulator, and
- Process is in place for operators to capture transient information for training evaluation.
Corrective steps that will be taken
- 1. Develop case study on the lessons learned for not identifying the Feedwater Regulating Valve seat leakage as an operator workaround. Case study will be presented to the Condition Review Group (CRG) members, all Operations Instructors, and at Supervisor training. Corrective action is due 9/28/1 5.
Date when full compliance will be achieved River Bend is currently in full compliance with the regulations based on the completed corrective actions discussed above. Additional actions are being taken to address the Extent of Condition. These actions will be completed by September 28, 2015.
Attachment 2 RBG-4761 5 List of Commitments
List of Commitments Type (Check one) Scheduled One-Time Continuing Completion Date Commitment Action Compliance (if required)
Develop case study on the lessons learned for not identifying the Feedwater Regulating Valve seat leakage as an operator workaround. Case study will be presented to X 9/28/15 the Condition Review Group (CRG) members, all Operations Instructors, and at Supervisor training.