This is very troubling. Why did it take a plant spinning wildly out of control to find grossly inappropriate training? Why didn't inspection activities pick this years ago? What else could the agency miss? You notice, nobody gets to ask the agency why this missed this and the NRC be compelled to be honest and fully truthful?
OFFICE OF ENFORCEMENTNOTIFICATION OF SIGNIFICANT ENFORCEMENT ACTIONSubject: ISSUANCE OF FINAL SIGNIFICANCE DETERMINATION AND NOTICE OF VIOLATION
This is to inform the Commission that a Notice of Violation will be issued on or about September10, 2015, to Entergy Operations, Inc. (Entergy) for a violation associated with a White Significance Determination Process finding identified during an inspection of River Bend Station.
This White finding, an issue of low to moderate safety significance, involves the failure to maintain the simulator so it would accurately reproduce the operating characteristics of the facility. Specifically, the River Bend Station simulator failed to accurately model feedwater flow and reactor vessel level response following a scram, failed to provide the correct alarm response for loss of a reactor protection system motor generator set, and failed to correctly model the operation of the startup feedwater regulating valve.
A Notice of Violation is included based on Entergy’s failure to meet 10 CFR Part 55.46(c)(1), “Plant-Referenced Simulators,” which 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.” In accordance with the NRC Enforcement Policy, the NOV is considered an escalated enforcement action because it is associated with a White finding.
Post this special inspection(actually two), they had one additional plant trip. As far as I am concerned, they bungled it again. We will be closely watching them in the future with how they control vessel level on plant trips.
They problem I see is, they need a program like tuning the system up in a new plant start up program. They'd have to start-up and scram a few times...tuning all the system as they go. Then getting a perfect vessel control scram.
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.
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