05000416/LER-2016-003, Regarding Loss of Secondary Containment Safety Function During Routine Roof Inspection

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Regarding Loss of Secondary Containment Safety Function During Routine Roof Inspection
ML16158A106
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 06/06/2016
From: Nadeau J
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2016/00027 LER 16-003-00
Download: ML16158A106 (7)
v • d • e


LER-2016-003, Regarding Loss of Secondary Containment Safety Function During Routine Roof Inspection
Event date:
Report date:
Reporting criterion: 10 CFR 50.73(a)(2)(v), Loss of Safety Function
10 CFR 50.73(a)(2)(i)
10 CFR 50.73(a)(2)(vii), Common Cause Inoperability
10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded
10 CFR 50.73(a)(2)(viii)(A)
10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition
10 CFR 50.73(a)(2)(viii)(B)
10 CFR 50.73(a)(2)(iii)
10 CFR 50.73(a)(2)(ix)(A)
10 CFR 50.73(a)(2)(iv)(A), System Actuation
10 CFR 50.73(a)(2)(x)
10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor
10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat
10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown
10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
4162016003R00 - NRC Website
v • d • e

text

~

~Entergy GNRO-2016/00027 June 6,2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 James Nadeau Manager, Regulatory Assurance Grand Gulf Nuclear Station Tel. (601) 437-2103

SUBJECT:

Dear Sir or Madam:

Licensee Event Report LER 2016-003-00, Loss of Secondary Containment Safety Function During Routine Roof Inspection Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29 Attached is Licensee Event Report LER 2016-003-00, Loss of Secondary Containment Safety Function During Routine Roof Inspection. This report is being submitted in accordance with Title 10 Code of Federal Regulations 50.73(a)(2)(v)(C).

This letter contains no new commitments. If you have any questions or require additional information, please contact James Nadeau at 601-437-2103.

Sincerely, rI~~

JJN/ram

Attachment:

Licensee Event Report (LER) 2016-003-00 cc: see next page

~

~Entergy GNRO-2016/00027 June 6,2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 James Nadeau Manager, Regulatory Assurance Grand Gulf Nuclear Station Tel. (601) 437-2103

SUBJECT:

Dear Sir or Madam:

Licensee Event Report LER 2016-003-00, Loss of Secondary Containment Safety Function During Routine Roof Inspection Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29 Attached is Licensee Event Report LER 2016-003-00, Loss of Secondary Containment Safety Function During Routine Roof Inspection. This report is being submitted in accordance with Title 10 Code of Federal Regulations 50.73(a)(2)(v)(C).

This letter contains no new commitments. If you have any questions or require additional information, please contact James Nadeau at 601-437-2103.

Sincerely, rI~~

JJN/ram

Attachment:

Licensee Event Report (LER) 2016-003-00 cc: see next page

GNRO-2016/00027 Page 2 of 2 U.S. Nuclear Regulatory Commission ATTN: Mr. Jim Kim, NRR/DORL (w/2)

Mail Stop OWFN 8 B1 Rockville, MD 20852-2738 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission ATTN: Marc L. Dapas (w/2)

Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 GNRO-2016/00027 Page 2 of 2 U.S. Nuclear Regulatory Commission ATTN: Mr. Jim Kim, NRR/DORL (w/2)

Mail Stop OWFN 8 B1 Rockville, MD 20852-2738 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission ATTN: Marc L. Dapas (w/2)

Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511

Attachment To GNRO-2016/00027 Licensee Event Report (LER) 2016-003-00 Attachment To GNRO-2016/00027 Licensee Event Report (LER) 2016-003-00

the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

NRC FORM 366 (11-2015)

U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

(See reverse for required number of digits/characters for each block)

APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018

1. FACILITY NAME Grand Gulf Nuclear Station, Unit 1
2. DOCKET NUMBER 05000416 1
3. PAGE 1 OF 4
4. TITLE Loss of Secondary Containment Safety Function During Routine Roof Inspection
5. EVENT DATE
6. LER NUMBER
7. REPORT DATE
8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR I SEQUENTIAL I REV MONTH DAY YEAR FACILITY NAME NUMBER NO.

N/A DOCKET NUMBER 05000 N/A 04 07 2016 FACILITY NAME DOCKET NUMBER 2016 - 003 - 00 06 06 2016 N/A 05000 N/A

9. OPERATING MODE
11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 100%

MODE 1

10. POWER LEVEL D 20.2201(b)

D 20.2203(a)(3)(i)

D 50.73(a)(2)(i)(C)

D 50.73(a)(2)(vii)

D 20.2201(d)

D 20.2203(a)(3)(ii)

D 50.73(a)(2)(ii)(A)

D 50.73(a)(2)(viii)(A)

D 20.2203(a)(1)

D 20.2203(a)(4)

D 50.73(a)(2)(ii)(B)

D 50.73(a)(2)(viii)(B) 1-----------1 D 20.2203(a)(2)(i)

D 50.36(c)(1)(i)(A)

D 50.73(a)(2)(iii)

D 50.73(a)(2)(ix)(A)

D 20.2203(a)(2)(ii)

D 50.36(c)(1)(ii)(A)

D 50.73(a)(2)(iv)(A)

D 50.73(a)(2)(x)

D 20.2203(a)(2)(iii)

D 50.36(c)(2)

D 50.73(a)(2)(v)(A)

D 73.71 (a)(4)

D 20.2203(a)(2)(iv)

D 50.46(a)(3)(ii)

D 50.73(a)(2)(v)(B)

D 73.71 (a)(5)

D 20.2203(a)(2)(v)

D 50.73(a)(2)(i)(A)

~ 50.73(a)(2)(v)(C)

D OTHER D 20.2203(a)(2)(vi)

D 50.73(a)(2)(i)(B)

D 50.73(a)(2)(v)(D)

Specify in Abstract below or in =

2. DOCKET 05000416 YEAR I
3. LER NUMBER SEQUENTIAL NUMBER 2016 - 003 - 00 I REV.

NO.

PLANT CONDITIONS PRIOR TO THE EVENT 100 percent reactor thermal power with no structures, components, or safety systems inoperable at the start of the event or contributing to the event.

DESCRIPTION

On April 7, 2016, while at 100 percent reactor thermal power, members of the Grand Gulf Nuclear Station (GGNS) staff were assigned to perform a routine inspection of the Secondary Containment [NG] roof surfaces and roof drain scuppers and screens. The purpose of this inspection was to verify the materials were in good working order and to identify any condition requiring maintenance/repair. The inspection is performed on a quarterly frequency and has been performed by the same lead individual for the past five years in the same manner. Therefore, it is estimated that the hatch has been inappropriately left open a minimum of 20 times in the past 5 years.

After obtaining permission to start work the personnel proceeded to the roof access hatch, [DR] proceeded through the hatch, and performed the required inspection activities. The inspection requires approximately 30 minutes to complete all of the required tasks.

Access to the roof is obtained via an access hatch that is normally closed and latched.

The hatch can only be opened from inside the building. This required the personnel to leave the hatch open during the time period they were on the roof performing the inspection.

Leaving the hatch open for purposes other than immediate access or egress results in a breach of the Secondary Containment boundary and a loss of safety function for the Secondary Containment boundary. This event occurred on April 7, 2016. The Nuclear Regulatory Commission Senior Resident Inspector questioned the acceptability of leaving the hatch in the open position. Members of the GGNS staff, based on the challenges from the Senior Resident Inspector, evaluated the concern and it was determined this event was reportable as a loss of safety function.

REPORTABILITY

A Licensee Event Report is required pursuant to Title 10 Code of Federal Regulations (10 CFR) 50.73(a)(2)(v)(C) for an event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to: (C) control the release of radioactive material. Specifically, the hatch was left open.

Page 2 of 4 NRC FORM (11-2015) 366A U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME Grand Gulf Nuclear Station, Unit 1 NARRATIVE
2. DOCKET 05000416 YEAR I
3. LER NUMBER SEQUENTIAL NUMBER 2016 - 003 - 00 I REV.

NO.

PLANT CONDITIONS PRIOR TO THE EVENT 100 percent reactor thermal power with no structures, components, or safety systems inoperable at the start of the event or contributing to the event.

DESCRIPTION

On April 7, 2016, while at 100 percent reactor thermal power, members of the Grand Gulf Nuclear Station (GGNS) staff were assigned to perform a routine inspection of the Secondary Containment [NG] roof surfaces and roof drain scuppers and screens. The purpose of this inspection was to verify the materials were in good working order and to identify any condition requiring maintenance/repair. The inspection is performed on a quarterly frequency and has been performed by the same lead individual for the past five years in the same manner. Therefore, it is estimated that the hatch has been inappropriately left open a minimum of 20 times in the past 5 years.

After obtaining permission to start work the personnel proceeded to the roof access hatch, [DR] proceeded through the hatch, and performed the required inspection activities. The inspection requires approximately 30 minutes to complete all of the required tasks.

Access to the roof is obtained via an access hatch that is normally closed and latched.

The hatch can only be opened from inside the building. This required the personnel to leave the hatch open during the time period they were on the roof performing the inspection.

Leaving the hatch open for purposes other than immediate access or egress results in a breach of the Secondary Containment boundary and a loss of safety function for the Secondary Containment boundary. This event occurred on April 7, 2016. The Nuclear Regulatory Commission Senior Resident Inspector questioned the acceptability of leaving the hatch in the open position. Members of the GGNS staff, based on the challenges from the Senior Resident Inspector, evaluated the concern and it was determined this event was reportable as a loss of safety function.

REPORTABILITY

A Licensee Event Report is required pursuant to Title 10 Code of Federal Regulations (10 CFR) 50.73(a)(2)(v)(C) for an event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to: (C) control the release of radioactive material. Specifically, the hatch was left open.

NRC FORM (11-2015) 366A U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME Grand Gulf Nuclear Station, Unit 1 NARRATIVE
2. DOCKET 05000416 YEAR I
3. LER NUMBER SEQUENTIAL NUMBER 2016 - 003 - 00 I REV.

NO.

A 10CFR 50.72 notification was not performed because the event was not identified until after compliance was restored.

CAUSE

Direct Cause:

The failure to immediately close the hatch upon completion of egress from Secondary Containment Building.

Apparent Cause:

The failure to establish adequate work instructions to maintain control of the hatch and to ensure Secondary Containment was maintained OPERABLE.

CORRECTIVE ACTIONS

Immediate:

The hatch was closed and Secondary Containment integrity was restored.

Pending Action:

Work instructions for the work orders that require personnel to access/egress the Secondary Containment Roof Hatch will be revised to ensure the correct control of the hatch and maintenance of Secondary Containment OPERABILITY. The work instructions will be revised by June 30, 2016.

SAFETY SIGNIFICANCE

There were no actual nuclear safety consequences or radiological consequences during the event. The time period for which there could have been an unmonitored release during an event was approximately 20 minutes. However, no abnormal event or release occurred during the time of the event, therefore, no radiological consequence occurred.

Page 3 of 4 NRC FORM (11-2015) 366A U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME Grand Gulf Nuclear Station, Unit 1 NARRATIVE
2. DOCKET 05000416 YEAR I
3. LER NUMBER SEQUENTIAL NUMBER 2016 - 003 - 00 I REV.

NO.

A 10CFR 50.72 notification was not performed because the event was not identified until after compliance was restored.

CAUSE

Direct Cause:

The failure to immediately close the hatch upon completion of egress from Secondary Containment Building.

Apparent Cause:

The failure to establish adequate work instructions to maintain control of the hatch and to ensure Secondary Containment was maintained OPERABLE.

CORRECTIVE ACTIONS

Immediate:

The hatch was closed and Secondary Containment integrity was restored.

Pending Action:

Work instructions for the work orders that require personnel to access/egress the Secondary Containment Roof Hatch will be revised to ensure the correct control of the hatch and maintenance of Secondary Containment OPERABILITY. The work instructions will be revised by June 30, 2016.

SAFETY SIGNIFICANCE

There were no actual nuclear safety consequences or radiological consequences during the event. The time period for which there could have been an unmonitored release during an event was approximately 20 minutes. However, no abnormal event or release occurred during the time of the event, therefore, no radiological consequence occurred.

NRC FORM (11-2015) 366A U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME Grand Gulf Nuclear Station, Unit 1 NARRATIVE

PREVIOUS SIMILAR EVENTS

2. DOCKET 05000416 YEAR I
3. LER NUMBER SEQUENTIAL NUMBER 2016 - 003 - 00 I REV.

NO.

LER 2015-002-00, Loss of Secondary Containment Differential Pressure during Drawdown Test LER 2015-003-00, Technical Specification Surveillance on Primary Containment Isolation Valves LER 2016-001-00, Engineered Safety Feature Actuation and Temporary Loss of Residual Heat Removal Entergy has reviewed the above identified licensee event reports and has concluded that the causes and corrective actions associated with these licensee event reports could not have prevented the occurrence of the event documented in this licensee event report.

Page 4 of 4 NRC FORM (11-2015) 366A U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME Grand Gulf Nuclear Station, Unit 1 NARRATIVE

PREVIOUS SIMILAR EVENTS

2. DOCKET 05000416 YEAR I
3. LER NUMBER SEQUENTIAL NUMBER 2016 - 003 - 00 I REV.

NO.

LER 2015-002-00, Loss of Secondary Containment Differential Pressure during Drawdown Test LER 2015-003-00, Technical Specification Surveillance on Primary Containment Isolation Valves LER 2016-001-00, Engineered Safety Feature Actuation and Temporary Loss of Residual Heat Removal Entergy has reviewed the above identified licensee event reports and has concluded that the causes and corrective actions associated with these licensee event reports could not have prevented the occurrence of the event documented in this licensee event report.

~

~Entergy GNRO-2016/00027 June 6,2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 James Nadeau Manager, Regulatory Assurance Grand Gulf Nuclear Station Tel. (601) 437-2103

SUBJECT:

Dear Sir or Madam:

Licensee Event Report LER 2016-003-00, Loss of Secondary Containment Safety Function During Routine Roof Inspection Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29 Attached is Licensee Event Report LER 2016-003-00, Loss of Secondary Containment Safety Function During Routine Roof Inspection. This report is being submitted in accordance with Title 10 Code of Federal Regulations 50.73(a)(2)(v)(C).

This letter contains no new commitments. If you have any questions or require additional information, please contact James Nadeau at 601-437-2103.

Sincerely, rI~~

JJN/ram

Attachment:

Licensee Event Report (LER) 2016-003-00 cc: see next page

~

~Entergy GNRO-2016/00027 June 6,2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 James Nadeau Manager, Regulatory Assurance Grand Gulf Nuclear Station Tel. (601) 437-2103

SUBJECT:

Dear Sir or Madam:

Licensee Event Report LER 2016-003-00, Loss of Secondary Containment Safety Function During Routine Roof Inspection Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29 Attached is Licensee Event Report LER 2016-003-00, Loss of Secondary Containment Safety Function During Routine Roof Inspection. This report is being submitted in accordance with Title 10 Code of Federal Regulations 50.73(a)(2)(v)(C).

This letter contains no new commitments. If you have any questions or require additional information, please contact James Nadeau at 601-437-2103.

Sincerely, rI~~

JJN/ram

Attachment:

Licensee Event Report (LER) 2016-003-00 cc: see next page

GNRO-2016/00027 Page 2 of 2 U.S. Nuclear Regulatory Commission ATTN: Mr. Jim Kim, NRR/DORL (w/2)

Mail Stop OWFN 8 B1 Rockville, MD 20852-2738 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission ATTN: Marc L. Dapas (w/2)

Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 GNRO-2016/00027 Page 2 of 2 U.S. Nuclear Regulatory Commission ATTN: Mr. Jim Kim, NRR/DORL (w/2)

Mail Stop OWFN 8 B1 Rockville, MD 20852-2738 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission ATTN: Marc L. Dapas (w/2)

Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511

Attachment To GNRO-2016/00027 Licensee Event Report (LER) 2016-003-00 Attachment To GNRO-2016/00027 Licensee Event Report (LER) 2016-003-00

the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

NRC FORM 366 (11-2015)

U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

(See reverse for required number of digits/characters for each block)

APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018

1. FACILITY NAME Grand Gulf Nuclear Station, Unit 1
2. DOCKET NUMBER 05000416 1
3. PAGE 1 OF 4
4. TITLE Loss of Secondary Containment Safety Function During Routine Roof Inspection
5. EVENT DATE
6. LER NUMBER
7. REPORT DATE
8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR I SEQUENTIAL I REV MONTH DAY YEAR FACILITY NAME NUMBER NO.

N/A DOCKET NUMBER 05000 N/A 04 07 2016 FACILITY NAME DOCKET NUMBER 2016 - 003 - 00 06 06 2016 N/A 05000 N/A

9. OPERATING MODE
11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 100%

MODE 1

10. POWER LEVEL D 20.2201(b)

D 20.2203(a)(3)(i)

D 50.73(a)(2)(i)(C)

D 50.73(a)(2)(vii)

D 20.2201(d)

D 20.2203(a)(3)(ii)

D 50.73(a)(2)(ii)(A)

D 50.73(a)(2)(viii)(A)

D 20.2203(a)(1)

D 20.2203(a)(4)

D 50.73(a)(2)(ii)(B)

D 50.73(a)(2)(viii)(B) 1-----------1 D 20.2203(a)(2)(i)

D 50.36(c)(1)(i)(A)

D 50.73(a)(2)(iii)

D 50.73(a)(2)(ix)(A)

D 20.2203(a)(2)(ii)

D 50.36(c)(1)(ii)(A)

D 50.73(a)(2)(iv)(A)

D 50.73(a)(2)(x)

D 20.2203(a)(2)(iii)

D 50.36(c)(2)

D 50.73(a)(2)(v)(A)

D 73.71 (a)(4)

D 20.2203(a)(2)(iv)

D 50.46(a)(3)(ii)

D 50.73(a)(2)(v)(B)

D 73.71 (a)(5)

D 20.2203(a)(2)(v)

D 50.73(a)(2)(i)(A)

~ 50.73(a)(2)(v)(C)

D OTHER D 20.2203(a)(2)(vi)

D 50.73(a)(2)(i)(B)

D 50.73(a)(2)(v)(D)

Specify in Abstract below or in

2. DOCKET 05000416 YEAR I
3. LER NUMBER SEQUENTIAL NUMBER 2016 - 003 - 00 I REV.

NO.

PLANT CONDITIONS PRIOR TO THE EVENT 100 percent reactor thermal power with no structures, components, or safety systems inoperable at the start of the event or contributing to the event.

DESCRIPTION

On April 7, 2016, while at 100 percent reactor thermal power, members of the Grand Gulf Nuclear Station (GGNS) staff were assigned to perform a routine inspection of the Secondary Containment [NG] roof surfaces and roof drain scuppers and screens. The purpose of this inspection was to verify the materials were in good working order and to identify any condition requiring maintenance/repair. The inspection is performed on a quarterly frequency and has been performed by the same lead individual for the past five years in the same manner. Therefore, it is estimated that the hatch has been inappropriately left open a minimum of 20 times in the past 5 years.

After obtaining permission to start work the personnel proceeded to the roof access hatch, [DR] proceeded through the hatch, and performed the required inspection activities. The inspection requires approximately 30 minutes to complete all of the required tasks.

Access to the roof is obtained via an access hatch that is normally closed and latched.

The hatch can only be opened from inside the building. This required the personnel to leave the hatch open during the time period they were on the roof performing the inspection.

Leaving the hatch open for purposes other than immediate access or egress results in a breach of the Secondary Containment boundary and a loss of safety function for the Secondary Containment boundary. This event occurred on April 7, 2016. The Nuclear Regulatory Commission Senior Resident Inspector questioned the acceptability of leaving the hatch in the open position. Members of the GGNS staff, based on the challenges from the Senior Resident Inspector, evaluated the concern and it was determined this event was reportable as a loss of safety function.

REPORTABILITY

A Licensee Event Report is required pursuant to Title 10 Code of Federal Regulations (10 CFR) 50.73(a)(2)(v)(C) for an event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to: (C) control the release of radioactive material. Specifically, the hatch was left open.

Page 2 of 4 NRC FORM (11-2015) 366A U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME Grand Gulf Nuclear Station, Unit 1 NARRATIVE
2. DOCKET 05000416 YEAR I
3. LER NUMBER SEQUENTIAL NUMBER 2016 - 003 - 00 I REV.

NO.

PLANT CONDITIONS PRIOR TO THE EVENT 100 percent reactor thermal power with no structures, components, or safety systems inoperable at the start of the event or contributing to the event.

DESCRIPTION

On April 7, 2016, while at 100 percent reactor thermal power, members of the Grand Gulf Nuclear Station (GGNS) staff were assigned to perform a routine inspection of the Secondary Containment [NG] roof surfaces and roof drain scuppers and screens. The purpose of this inspection was to verify the materials were in good working order and to identify any condition requiring maintenance/repair. The inspection is performed on a quarterly frequency and has been performed by the same lead individual for the past five years in the same manner. Therefore, it is estimated that the hatch has been inappropriately left open a minimum of 20 times in the past 5 years.

After obtaining permission to start work the personnel proceeded to the roof access hatch, [DR] proceeded through the hatch, and performed the required inspection activities. The inspection requires approximately 30 minutes to complete all of the required tasks.

Access to the roof is obtained via an access hatch that is normally closed and latched.

The hatch can only be opened from inside the building. This required the personnel to leave the hatch open during the time period they were on the roof performing the inspection.

Leaving the hatch open for purposes other than immediate access or egress results in a breach of the Secondary Containment boundary and a loss of safety function for the Secondary Containment boundary. This event occurred on April 7, 2016. The Nuclear Regulatory Commission Senior Resident Inspector questioned the acceptability of leaving the hatch in the open position. Members of the GGNS staff, based on the challenges from the Senior Resident Inspector, evaluated the concern and it was determined this event was reportable as a loss of safety function.

REPORTABILITY

A Licensee Event Report is required pursuant to Title 10 Code of Federal Regulations (10 CFR) 50.73(a)(2)(v)(C) for an event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to: (C) control the release of radioactive material. Specifically, the hatch was left open.

NRC FORM (11-2015) 366A U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME Grand Gulf Nuclear Station, Unit 1 NARRATIVE
2. DOCKET 05000416 YEAR I
3. LER NUMBER SEQUENTIAL NUMBER 2016 - 003 - 00 I REV.

NO.

A 10CFR 50.72 notification was not performed because the event was not identified until after compliance was restored.

CAUSE

Direct Cause:

The failure to immediately close the hatch upon completion of egress from Secondary Containment Building.

Apparent Cause:

The failure to establish adequate work instructions to maintain control of the hatch and to ensure Secondary Containment was maintained OPERABLE.

CORRECTIVE ACTIONS

Immediate:

The hatch was closed and Secondary Containment integrity was restored.

Pending Action:

Work instructions for the work orders that require personnel to access/egress the Secondary Containment Roof Hatch will be revised to ensure the correct control of the hatch and maintenance of Secondary Containment OPERABILITY. The work instructions will be revised by June 30, 2016.

SAFETY SIGNIFICANCE

There were no actual nuclear safety consequences or radiological consequences during the event. The time period for which there could have been an unmonitored release during an event was approximately 20 minutes. However, no abnormal event or release occurred during the time of the event, therefore, no radiological consequence occurred.

Page 3 of 4 NRC FORM (11-2015) 366A U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME Grand Gulf Nuclear Station, Unit 1 NARRATIVE
2. DOCKET 05000416 YEAR I
3. LER NUMBER SEQUENTIAL NUMBER 2016 - 003 - 00 I REV.

NO.

A 10CFR 50.72 notification was not performed because the event was not identified until after compliance was restored.

CAUSE

Direct Cause:

The failure to immediately close the hatch upon completion of egress from Secondary Containment Building.

Apparent Cause:

The failure to establish adequate work instructions to maintain control of the hatch and to ensure Secondary Containment was maintained OPERABLE.

CORRECTIVE ACTIONS

Immediate:

The hatch was closed and Secondary Containment integrity was restored.

Pending Action:

Work instructions for the work orders that require personnel to access/egress the Secondary Containment Roof Hatch will be revised to ensure the correct control of the hatch and maintenance of Secondary Containment OPERABILITY. The work instructions will be revised by June 30, 2016.

SAFETY SIGNIFICANCE

There were no actual nuclear safety consequences or radiological consequences during the event. The time period for which there could have been an unmonitored release during an event was approximately 20 minutes. However, no abnormal event or release occurred during the time of the event, therefore, no radiological consequence occurred.

NRC FORM (11-2015) 366A U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME Grand Gulf Nuclear Station, Unit 1 NARRATIVE

PREVIOUS SIMILAR EVENTS

2. DOCKET 05000416 YEAR I
3. LER NUMBER SEQUENTIAL NUMBER 2016 - 003 - 00 I REV.

NO.

LER 2015-002-00, Loss of Secondary Containment Differential Pressure during Drawdown Test LER 2015-003-00, Technical Specification Surveillance on Primary Containment Isolation Valves LER 2016-001-00, Engineered Safety Feature Actuation and Temporary Loss of Residual Heat Removal Entergy has reviewed the above identified licensee event reports and has concluded that the causes and corrective actions associated with these licensee event reports could not have prevented the occurrence of the event documented in this licensee event report.

Page 4 of 4 NRC FORM (11-2015) 366A U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

CONTINUATION SHEET APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2018

, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

1. FACILITY NAME Grand Gulf Nuclear Station, Unit 1 NARRATIVE

PREVIOUS SIMILAR EVENTS

2. DOCKET 05000416 YEAR I
3. LER NUMBER SEQUENTIAL NUMBER 2016 - 003 - 00 I REV.

NO.

LER 2015-002-00, Loss of Secondary Containment Differential Pressure during Drawdown Test LER 2015-003-00, Technical Specification Surveillance on Primary Containment Isolation Valves LER 2016-001-00, Engineered Safety Feature Actuation and Temporary Loss of Residual Heat Removal Entergy has reviewed the above identified licensee event reports and has concluded that the causes and corrective actions associated with these licensee event reports could not have prevented the occurrence of the event documented in this licensee event report.

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