River Bend Talking Points to Region IV Alligations

RIVER BEND STATION – NRC SPECIAL INSPECTION REPORT 05000458/2015009; PRELIMINARY WHITE FIND

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River Bend Talking Points to Region IV Allegations

Reactor high level: Issues of not putting corrective action program. Hiding issues from NRC.  A fleet wide tactic with Entergy.

Request a reset of River Bends simulator and simulator fidelity of all Entergy simulator?

“During power ascension following startup, RFP B did not start. The licensee re-racked its associated circuit breaker and successfully started RFP B.”

“The team identified an apparent violation of 10 CFR 55.46(c)(1), “Plant-Referenced Simulators,” for the licensee’s failure to maintain the simulator so it would demonstrate expected plant response to operator input and to normal, transient, and accident conditions to which the simulator has been designed to respond.”

Pilgrim simulator problems and River Bend within a months of each other only discovered in a troublesome plant trip?

Another work around tripping MFP to control level because of leaking FRVs…

*“On several occasions, the team noted that the licensee chose the expedient solution rather than complete an evaluation to determine that corrective actions resolved the deficient condition.”

“Other examples included the licensee’s choice to have operations personnel rack in and out breakers (MFP), and have maintenance personnel manually operate a limit switch, on the makeup and start logic for the RFP C minimum flow valve, when the RFP did not start.”

NRC widely allow a plant to spin out of control in a complex system, eventually leads to a ANO event (dropped stator and flooding problems).

“Only four minutes elapsed from the time of the scram until the time the Level 8 (high) reactor water level isolation signal was reached. Consequently, operations personnel did not have sufficient time to gain control and stabilize reactor vessel level in the required band.”

“However, operations personnel stated that the plant did not respond in a manner consistent with their simulator training.”

*However, operations personnel stated that the plant did not respond in a manner consistent with their simulator training.”

*It looks like operations works for everyone else instead of everyone else working for operations.” Engineering centric instead of operations centric.”  

HB Robinson breaker event:  “The team identified that the licensee’s maintenance programs for Division I, II, III, and non-safety 4160 V and 13.8 kV breakers installed in the plant may not meet the standards recommended by the vendor, corporate, or Electric Power Research Institute (EPRI) guidelines.”

Why so many issues with faulty cards: SFRV in manual and RPS?

The operations staff is amazingly adaptive with not approved work-arounds and degraded components.

If looks to me the staff went to the SFRV because the FRVs were grossly leaking…

“In reviewing the feedwater system data from the December 24, 2014, scram, the licensee estimated 500,000 lbm/hr leaked past the closed FRVs. This represents approximately 3 percent of the full-power feedwater flow and significantly exceeds the design specification for leakage of 135,000-150,000 lbm/hr.

The licensee identified excessive leakage past the FRVs during testing in 1986. At the time of inspection, the licensee could not produce any corrective actions taken to identify or correct leakage past the FRVs. Further, the licensee had not quantified the amount of leakage past the FRVs prior to the December 24, 2014, event and NRC Special Inspection.”

So why isn’t this A COVER-UP: “The team reviewed the history of Level 8 (high) RFP trips and noted that similar issues of concern were raised by the NRC in 2012. Specifically, a Supplemental Inspection, performed in 2012, for a White performance indicator associated with reactor scrams with complications documented the failure to recognize a Level 8 (high) trip as an adverse condition and enter it into the corrective action program. This non-cited violation was documented in NRC Inspection Report 05000458/2012012.”

“The team identified an apparent violation of 10 CFR 55.46(c)(1), “Plant- Referenced Simulators,” for the licensee’s failure to maintain the simulator so it would demonstrate expected plant response to operator input and to normal, transient, and accident conditions to which the simulator has been designed to respond. As of January 30, 2015, the licensee failed to maintain the simulator consistent with actual plant response for normal and transient conditions related to feedwater flows, alarm response, and behavior of the SFRV controller. As a result, operations personnel were challenged in their control of the plant during a reactor scram that occurred on

December 25, 2014.”

“During an investigation into the report at the OSRC (Onsite Safety Review Committee) for the SCRAM on December 25, 2014, that feed regulating valve leakage (FRV) contributed to the Level 8 received reactor vessel, it was determined by analysis that there is sufficient evidence that leakage by the Feedwater Regulating Valves presents a significant challenge to Operations during a scram event.”

Is a single issue, or is it really an intentional or a inability to keep the simulator accurate?  

Work arounds:

• Work Order WO-RBS-00404323: RFP B supply breaker repetitive failures to close potentially reduces the number of feedwater pumps available to operations personnel during a transient following reactor pressure vessel water Level 8 (high). Operations personnel would rack out and then rack the breaker back in until the breaker would function properly. This work order was initiated on February 3, 2015, following discussions with the NRC inspection team.

how long did this go on?

• Work Order WO-RBS-00396449: RFP C minimum flow valve does not stroke fully open which prevents starting the C feed pump. Maintenance personnel would manually operate a limit switch on the valve to make up the start logic for the RFP. This work order was initiated on October 10, 2014.

• Work Order WO-RBS-00346642: leakage past FRVs when closed complicated post-scram reactor water level control. Operations personnel proceduralized the closure of the main feedwater isolation valves to stop the effect of the leakage.

This work order was initiated on March 27, 2013.