05000416/FIN-2015301-01

Finding

Title

Inadequate Plant Operating Procedures with Eight Examples

Description

Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Contrary to this, The licensees Off-Normal Procedure ONEP 05-1-02-I-1, Reactor Scram, Revision 125, does not provide all necessary guidance on how to scram the reactor. Once the immediate action of placing the mode switch in the shutdown position is completed, all additional guidance for shutting down the reactor using alternate methods is contained in EP-2A. However, the first backup method of using the scram pushbuttons is missing from both of these procedures. This procedure deficiency was entered into the licensees corrective action program as Condition Report CR-GGN-2015-07209. The licensee is missing several off-normal procedures that are required by Technical Specifications based on commitments to NRC Regulatory Guide 1.33, Revision 2. Specifically, there are no off-normal procedures for 1) a total or partial loss of DC power, 2) electrical grounds, and 3) partial or total loss of all annunciators. The licensee is committed to revision 2 of this regulatory guide in its Technical Specifications. These procedure deficiencies were entered into the licensees corrective action program as Condition Report CR-GGN-2015-07209. The licensees Emergency Procedure 05-1-02-II-1, Attachment III, Shutdown from the Remote Shutdown Panel, Revision 47, does not include all of the required steps to complete the attachment. Step 3.2.5a of this procedure requires an operator to obtain one key while two keys are actually required to complete the task. One key is required to open the protective box covering the switch and a different key is required to operate the switch. This procedure discrepancy led to delays and confusion during examination administration by applicants and during examination validation by licensed operators. This procedure deficiency was entered into the licensees corrective action program as Condition Report CR-GGN-2015-07209. The licensees Emergency Procedure 05-S-1-EP-1, Attachment 6, Defeating Reactor Feed Pumps RPV Level 9 Trips, Revision 32, contains labeling discrepancies in that the relay nomenclature in the procedure does not match the nomenclature in the main control room cabinet 1H13-P612 Bay B. This caused confusion among both the applicants and licensed operators. The confusion delayed the completion of the task administered during the examination. This procedure deficiency was entered into the licensees corrective action program as Condition Report CR-GGN-2015-07209. The licensees System Operating Instruction 04-1-01-P41-1, Standby Service Water System, Revision 140, Section 4.2, contains labeling discrepancies in that the control board labeling for several switches do not match the nomenclature listed in the procedure for the associated switches. Specifically, steps 4.2.2A(4)(a), 4.2.2A(4)(b), and 4.2.2A(6) each have a discrepancy. This procedure deficiency was entered into the licensees corrective action program as Condition Report CR-GGN-2015-07209. The licensees Alarm Response Instruction 04-02-1H13-P870-2A-E1, Revision 134, for the residual heat removal (RHR) alarm RHR A PMP RM FLOODED contains non-conservative guidance to close the suction valve (valve 1E12-F004A) for RHR pump A without regard to ensuring that the pump is secured first. This creates a condition where the safety-related residual heat removal pump is tripped on interlock only in order to prevent damage. The expectation provided to the NRC by the operations staff is that the operators should first trip the residual heat removal pump and then shut the suction valve. This procedure deficiency was entered into the licensees corrective action program as Condition Report CR-GGN-2015-07209. The licensee was unable to locate any written guidance for placing a safetyrelated diesel generator in maintenance mode to prevent automatic start and subsequent overheat of the machine when cooling water is unavailable. According to the Updated Final Safety Analysis Report, Section 9.5, Revision LDC 05077, the diesel generator jacket cooling water system provides sufficient heat sink to permit the standby diesel engines to start and operate for 2 minutes without cooling water available. Procedures that were reviewed included SOI 04-1-01-P75-1, SOI 04-1-01-Y47, and ONEP 05-1-02-I-4. An additional NRC concern for this sequence is that there is no time critical action associated with securing these diesel generators when cooling water (standby service water) is not available. The licensee needs to review the risk management program and ensure that this is not assumed in the risk management profile or if it is assumed, then operators are trained and can implement the shutdown in the appropriate time to prevent equipment damage. This procedure deficiency was entered into the licensees corrective action program as Condition Report CR-GGN-2015-07209. The licensees Equipment Performance Instruction 04-1-03D21-1, Monthly Area Radiation Monitors Functional Test, Revision 37, has confusing guidance which led several applicants in not being able to complete the task administered during the NRC initial license examination. Specifically the procedure has a limit and precaution stating that not all ARM module function switches spring return to OPERATE after being taken to ALARM. Some must be manually returned to OPERATE after being taken to ALARM while the specific steps in the procedure have the operator place and hold function switch in alarm and then release. No guidance is given within the step to return the switch to operate and this creates a situation where the observation of indication returning to normal does not occur. A precaution in the front matter in the procedure stating that the equipment may not function as the procedure is written is not sufficient to meet the quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. This procedure deficiency was entered into the licensees corrective action program as Condition Report CR-GGN-2015-07209. The failure of these eight procedures to have the appropriate qualitative and/or quantitative criteria to complete these activities was a performance deficiency. The finding was more than minor because it is associated with the procedure quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring availability, reliability, and capability of systems needed to respond to initiating events to prevent undesired consequences. Specifically, inadequate procedures could adversely affect the operating crews ability to take appropriate actions to ensure reactor safety is being maintained. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings AtPower, dated June 19, 2012, the team determined that the finding was of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The finding has a cross-cutting aspect in the area of human performance associated with procedure adherence because individuals did not follow the processes to change or correct procedures that contained incorrect, missing, or non-conservative guidance [H.8].

01
Site:	Grand Gulf
Report	IR 05000416/2015301 Section 4OA5
Date counted	Dec 31, 2015 (2015Q4)
Type:	NCV: Green
cornerstone	Mitigating Systems
Identified by:	NRC identified
Inspection Procedure:	IP 71150
Inspectors (proximate)	J Drake K Clayton M Kennard S Hedger V Gaddy
Violation of:	10 CFR 50 Appendix B Criterion V Technical Specification Technical Specification - Procedures
CCA	H.8, Procedure Adherence
INPO aspect	WP.4
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v • d • e

Finding - Grand Gulf - IR 05000416/2015301

1(6)2(5)3(1)4(6)5(0)6(0)7(11)8(4)201(6)301(1)402(0)403(0)404(3)405(4)406(1)501(0)

IR 05000416/2015301: 1

Finding List (Grand Gulf) @ 2015Q4

CCA Matrix: 2015Q4

	Q	CCA	Title
05000416/FIN-2015001-02	2015Q1	H.12	Failure to Follow a Procedure Resulting in the Unplanned Inoperability of the Reactor Core Isolation Cooling System
05000416/FIN-2015001-05	2015Q1	H.8	Failure to Establish, Implement, and Maintain Appropriate Changes to the Offsite Dose Calculation Manual For REMP Airborne Sampling
05000416/FIN-2015001-04	2015Q1	H.1	Failure to Properly Calibrate Main Steam Line Radiation Monitors and Containment/Drywall High Range Radiation Monitors
05000416/FIN-2015001-03	2015Q1	P.2	Emergency Action Level Scheme for Nonfunctional Seismic Monitor
05000416/FIN-2015201-06	2015Q1		Security
05000416/FIN-2015201-05	2015Q1		Security
05000416/FIN-2015201-04	2015Q1		Security
05000416/FIN-2015201-03	2015Q1		Security
05000416/FIN-2015201-02	2015Q1		Security
05000416/FIN-2015201-01	2015Q1		Security
05000416/FIN-2015001-01	2015Q1		Failure to Take Timely Corrective Actions Associated with Division 1 and 2 Standby Service Water Pump House Ventilation System Due to Degraded Relays
05000416/FIN-2015001-06	2015Q1		Failure to Adequately Establish Commercial-Grade Items as Basic Components
05000416/FIN-2015002-03	2015Q2		Failure to the Update the Final Safety Analysis Report after the Extended Power Uprate
05000416/FIN-2015002-04	2015Q2		Possible Loss of Communications Systems during Control Room Fire Scenarios
05000416/FIN-2015002-01	2015Q2	H.12	Failure to Have Appropriate Instructions Resulted in the Unplanned Unavailability of the Reactor Core Isolation Cooling System
05000416/FIN-2015002-02	2015Q2	H.12	Failure to Identify High Vibration on the Division 3 EDG Soak Back Oil Pump
05000416/FIN-2015405-01	2015Q3		Security
05000416/FIN-2015003-01	2015Q3		Failure to Have Appropriate Instructions for Preventative Maintenance on the Division II Diesel Generator Fuel Rack Control Lever
05000416/FIN-2015007-05	2015Q4		Failure to Maintain a Safety-Related Cable Tray Overfill Analysis Record
05000416/FIN-2015007-02	2015Q4	H.6	Failure to Ensure that Electrical Interrupting Devices are Rated for Available Fault Current Levels
05000416/FIN-2015004-03	2015Q4		Failure to Make a Required Eight-Hour Report for Loss of Safety Function
05000416/FIN-2015007-07	2015Q4		Failure to Update the Final Safety Analysis Report
05000416/FIN-2015008-03	2015Q4	H.12	Failure to Declare Secondary Containment Inoperable Based on Failed Surveillance Testing
05000416/FIN-2015404-03	2015Q4		Security
05000416/FIN-2015404-02	2015Q4		Security
05000416/FIN-2015404-01	2015Q4		Security
05000416/FIN-2015007-08	2015Q4		Incomplete and Inaccurate Response to NRC Bulletin 88-04
05000416/FIN-2015008-04	2015Q4		Failure to Make Required Event Notification
05000416/FIN-2015007-03	2015Q4	S.4(o)	Lack of Coordination of Division III HPCS Switchgear 127N Undervoltage Relays
05000416/FIN-2015007-01	2015Q4		Failure to Ensure Safety-Related Alternating Current and Direct Current Equipment Operability and Functionality at Maximum Allowable Voltage Levels
05000416/FIN-2015008-01	2015Q4	P.1	Failure to Enter a Condition Adverse to Quality into the Corrective Action Program
05000416/FIN-2015007-04	2015Q4	H.8	Failure to Identify and Address Impacts of Revised Calculation Output Data
05000416/FIN-2015007-06	2015Q4		Failure to Perform Surveillance Requirement 3.8.1.9
05000416/FIN-2015007-09	2015Q4		Failure to Obtain a License Amendment for Use of Probabilistic Methods to Evaluate Tornado Missile Hazards
05000416/FIN-2015007-10	2015Q4	P.6	Failure to Ensure Equipment Operability and Functionality of Allowable Alternating Current Frequency Range
05000416/FIN-2015007-11	2015Q4	H.12	Failure to Implement Equipment Control Procedures for Loose Items in Containment
05000416/FIN-2015004-04	2015Q4		Failure to Establish Adequate Maintenance Instructions to Perform Work Activities on the Division III Diesel Generator Overspeed Trip Limit Switch
05000416/FIN-2015004-02	2015Q4	H.14	Failure to Timely Enter Technical Specification Surveillance Requirement 3.0.1
05000416/FIN-2015004-01	2015Q4	H.6	Failure to Have Appropriate Instructions for Preventative Maintenance on the Division I Diesel Generator Simulated Run
05000416/FIN-2015301-01	2015Q4	H.8	Inadequate Plant Operating Procedures with Eight Examples
05000416/FIN-2015008-02	2015Q4	P.1	Failure to Promptly Initiate Condition Reports

Self-Identified List (Grand Gulf)

	Q	Title
05000416/FIN-2015002-05	2015Q2	Licensee-Identified Violation
05000416/FIN-2015405-02	2015Q3	Licensee-Identified Violation
05000416/FIN-2015405-03	2015Q3	Licensee-Identified Violation
05000416/FIN-2015405-04	2015Q3	Licensee-Identified Violation
05000416/FIN-2015406-01	2015Q3	Security
05000416/FIN-2015004-05	2015Q4	Licensee-Identified Violation
05000416/FIN-2015004-06	2015Q4	Licensee-Identified Violation

[Grand Gulf Findings full list]

05000416/FIN-2015301-01

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