IR 05000416/1997018
| ML20199L958 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/25/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20199L899 | List: |
| References | |
| 50-416-97-18, NUDOCS 9712020156 | |
| Download: ML20199L958 (47) | |
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ENCLOSURE 2
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U.S. NUCLEAR REGULATORY COMMISSION REGION IV-
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Docket No.:--
50 4'16 License No.:
NPF 29 Report No.:
50-416/97 18-Licensee:
Entergy Operations, Inc.
Facility:-
Grand Gulf Nuclear Station Location:
Waterloo Road Port Gibson, Mississippi Dates:
August 4 22,-1997 Inspectors:
W. P. Ang, Senior Reactor inspector, Maintenance Branch R. V. Azua, Project Engineor, Project Branch B
,
C. A. Clark, Reactor inspector, Maintenance Branch Approved By:
T. F. Stetka, Acting Chief,2ngineering Branch Division of Reactor Safety ATTACHMENT:
Supplemental Information 971 156 971125 PDR A
K 05000416 G
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2-EXECUTIVE SUMMARY Gaad Gulf Nuclear Station NRC Inspection Report 50-416/97-18 Three NRC Region IV inspectors performed an onsite inspection at the Grand Gulf Nuclear Station during the weeks of August 4-8 and 18-22,1997. The inspectors used NRC Inspection Procedure 40500 to evaluate the licensee's effectiveness in identifying, resolving, and preventing issues that degrade the quality of plant operations or safety.
In addition, one NRC Region IV inspector performed an inspection of maintenance activities during the week of July 28 through August 1,1997, inspection Procedure 62700,
" Maintenance Program implementation," was used to verify that on-line maintenance activities were being conducted in a manner that results in the reliable and safe operation of the plant.
The inspectors determined that Grand Gulf Nuclear Station had a good corrective action program and that conditions that degrade the quality of plant operations were, for the most part, being effectively identified, resolved, and prevented. One significant exception was, the apparent lower level of significance placed by licensee personnel in the identification and resolution of fire protection program deficiencies.
The inspectors determined that Grand Gulf Nuclear Station had a good maintenance program. The inspectors also determined that maintenanen activities were being conducted in an appropriate manner.
Ooerations The inspectors did not identify any material condition deficiencies that had not
already been identified by the licensee in condition reports or other corrective action documents (Section 01.1).
The licensee significantly improved its condition reporting process by issuing a new
procedure in August 1996. The new procedute combincd numerous condition reporting processes into one, f acilitated access to condition report forms and data by incorporating it into an electronic local area network, and eliminated the requirement for supervisory approval for the initiation of a nonconforming condition report (Section 01.1).
The licensee's new condition reporting process resulted in an increase in the number
of condition reports being initiated. The increased open condition report backlog was a subject of licensee management concern; however, the backlog was being tracked and adequately managed (Section C1.2).
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C No operability evaluation had been performed for Condition Report GGCR1996-0179-01 as required by Administrative Procedure 01-S-0310,
"GGNS Condition Report (CR)," Revision O. The licenseo subsequently performed an operability evaluation that determined no other condition report operability evaluations were missed. -This was identified as a noncited violation (Section 01.2).
At least five different condition identification forms 1064800,065685,065779,
065457, and 065938) had been written in the 3-month period prior to the--
inspection regarding spurious fire detector and computer alarms. The' conditions reported had been individually reviewed and corrected, but the cumulative problem was not being reviewed for adequacy of fire detectors, alarms, and computers; adequacy of maintenance of those fire protection equipment; and potential human f actors impact on control room crew responsiveness to spurious fire alarms. This was a weakn3ss of the implementation of the corrective action program for fire protection systems (Section 01.2).
The inspectors reviewed 51 operator aids and 23 operator work arounds. The
operator aids and work arounds had been appropriately evaluated and were being properly controlled (Section O2.1),
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Audits and self assestments of operations and radiation protection were thorough,
in depth, and critical, with very good corrective actions recommended. However, corrective actions in response to audit recommendations for improvement were not being rigorously tracked and controlled (Section 07.1).
A comprehensive fire protection program audit was performed by the licensee in
January and February of 1997. The audit determined that the fire protection program was not being adequately implemented (Section 07.2).
The fire protection audit identified deficiencies in the fire protection system as
described in the Updated Final Safety Analysis Report. These deficiencies were identified as conditions that were outside the design basis of the plant. While these deficiencies were correctedithe failure to report these fire protection program deficiencies was identified as a violation of 10 CFR 50.73 (Section 07.2).
The f ailure to provide compensatory action for an inoperable emergency light,
identified by the fire protection audit, was identified as a violation of the approved fire protection program (Section 07.2).
-The fire protection audit identified a weaknesses in the corrective actions that Grand
Gulf _ Nuclear Station performed to preclude conditions identified during a June 1995 Waterford Generating Station, Unit 3, fire (Section 07 2).
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The offsite safety review committee was performing the activities required by the
technical specifications and implementing procedures (Section 07.3).
The plant safety review committee was performing all activities required by the
technical specifications and implementing procedures. The plant safety review committee meetings that were observed included critical discussions of activities under review (Section 07.4).
The independent safety engineering group was performing the activities required by
the technical specifications and implementing procedures (Section 07.5).
Licensee reviews and corrective actions for operating experience were being
controlled. The industry operating experience review program was managed appropriately (Section 07.6).
The corrective action review board was performing good reviews of identified
conditions and root cause determinations and was assuring good corrective actiorn for significant conditions adverse to quality. A high level of management attention to significant conditions adverse to quality was being provided through management participation in the board activities (Section 07.7).
Condition reports were adequately dispositioned (Section M2.1).
- Maintenance The observed on-line maintenance activities were performed in accordance with
appropriate procedures by knowledgeable personnel (Section M1.2).
There were examples of out-of-date vendor technicalinformation and it' correct
replacement material / parts in the field. The licensee implemented a quality action
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team to inveuigate and resolve these problems (Section M1.2).
Work orders were properly used for the repair and replacement of plant equipment
(Section M2.2).
The backlog of maintenance work orders was being appropriately tracked
(Section M2.3).
Sonie maintenance documents were not detailed, and required a high level of " skill-
of-the-craf t" to complete the identified tasks (Section M3.1).
Reviewed maintenance work order packages were adequately developed for the
identified tasks (Section M3.21.
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-5-Observed maintenance activities were performed in an acceptable manner by
knowledgeable and skilled personnel (Section M4.1).
The licensee assessments were effective in identifying good reco.nmendations for
maintenance; however, the licensee did not appear to be aggressively following up on some recent assessment findings (Section M7.1).
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Report Details
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l. OperatiQDA
Conduct of Operations l
01.1-Condition Reoortina Process a
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insoection Sqoce (405001 The inspectors reviewed the licensee's implementation of its condition reporting process to determine if issues that could degrade the quality of plant operations or t
safety were being appropriately identified. The inspectors reviewed approximately 50 condition reports and approximately 50 condition identifier and work orders, and'
discussed issues with both management and working level personnel. The inspectors performed walkdowns of vario>
'ccessible areas of the plant,' observed equipment condition, and observed work e armance by plant personnel.
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Observations and Findinas Administrative Procedure 01 S-03-10, "GGNS Condition Report (CR)," Revision 0, August 26,1996, specified the licensee's primary process for identifying, evaluating and resolving conditions adverse to quality. The procedure required any individual or
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organization to initiate a condition report whe ever a nonconformance, material nonconformance, or potential reportable event was discovered. This procedure
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required an operations representative to evaluate condition reports documenting a material nonconformance for effect on system or component operability, reportability under 10_ CFR 50.72 and 10 CFR 50.73, or for violation of a license
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condition. The procedure also required that maintenance items and material conditions discovered in installed or removed plant equipment that were not material-i nonconformances be documented on a condition identifier in accordance with Administrative Proceduto 01 S-07-1, " Control of Work on Plant Equipment and Facilities," Revision 31. Procedure 01-S-07-1 required the shif t supervisor to assign L
limiting condition for operation conditions on the condition identifier.
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The inspectors determined, through discussions with the quality programs personnel, that the new procedure and problem identification process was implemented to
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improve the process consolidate _ numerous corrective action recording and tracking
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personnel would report identified problems. The condition report replaced previous material nonconformance report, quality deficiency report, ditcrepant material
- report, incident report, radiological deficiency report, and security deficiency report
. reporting systems.
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The new procedure also provided requirements for documer%g reviews for operability and reportability, classification, determination of cause, corrective action determinatina used on identified cause, corrective action implementation, and actic. verification for closure.
The new procedure allowed the electronic initiation of condition reports by means of a local area network. The manual condition report process and forms were also still available for use. The ability to electronically initiate a condition report allowed better access to condition report forms. The new procedure also eliminated the previously required supervisory approval for initiation of condition reports. The inspectors dete< mined that the electronic process provided more efficient and timely control room and quality programs notification of identified conditions and more timely determinations of equipment and/or system operability.
The procedure specified three classification levels for condition reports based on importance. The procedure assigned responsibility for the classification of condition reports to the director of quality or his designee. The condition report classifications were as follows:
Significant condition reports - The highest condition report classification. The
root and contributing causes were to be determined. The correcWe action review board was assigned to determine if a root cause analyses 4 + root cause determination was required, if required, the board also assigned a completion due date.
Station levelimpact condition reports - A root cause determination was
required. Identification of contributing causes was not required.
Department level impact condition reports - An apparent cause was required
to be determined.
For those identified problems that did not meet the criteria set forth above for condition reports, the licensee used a number of other reporting processes. The first and foremost was the condition identifiers. The majority of lower threshold problems identified by licensee personnel were recorded through the condition identifier. Other processes included trouble tickets and engineering requests.
Newly issued condition identifiers were reviewed by the licensee at a daily work control planning meeting and a daily control room management meeting. On both occasions, the adequacy of the prioritization assigned to a particular condition identifier was verified. In addition, the licensee collectively determined whether a condition report was needed for the identified condition.
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Quality programs personnelinformed the inspectors that problem identification by means of condition reports had increased from 1106 condition report equivalent forms (material nonconformance reports, quality deficiency reports, security deficiency reports, radiological deficiency reports, and discrepant material reports) in the 12 months prior to August 1995, and 813 condition report equivalent forms for the 12 months prior to August 1996, to 1513 condition reports for the 12 months prior to August 1997.
During the inspection, adverse conditions observed by the inspectors during tours of the plant and observation of work activities were generally already identified by the licensee by means of condition reports or condition identifier / work order forms.
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Conclusions The inspectors concluded thet conditions adverse to quality were generally being identified in condition reports or other corrective action documents. The inspectors also concluded that electronic initiation of condition reports, elimination of supervisory approval for initiation of condition reports and the combi.iation of several reporting mechanisms into one condition reporting process were f avorable changes to the problem identification and reporting process.
01.2 Problem Identification and Resolution a.
Insoection Scone (40500)
The inspectors reviewed operating logs, interviewed 11 licensed and nonlicensed
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operators, observed operatbns' department plant status meetings, observed control room activities, accompanied equipment operators in the plant, and reviewed corrective action documents to determine if problems were being appropriately identified and corrected using the corrective action program.
The inspectors reviewed the list of open condition reports, to determine the size of this list, the trend, how open condition reports were tracked and managed, and how priorities were determined. The inspectors also discussed the open condition report list with applicable licensee personnel, b.
Qhtervations and Findinas The inspectors reviewed control room shif t supervisor logs and operator logs for the months of July and August of 1997. No problems or issues were identifeed, which had not been appropriately documented through the corrective action progra _. -
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The inspectors interviewed auxiliary operatocs and control room operators. All personnelinterviewed were found to be know'edgeable of the corrective action (condition report) program as a whole. While auxiliary operators' knowledge regarding some of the specific criteria for when a condition report was to be written was lacking, all operators indicated that whenever there was any uncertainty they would not hesitate to bring it to the shif t superintendent's attention. This coupled with the licensee's effort to continue to periodically train the plant staff on the new corrective action program, and the lack of any identified specific errors in recording problems indicated that the licensee's operations personnel were effectively implementing the corrective action program.
The inspectors found that operations personnel were correct!y initiating condition reports and condition identification and work order forms as new issues were identified.
Condition Reoort Bukloa Data provided by quality programs personnelindicated that condition reports were being initiated at a rate of approximately 100 to 125 reports per month while approximately 70 to 100 condition reports were being closed per month in 1997.
During the inspection period, approximately 750 condition reports were open and approximately 450 of the open condition reports were over 6 months old. The open condition reports were being tracked by quality programs. Open and overdue condition reports were being identified in monthly summaries issued by quality programs and were being discussed during monthly management meetings.
The inspectors reviewed the licensee's list of open condition reports that were greater than 6 months old. The inspectors selected six condition reports from the list for a more detailed review. The inspectors determined that, in ger,eral, appropriate reviews and interim actions had been performed for the open condition reports, and reasonable due dates were specified. The inspectors also determined that, in general, licensee rationale for the condition reports being still open was reasonable. For example, Condition Report GGCR1996-0110 identified potentially Grade 2 bolts in lieu or Grade 5 bolts installed on motor-operated valve actuator upper bearing housing covers. The licensee performed extensive reviews and technical evaluations, replaced bolts in marginally acceptable applications, and technically accepted postponement of replacement of other bclts for the next refueling outage.
One of the six condition reports greater than 6 months old that was reviewed by the inspectors was Condition Report GGCR1996 0179-01, dated October 20,1996.
The condition report noted that six control rods were observed to be slower than administrative limits, but were within technical specification limits during
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- 10-surveillance testing. The condition report and licensee corrective actions were discussed by the inspectors with licensee personnd. During the discussions, the inspectors noted that no operability evaluation was performed for the condition report at the time the condition was identified. The licensee's representative confirmed that no operability evaluation had been performed for the condition report as required by the condition report procedure. The licensee issued Condition Report GGCR1997-0916, dated August 19,1997, to record the failure to perform an operability evaluation. The licensee performed an operability evaluation for the conditions identified by Condition Report GGCR1996-0179-01 and confirmed that the control rods in question were still operable. The licensee reviewed the condition report database and determined that no other condition reports lacked required operability evaluations. The inspectors concluded that the specific missed operability evaluation was of minor safety significance, appeared to be an isolated case, and was promptly corrected by the licensee. This f ailure constitutes a violation of minor significance and is being treated as a noncited violation, consistent with Section IV of the NRC Enforcement Policy (50-416/9718-01).
During discussion of licensee corrective actions for Condition Report GGCR1996-0179 01, the inspectors determined that the licensee performed extensive technical evaluation and testing for the observed condition.
The inspectors determined that the scram solenoid pilot valve top head assemblies for two affected hydraulic control units were replaced. The new assemblies were subsequently satisfactorily tested. The scram time testing frequency for the af fected control rods were accelerated to approximately every 120 days, and the new assemblies were not exhibiting the previously observed condition. However, the inspectors also noted that the condition that resulted in the slower scram times had not yet been determined and corrective actions specified by plant systems engineering, in January 1997, to be ich test and inspect the removed scrern solenoid valve top head assemblies had not yet been completed. The insoecie found this lack of aggressive resolution of the slow scram times to be a weakness.
Operations Deoartment Condition Reoorts The inspectors determined that the operations department list of open condition reports was small, totaling only 64 items. No appreciable increase was noted from the previous year. The inspectors found that all of these items had been appropriately prioritized in terms of their safety significance, and that recommended corrective actions were performed in a timely manner. As a result of these findings, the inspectors determined that the operations department personnel were appropriately managing their open item backlo. =.
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-11-The inspectors reviewed 10 open condition reports and 32 completed condition reports and verified all had been reviewed and properly categorized. The inspectors also verified that determinations regarding reporteh)hty in accordance with 10 CFR 50.72 and 50.73, and operability associated with these condition reports, were proporly dispositioned. In accordance with the requirements of Administrative Procedure 01 S-0310, "GGNS Condition Report (CR)," root-cause analyses were performed for those open condition reports that were determined to be safety significant.
For those condition reports requiring a root cause analysis, the inspectors reviewed the conclusions and the resultant recommended corrective actions. The inspectors found the licensee's analyses to be thorough and the recommended corrective actions to be appropriate.
Condition Identifiers The inspectors selected and reviewed 30 open condition identifiers assigned to operations for resolution and determined that each item had been appropriately prioritized. No problems were noted from these reviews. In all cases, no condition identifiers were found that met the criteria for a condition report.
The inspectors reviewed a licensee list of condition identifiers issued since mid June 1997. The inspectors noted that at least five different condition identifiers (064800,065685,065779,065457, and 065938) had been written in the 3-month period regarding spurious fire detector and compJter alarms. One of five, Condition identifier 065457, involved the diesel generator building deluge control panel fire detector, which alarmed la times during a control room shift briefing and was reported by control room operators to be a distraction from control room business.
The operators subsequently determined the alarms were spurious. The licensee informed the inspectors that subsequent trouble shooting did not identify the cause of the alarm.
The inspectors determined that in each case the condition reported on the condition identifiers noted above, were being individually reviewed and corrected. However, the inspectors also noted that the cumulative problem of spuric o fire alarms was not being reviewed for more generic considerations, such as:
(1)
Adequacy of fire detectors, alarms, and computers (2)
Adequacy of maintenance of fire protection equipment (3)
Potential human f actors impact on contro' am crew responsiveness to spurious fire alarms
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This was considered to be a weakness in the implementation of th a corrective action program for the fire protection system, i
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Conclusions
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The inspectors concluded that operations was appropriately identifying and resolving conditions adverse to quality and that the licensee vias adequately managing the
condition report backlog.
-The inspectors also concluded that the licensee's lack of aggressiveness in identifying the cause of control rod slow scram times and spurious fire alarms was a weakness.
Operational Status of Facilit!es and Equipment O 2.1 Ooorator Work-Arounds a.
insoection Scoce (40500)
The inspectors reviewed control room shift supervisor logs to determine the number, status, and use of operator aids and work arounds. In addition, the inspectors interviewed five operations personnel and the operatians manager.
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Observations and Findinos The inspectors reviewed the licensee's operator aid and work-around programs. The status of these programs, which were maintained in logs, was found to be current,
with each log identifying the number of outstanding items in the plant.
The inspectors found that the licer see had a total of 51 operator aids logged. The
' inspectors selected 5 of these operator aids and found that they were appropriately reviewed and approved. The inspectors found that the licensee reviewed the
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operator aids log on a periooic basis. No unapproved operator aids were identified
by the inspectors and none of the oporator aids were found to constitute an operator work around.
'The operator work-around program was managed by the operations assistant in
. charge of. work control. Guidance for this program was provided in the Principles of
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Operation Number A-001, " Operator Work Arounds." The inspectors found that the licensee logged 23 items as work-arounds. Principles of Operation A 001 defined an
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13-oport. tor work around as any equipment deficiency that adversely affects or could af fect normal, abnormal, or emergency plant operations, or causes an operator to take compensatory actions beyond the intended t' sign. The inspectors found that the licensee reviewed ar.d prioritized the items on the operator work arounds log on a weekly basis.
Of the 23 items listed, only 2 required operations personnel actions during transient conditions. The inspectors noted that the licensee had reviewed these, and all the other work-arounds, and cietermined that the plant could be operated saf ely with these work arourds in-place until the next refueling outage. The inspectors corisidered management of operator work arounds to be appropriate.
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Conclusions The inspectors concluded that the operator aids and operator work arounds were property controlled.
Quality Assurance in Operations 07.1 Scll Assessment Activities a.
inspection _ Scone (40500)
The inspectors reviewed the licensee's audit schedule and compared it with the frequency requirements specified in the quality assurance program. The inspectors also evaluated the scope and depth r;f audits listed in the Attachment, b.
OhiciYations and Findings The inspectors reviewed three self assessments and three quafity programs audits that had been performed in the operatioris and radiation protection functional areas during the last 15 months. All of those assessments and audits were found to be thorough, in depth, and critical.
Problems identi.fied in each assessment / audit were evaluated Sy quality programs to determine if they met the criteria for being written up as condition reports. The inspectors r.oted that the audits also provided recommendations for improvement, in addition to findings of conditions adverse to quality. Recommendations were determined appropriate for each assessment or audit for each identified concern.
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ConcluMQas The inspectors concluded that cudits and self assessments of operations and radiation protection were found to be thorough, in depth, and critical with very good corrective actions recommended.
07.2 Resolution of Audit Identified issuns a.
insocction ScDDs MO5001 The inspectors selecteiissues identified during a quality programs audit to determine the licensee's effectiveness in resolving the identified issues.
Specifically, the inspectors selected issues identified by Quality Systems Audit Report OPA 09.0197, issued April 14,1997. The audit was the licensee's annual fira protection audit that was performed from January 27 through February 28, 1997. The inspectors discussed the audit findings with licensee personnel and reviewed associated corrective action documentation. The inspectors visually inspected various areas of the plant to review the reported conditions and associated corrective actions, b.
Observations and Findinas Quality Systems Audit Report OPA 09.0197 indicated that a comprehensive fire protection program audit was performed by the licensee. The audit determined that
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the Grand Gulf Nuclear Station Fire Protection Program met the intent of NRC Branch Technical Position APCSB 9.5.1 regarding fire protection requnements.
However, the audit also found that the fire protection program and support programs were not being adequately implemented.
The audit identified 11 negative findings thet resulted in 10 condition reports (1 finding was corrected during the audit). In addition the audit resulted in 11 condition identifiers. As a result of $he audit, the licensee formed a task force to develop and implement recommended corrective actions for the fire protection progtam.
Five Brigade Training The audit found that a fire drill fcr ont. operations shif t fire brigade was not performed within ihe 92 day frequency (23 days over due) as required by Procedure 10 S-03 7, " Fire Protection Training Program," Revision G.- Condition Report GGCR19970180-00 was written for this noted conditiv. Tha audit also found that one fire brigade member was called away from fire brigade training on September 23,1996, and there was no evidence that the training was completed by
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15-i the individual. The audit found that foui fire brigade members did not attend procedurally required quarterly fire brigade meetings at various periods in 1996.
Condition Report GGCR19970180 01 was written for these noted conditions.
The training department evaluation of the condition reports determined that the cause of the discrepancies was a lack of ownership of the program (i.e., the shift crews were responsible for their own drillst As corrective action, the training department took over rerponsibility for the fire drills and the involved instructors were counseled on proper procedure compliance. The operations department evaluation of the condition reports determined that the operations shift crews f ailed to track the fire brigade qualification matrix and ensure that fire brigade drills were performed within required times. As corrective actions, operations supervisors were provided instructions on the use of the fire brigade qualifications matrix, provided updates to the fire brigade qualifications matrix when training is performed, and transferred fire protection training responsibilities to the training department.
1ha inspectors determined that licensee corrective actions were reasonable.
Fire Fiahtina and Fire Brigado,1guioment The audit found several deficiencies associated with fire fighting and fire brigade equipment and issued condition identifiers for the identified deficienciis. The audit found the following:
General observation of plant exterior ya'd fire hose stations and tool racks
were degraded and in need of repair due to exposure to the elements.
Condition identifier 62926 was written on this issue. The yard fire hose stations and toal racks were repaired and added to the weekly rounds.
Hose Housa D029G, in the vicinity of the control building, was not anchored
and was determined to be a potential hazard during high winds. Condition identifier 62023 was written on this issue. The hose house was anchored and added to the weekly rounds.
Hose House D0290 had a broken ax holder. Condit;cn identifier 62925 was
written on this issue. The broken holder was repaired and the hose house was added to the weekly rounds.
Two self contained breathing apparatus that had not been checked in over
6 months, were found in the station's fire truck. The seif-contair'ed breathing apparatus were not requireo to be in the truck and were inadvertently lef t in tha truck during training performed May 1996. The audit determined $. hat the fire truck alco had the required number of properly
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checked self contained breathing apparatus, that the observed condition was an isolated case, and that personnel donning self-contained breathing apparatus were trained to verify that their equipment was operable.
Fire Brigado Equipment Locker FL6 for the Control Building Division 1 and 2
switchgear room did not have a flashlight. The fire coordinator was notified and corrected the conditior..
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The inspectors determined that reasonable corrective actions were performed for the identified conditions.
Fire Patrica The audit identified fire bar,ier deficiencies that jeopardized the fire barriers and presented leakage paths for carbon dioxide from one fire area to another. The deficiencies reviewed were as follow:.:
There was an approximately %-inch diameter hole through the wall that
separates the Division i electrical switchgear area and the Division lll battery room. Condition Report GGCR19970146 00 was issued. The licensee determined that the fire wall was inoperable and posted a continuous fire watch. The condition was determined not reportable. The hole was subsequently filled.
A 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> concrete masonry wall fire barrier had eight %-inch diameter wall
holes and two 3/8 inch diameter holes. The wall separates the 93 foot elevation control building heating, ventilation, and air conditioning room from the health physics supervisors office and health physics break room.
Condition Report GGCR19970218 00 was issued. The licensee determined that the fire barrier was inoperable and established a fire watch. The condition was determined not reportable. The holes were subsequently filled.
Emergency Liahting The audit identified two emergency lights that did nnt work. Condition identifiers 062048 and 062871 were wutten for the lights January 27 and March ~7, 1997, respectively. Subsequent processing of the condition identifiers resulted in a determination that an incorrect component number was used in Condition identifier 062048 and that the light in question had been previously identified as not
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working by Condition Ide.itifier 061826 on January 17,1997. Both conditions and condition identifiers were reviewed by the licensee and no inoperable conditions, technical specification limiting condition for operations or compensatory actions tvere specified. Both conditions were also reviewed for 10 CFR 50.72 and
' O CFR 50.73 reportability and both conditions were determined not reportable. No reports to the NRC were made by tht acensee for either condition.
The inspectors determined that fire barrier, fire detection, and fire suppression requirements were specified in the Grand Gulf Nuclear Station Technical Requirements Manual, but no emergency ligSting requirements were specified in the manual. The inspectors discussed the conditions associated with the emergency lights that were identified by the audit riot working, with the fire protection engineer and other licensee personnel. The inspectors were informed by the fire protection engineer that the light noted in Condition Identifier 062871,
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Component 1Z92S3030, was a light in Control Building Stairway 25A, that was required by the fire code, but was not required for operation and/or access and egress to equipment needed for the safe shutdown of the plant during a fire. The light was inspected and tested and no problems were found. The light was returned to operations * control on March 10,1997.
The inspectors were also informed by the fire protection engineer that the light noted in Condition Identifier 061826 and 062048, Coinponent 1T92S222A, was a light in Elevation 119 of the auxiliary building that was required for access and egress to Electrical Switchgear Room 1 A219 where equipment may be needed to be operated to bring the plant to eafe shutdown condition during a fire. The inspectors determined that Emergency Light 1T92S222A was repaired by replacing a switch module, and returned to operations' control on January 29,1997. The inspectors determined that the light was not working for approximately 12 days while the unit operated at or about 100 percent power and no compensatory action was taken for the inoperable light.
The inspectors determined that Grand Gulf Nuclear Station Facility Operating License NPF 29, Amendment 82, Condition 2.C.(41) dated August 23,1991, required that Entergy Operations, Inc., implement and maintain in effect all provisions of the approved fire protection program as described in Revision 5 to the Updated Final Safety Analysis Report. The inspectors determined that Section 9.5.1, " Fire Protection System," of the Grand Gulf Nuclear Station Updated
Final Safety Analysis Report provided the design basis for the fire protection systems.
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Updated Final Safety Analysis Report, Section 9.5.3.2.3, " Emergency Lighting System." Revision 10 states, in part, " Backup de lighting with battery packs are provided for areas essential to the operation of equipment required for safe
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shutdown as tabulated in Table 9.515 and along access ioutes between these areas where critical tasks are carried out durhg emergencies." Table 9.515 lists the access routes to the auxiliary building elevation 119 foot electrical switchgear rooms as an area where emergency lighting was provided. Emergency
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Light IT92S222A provided on the access route to the switchgear rooms was not functioning properly for approximately 12 days. No interim compensatory action was providta to provide emergency lighting that was required for access to areas where critical tasks are carried out during an emergency and to bring the plant to a safe shutdown condition. The inspectors determined that the licensee's corrective actions specified in Condition Identifiers 061820 and 062048 were inadequate, This was identified as a violation of Amendment 82 of the approved fire protection program requirements and the operating license (50-41 *i/9718 02).
the of Water on Electrical Fires Grand Gulf Nuclear Station actions taken as a result of a June 10,1995, Waterford Generating Station, Unit 3, fire were reviewed during the audit. During an interview with a fire brigade leader, the Grand Gulf Nuc; ear Station auditors were informed that the leader was reluctant to use water on an electrical fire. The Waterford Generating Station, Unit 3, fire was finally extinguished by the offsite fire department within 4 minutes of using water. The inspectors noted that NRC Information Notice 95 33, "Switchgear Fire and Partial Loss of Offsite Power at Waterford Generating Station, Unit 3," informed licensees that delays in extinguishing a cable tray fire hisulted from a fire brigade leader's reluctance to use water on the fire.
. The inspectors discussed the audit findings with the licensee's fire protection coordinator, fire protection engineer, and other licenseo personnel. The fire protection coordinator informed the inspectors that the use of water and fog pattern spray nozzles to fight fires on electrically energized equipment was re-emphasized during the weekly briefings provided to fire brigade members, in addition, the fire protection coordinator provided the inspectors with records of fire brigade drills, that were perfortred in June and July 1997, that simulated the use of water on electrically energized equipment. Finally, tha fire protection coordinator informed the inspectors that the licensee was consid ring the use of better fire fighting simulation that could be attained in an offsite f acility, for further fire brigade training. The inspectors determined that the licensee had taken adequate corrective
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action for the audit identified reluctance to use watet on an electrical fire, f
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19-Renoitabiliiv Evaluation of Fire Protection Proaram Deficiencies As noted above, the individual fire protection program audit deficiencies were evaluated for reportability by the licensee in accordance with 10 CFR 50.72 and 50,73. None of the identified conditions were determined to be reportable. In addition, the licensee informed the inspectors that the collective audit findings were also determined to be not reportable and no licensee event reports had been
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submitted for any of the fire protection program deficiencies individually or collectively.
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The inspectors noted that the design bases of the fire protection system was provided in Updated Final Safety Analysis Report, Section 9.5.1, and the Fire
Hazards Analysis. The inspectors noted that the design bases for the fire protection system consisted of fire barriers, fire detection, fire suppression, and emergency lighting to allow access to, and operation of equipment, needed to place the plant in a safe shutdown condition during a fire. The inspectors determined that the numerous fire protection program implementation deficiencies identified by Ouslity Systems Audit OPA 09.01-97 collectively represented conditions that placed the fire protection system outside the design bases of the plant.
f(ii)(B), requires, in part, that a licensee event report be 10 CFR 50.73, Section (ru submitted within 30 da
. iter discovery of a condition of the nuclear power plant, including its principal 5
- y barriers being seriously degraded, or that resulted in the nuclear power plant being in a condition ti.at was outside the design basis of the plant. The inspectors determined that while the licensee corrected the implementetion deficiencies identified in the audit, the licensee's f ailure to submit a licensee event report regarding the fire protection system deficiencies identified by the audit was a violation of 10 CFR 50.73 (50 416/9718-03).
c.
Conclujiinns The inspectors concluded that the licensee performed a good fire protection audit that identified numerous deficiencies. Based on the audit findings, and other licensee identified fire protection program deficiencies, the inspectors concluded that the licensee's impicmentation of the corrective action program in the fire protection
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functional area was weak, This weakness was demonstrated by the failure to i
provide compensatory action for an inoperable emergency light, the weakness in the corrective actions for repetitive spurious fire alarms, the weakness in the corrective actions taken for the Waterford fire, and the f ailure to report fire protection program
- deficiencies, a.
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07.3 Offsite Safety Revjew Committee a,
Insagetion Scope f40500)
On July 29,1997, the inspector observed a portion of Offsite Safety Review Committeo Meeting 97 03 to observe committee activities and verify corrpliance with Technical Specification 7.4.2. The inspectors reviewed Procedure G2.501,
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" Safety Review Committee " Revision 6, which identified the organization, duties, and responsibilities of the Grand Gulf Safety P.sview Committee. The inspectors also reviewed safety review committee minutes for Meetings 97-01 and 97 02, and committee initiated assessment and audit findings, t
b.
Observations and FindiDES The inspectors noted that the committee reviewed safety evaluations for changes to procedures, equipment, systems, plant operating history, reportable events, violations, reports of significant operating abnormahties or deviations, and reports from subcommittees. The inspectors noted that the committee asked challenging questions and, as a result, some items reviewed were assigned additional review actions.
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Conclusions
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The inspectors concluded that the safety review committee mr't the function, composition, and responsibility requirements of Technical Specification 7.4.2.
07.4 Plant Sainty_ Review _C9mmittee Activities
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a.
insp.ection Scone (40500)
I The inspectors reviewed the activities of the Grand Gulf Plant Safety Review Committee. The inspectors interviewed members of the plant safety review committee, attended two plant safety review committee meetings, reviewed
l Administrative Procedure 01 S 013, " Plant Safety Review Committee," and l
reviewed the plant safety review committee meeting minutes for the period of l
June 3 through August 5,1997, to venfy that technical specification requirements l
were being met and that the reviews were effective in identifying and resolving problems, i
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Observations and Findingi The inspectors determined that the plant safety review committee was performing all activities required by the technical specifications and implementing procedures.
The observed plant safety review committee meetings included critical discussions of the reviewed activities including new condition reports, c.
CQncluS10ns The inspectors concluded that the plant safety review committee was effectively implementing technical specification requirements related to its function.
07.5 Indegnadent Safety Enaineerina Grouo a.
insnection Scoce (405001 The inspectors reviewed the activities of the independent safety engineering group to determine whether they were accomplishing the functions described in the technical specifications. The inspectors reviewed Procedure 09 S-0314,
" Administration of ISEG Activities," Revision 100, which described the scope of the activities of the safety issues group, and the rules for administration of the indepencant safety engineering group function within the nuclear safety and regulatory af f airs department. The inspectors reviewed the independent safety engineering group activities and various safety issues group assessments, b.
Qhservations and Findinas The inspectors determined that the independent safety engineering group examined plant operating events, NRC issued documents, industry advisories, and other sources of operating experience information. Based upon those examinations, the independent safety engineering group made detailed recommendations for improving plant safety to the chairman of the safety review committee.
The inspectors determined by a review of documents that the independent safety engineering group members were appropriately monitoring plant activities, c.
Conclu1iQns The inspectors concluded that the independent safety engineering group met the function, composition, and responsibilities requirements contained in Technical Specification 7.2.6.
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22-07.0 ladustr.y_ Operating Exoerlente a.
Insacr110n3 nope (405001 The inspectors reviewed the licensco's program for evaluating and tracking industry operating events. This program was reviewed to determine its effectiveness in assessing, documenting, and informing appropriate plant personnel of significant plant events in an effort to prevent their occurrence at the plant.
b.
Observations _and Findinas The licensee's program for evaluating and tracking industry operating events was managed by the Director, Nuclear Safety and '4egulatory Aff airs. The program was governed by Nuclear Safety and Regulatory Aff airs Procedure 09 S 0310, " Industry Operating Experience Review Program." The licensee's program evaluated industry operating experience documents, including:
NRC infoimation notices
NRC bulletins NRC generic letters
NRC administeative letters
INPO significant operating experience reports
INPO significant event reports
Vendor bulletins
10 CFR Part 21 notifications
The inspectors reviewed two significant event reports and one 10 CFR Part 21 notification to determine the adequacy of the licensee's program. All three items had beer, properly evaluated and appropriately dispositioned.
The inspectors selected NRC Information Notice 95-36, " Potential Problems with Post Fire Emergency Lighting," and NRC Dulletin 96-03, " Potential Plugging of Emergency Core Cooling Suction Strainers by Debris in Boiling Water Reactors,"
to determine the licensee's actions for these documents. The inspectors also reviewed the " Quarterly Summary of Plant and Industry Operating Experience (GIN 97/01352)." dated July 29,1997.
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The inspectors determined that the quarterly report summary report provided appropriate program information. The inspectors found that from Januery 1 to
August 21,1997, the operating experience feedback program had identified, and was tracking,171 new operating experience documents. The inspectors' review uf the licensee actions for NRC Information Notice 95 36 and NRC Bulletin 96 03 i
found that while the items were being tracked in the licensee program, the licensee had not completed the evaluations of these two items as of August 22,1997, c.
Conclusions The inspectors concluded that reviews and corrective actions for operating
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experience were being controlled and L.t the industry operating experience review program was managed appropriately.
07.7 Corrective Action Review band a.
lnspection Scoce (4050.Q)
The inspectors reviewed the activities of the licensee's corrective action review boord to determine the effectiveness of the licensee's process for review and resolution of significant conditions adverse to quality, b.
Observations and FindiDOS On May 9,1996, the licensee issued Administrative Procedure 01 S-03 9, "GGNS Corrective Action Review Board (CAFB)," Revision 0, to formalize the correctivo action review board review process. The procedure required the review of significant deficiencies and their root cause by a corrective action review board.
On August T;,1997, the inspectors observed a corrective action review board meeting, The board discussed significant condition reports, and root cause evaluations for Condition Reports GGCR1997-0644-00 and GGCR1997-0722. The inspectors noted good discussions regarding the identified conditions, the root causes of the conditions and planned corrective actions.
c.
Conclusjons The inspectors concluded that the corrective action review board was performing good reviews of identified conditions and root-cause determinations and was assuring effective corrective actions for significant conditions adverse to quality.
High level management attention to significant conditions adverse to quality was being provided through particioation in the board activities.
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11. Maintenanna M1 Conduct of Maintenance M1.1 Observation of On Line Mpintenance Activities a.
Insocction Scone (62700)
During the inspection, the inspectors observed various elements of on une maintenance in progress and assessed the performance of individual elements of the licensee's maintenance process. These elements included coordination, control, testing, nod documentation of unexpected or unsatisf actory conditions.
The inspectors observed portions of various on-line maintenance activities and post maintenance testing performed for the following work orders:
00103350 (MWO)
Investigate as-built v ing configuration for Standby Diesel Generator Engine 1P75E001 A 00184857 (MWO)
Rebuild Service Air Compressor SP52C0010 00185456 (MWO)
Correct jacket water leak (dresser couplings, etc.) on Standby Diesel Generator Engine 1P75E001 A 00185492 (MWO)
Repair fuel oil pipe supports for Standby Diesel Generator Engine 1P75E001 A 00187660 (MWO)
Rebuild second stage of Instrument Air Compressor SP53 001 00187890 (MWO)
Truobleshooting Division i Standby Diesel Generator Instrument Panel 1H22P400 control fuse f ailure 00191700 (MWO)
Repair Division 1 Standby Diesel Generator Motor Driven Compressor Air Dryer Air Trap 1P75D0248 00191701 (MWO)
Troubleshoot Division 1 Standby Diesel Generator Lube Oil Temperature Trip Switch 1P75N053A l
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Observations and Findinas Plant operations, engineering, and other maintenance personnel provided good support during the observed maintenance activities. The observed on line i
maintenance activities were performed in accordance with approved procedures by knowledgeable personnel. Tne inspectors noted that on July 31,1997, the licensee identified that an out of dato vendor manual and incorrect replacement material were provided for the performance of maintenance in accordance with the following work orders:
QO184857 (MWO): During the rebuild of Service Air Compressor SP52C001 A, the mechanic identified that the replacement first stage diffuser had insufficient eye clearance because the as received contour of the diffuser did not match the impeller.
An onsite vendor representative stated that the as received diffuser was the correct part and that.he parts list in the licensee's onsite copy of the vendor manual was out of date. The diffuser was sent back to the vendor to have the eye clearance machined to an acceptable dimensioa. Upon return of the diffuser from the vendor, the mechanic found that the eye clearance was less than the minimum 0.018 inch spo.;ified in the existing onsite copy of the vendor manual. During followup discussions with the vendor, the vendor identified that they had revised their f actory specifications for the eye clearance to a minimum of 0.013 inch. The licensee verified the current as-received diffuser to impeller eye clearance was acceptable in accordance with the later f actory specifications and noted the,t their onsite cen""' the vendor manual was not up to-date. The out-of-cate vendor information anJ inwrrect material problems were documented in licensee Condition Report GGCR1997-0909 00.
QO187660 (MWO): In the process of purchasing replacement parts for rebuilding the second stage of instrument Air Compressor SP53 COO 1, the vendor specified a new part number for the replacement gasket kit. Engineering Request 91/0361 00 identified that the vendor was contacted about the acceptability of the new gasket kit part number and the vendor provided a f ax stating that, "It]he items in the gasket kit twere] the same, the only change (wasl the part number." When the new gasket kit was opened, the licensee noted the rear door pasiret was thicker and
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manufactured from a different material than the originally removed door gasket. The new replacement door gasket was supplied in a black rubber or neoprene material.
The onsite vendor representative stated that the black rubber or neoprene gasket was the latest updated replacement part and that the parts list in the licensee's vendor manual was out of-date. The new replacement gasket was installed with the vendor representative present, usirg the same vendor instructions provided for the original thinner Garlock material gasket. The inspectors noted that the new rubber gasket material extruded approximately 0.5 to 1 inch beyond the outside c0nfiguration the door when the doar bolts were torqued. The onsite
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26-vendor representative stated that this observed rubber gasket extrusion was normal. The air compressor was retested satisfactorily and returned to service.
Within a day of returning the air compressor to service, an air leak was identified in the third stage of the air compressor introducing air into the turbine building cooling water system. The air leak was documented in licensee Condition Report GGCR1997 0867-00 and this condition report noted that the air leak could have resulted in a plant transient. The air compressor was disassemblad for examination.
Upon initial examination of the removed rubber door gasket, the lic:.nsee's representative observed that an extrusion of the rubber gasket material on the inside diameter of the door gasket may havs prevented an acceptable seal. The licensee corrected the air leak problem by replacing the rubber gasket with a gasket manufactured from Garlock gasket material. The problems encountered with out-of date vendor information and door gasket kit material were also documented in licensee Condition Report GGCR1997 0909 00.
00187820 (MWOh During troubleshooting of a Division 1 Standby Diesel Generator instrument Panel 1H22P400 control fuse f ailure, a replacement optical isolator was obtained. The replacement isolator mounting block was too wide to fit into the instrument panel. Since a correct size replacement opticalisolator was not readily available, the original optical isolator was rebuilt to complete the repair work. This material problem was documented in licensee Condition Report GGCR1997-0849 00. Dunng followup material ordering to obtain new replacement opticalisolators, Engineering Request 97/0583-00, dated July 27, 1997, noted that the vendor could no longer supply the subject opticalisolator as safety related.
Discussionc with the licensee representatives revealed that there had been several instances of work delays encountered when material that had been approved for use for specific applications was found to be incorrect through a like for like comparison.
The licensee had documented other examples of where incorrect reolacement material was supplied in the field. The licensee noted in an initial ront-cause
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analysis for Condition Report 1997-0491-00 that there was an increased reliance on the craf t in the field to identify incorrect material. The licensee implemented a quality action team to review the material problems identified in Condition Report 1997-0491-00, and other similar condition reports, and provide recommended actions to resolve this replacement material problem.
Onsite vendor technicalinformation and manuals were controlled in accordance with
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Procedure 01-S 05-4, " Control of Vendor / Technical Manuals," Revision 14, to ensure the latest vendor information was available. Liccnsee representatives stated that a review of the vendor technicalinformation and manual updating program would be performed as part of the quality action team investigation of the introduction of incorrect replacement material to the job site.
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Conclusions The observed on line maintenance ectivities were performed in accordance with the procedures by knowledgeable personnel. When out-of-date vendor technical information and/or incorrect replacement material were supplied for work, appropriate corrective action was implemented to investigate the problems encountered.
M2 Maintenance and Material Condition of Facilities and Equipment M 2.1 Canditto.tLEcus11s a.
Insocction_ScQue (405001 The inspectors reviewed 16 condition reports to determine the licensee's ef fectiveness of:
(1)
Initialidentification and characterization of problems (2)
Root cause analysis (3 Implementation of corrective actions, including evaluation of repetitive conditions (4)
Expans;on of the scope of corrective actions to include applicable related systems, equipment, procedures, and personnel actions The inspectors also discussed several of the condition reports with licensee personnel, b.
Obscivations and Findinas The inspectors found that the condition reports were being appropriately utilized for problem identification en j implementation of repair and replacement of plant equipment. The inspea: ors found no examples where the condition reports were improperly used to modify the plant design. In addition, no examples of major repetitive maintenance were identified. The inspectors determined that the licensee had implemented appropriate corrective actions for the condition reports reviewed.
c.
CQDcluS1Dns The inspectors concluded that the selected condition reports had been adequately disnositioned.
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M2.2 Msintenance Work Orders a.
InSDsnil0D_Sapoe (405001 The inspectors reviewed 16 work orders involving maintenance activities to determine if repetitive problems existed and to determine if they were being used to improperly modify the plant design. The inspectors discussed several of the work orders with licensee personnel, b.
Qhsetyations and Findings The inspectors found that the woik orders were used appropriately for the repair and -
replacement of plant equiprnent. The inspectors found no examples where the work orders were improperly used to modify the plant design. In addition, no examples of major repetitive maintenance were identified, c.
Conclusions The inspectors concluded that work orders were appropriately used for the repair and replacement of plant equipment.
M2.3 Mainignance Backing a.
insngetion Scoots (405QQ1 The inspectors reviewed the maintenance backlog of work orders to determine the backlog size, the trend, how the backlog wcs tracked and managed, and how priorities were determined. The inspectors also discussed the backlog with applicable maintenance perso.inel, b.
Observations and Findings In accordance with Procedure 01 S-071, Control of Work on Plant Equipment and Facilities," RevWon 31, the licensee's work order priority system distinguished the action level re. ired by plant organizations in initiating, working, and closing a work order, as noted below:
Priority 1:
Immediate action was required and should havn been maintained on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis until the item was under control.
Priority 2:
Action was assigned and coordinated on a priority basis to meet imposed time restraints.
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Action was assigned and coordinated on a routine basis.
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Priority 4:
Action was assigned and coordincted on a fill in basis.
The licensee's backlog of higher Priority 13 maintenance work orders F.id not changed much over a yect, while the backlog of lower Priority 4 maintenance work orders increased approximately 50 percent, in August 1996, tne maintenance work order backlog cor.sisted of 494 Priority 13 work orders, and 515 Priority 4 work orders. By August 1997, the backlog of Priority 13 maintenance work orders had decreased to 445, while the backlog of Priority 4 ma%tenance work orders increased to 981. The inspectors reviewed selected work orders and noted that the licensee's tracking system was effectively tracking the backlog of maintoaance work orders.
c.
Cont lusions The inspectors concluded that the licen';ee's backlog of maintenance work orders was being appropriately tracked.
M 2.4 Plant Walkdown a.
Insoection Scone (4050D and 62700)
The inspectors observed the material condition of the plant and determined the offectiveness of licensee actions in maintaining material condition, b.
QD5gtvations and Findinas During tours of the diesel generator building, control building, containment / auxiliary building, turbint; building, and radioactive waste building, the inspectors found that the structures, systems, and components observed were visually free of corrosion.
There were some minor oil and water leaks; however, based on the external condition of the affected structures, systems, and components, they appeared to be well maintained, c.
Conclusions Based on the external condition of the observed structures, systems, and components, the material condition of the plant was good.
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M3 Maintenance Procedures and Documentation
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M3.1 Beview of Maintenance Procedures. Records, and Work Orden i
a.
Insoection Sgane (62700)
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The inspectors reviewed selected rnaintenance work procedures and work orders i
during the review of maintenance activities. The inspectors assessed these documents to determine if they had been developed in accordance with the licensee's administrative requirements to ensure maintenance activities were l
cor. ducted in a manner that resulted in the reliable and safe operation of the plant.-
b.
Observations and FindiDSS i
I A majority of the reviewed maintenance work procedures and work orders were written with little or no detailed work instructions. Craf t personnel were normally
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expected to review reference documents and perform component disassembly, repair, and reassembly activities in accordance w;th skill of the craf t. During the observed air comprest.or work performed in accordance with skill-of-the-craft, the
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inspector: noted difficulties and necessary rework as a result of the lack of detailed
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Concluuons
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The inspectors concluded that some maintenance documents provided the minimum j
level of instructions for tasks, and thr.t problems were encountered on the job due to
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the lack of detailed work instructions.
M3.2 Review of Maintenance Work PackaoAS a.
lasoection Scone (627001
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The inspectors reviewed 16 work packages (work orders, maintenance procedures, etc.) to verify that maintenance activities for systems and components were being
.i conducted in a manner that resulted in the teliable and safe operation of the plant,
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Ohicnation:Landl_tadings The inspectors found the content of the work packages appropriate at the time of istue for repair and replacement of plant equipment. However, as noted in Section M 1.2 of this report, some out of-date vendor technicalinformation and incorrect replacement material problems were encountered during the implementation of maintenance activities. The inspectors noted that the licensee issued condition reports and implemented a quality actinq tecm to address the out of date vendor technical manual and incorrect replacement materi6l problems that were identified.
c.
Csuclusions The inspectors enneluded that, except for the licensee identified out-of-dato vendor technical information and incorrect replacement material problems, the reviewed work packages were appropriately prepared for the subject maintenance activities.
M4 Maintenance Staff Knowledge and Performance M4.1 McChanical and Electrical Stall a.
InSDec. tion 3cnDc. (62700]
The inspectors reviewed work control and procedures in crder to understand the hcensee's work control and validation process, The inspectors observed the various maintenance activities noted in Section M1.1 of this report, associated with safety related component removal, as-found testing, disassembly, troubleshooting, repair, replacement, and post maintenance testing. The inspectors assessed licensee and contractor personnel knowledge and performance in this area during observation of wark control and planning meetings, maintenance activities, and during discussions with maintenance contractor and licensee personnel, b.
OhicLYAtions and Findings The inspectors attended dail/ work control and planning meetings to observe how emergent maintenance activities were handled. The inspectors observed portions of the maintenance activities performed by the mechanical and electrical staff in accordance with the work orders listed in Section M1.1 of this report. The inspectors also observed portions of othei maintenance activities, such as minor maintenance activities, during tours of the plant. Minor maintenance work was
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identified as work of such minor nature that work instructions were not required.
Knowledgeable and skilled maintenance personnel had the work package instructions available at the work sites, when required, and were performing their activities in accordance with the available work instructions or by " skill of the craf t."
Supervisors were present, or were closely monitoring most of the work activities observed.
c.
Conclusions T he inspectors concluded that the observed work control and planning meetings and maintenance activities were performed in accordance with the appropriate procedural requirements by knowledgeable and skilled personnel under appropriate guidance and supervision.
M7 Quality Assurance in Maintenance Activities M 7.1 Reviaw of SclhAhsc15ments Activitics a.
InsperlionStone (40500)
i The inspectors reviewed selected assessments and audits to evaluate the effectiveness of the licensee's self assessment capability. The inspectors discussed the findings with licensee personnel to determine if the corrective actions and recommendations that resulted from the assessments and audits were adequate and were completed in a timely manner.
b.
Qbietutions and Findirigs The inspectors found that the majority of the self bssessments were thorough and critical of maintenance department processes. Some of the areas covered by the self assessments included training, work control, preventive maintenance, and maintenance prccedures and documentation.
The inspectors sampled some of the recommendations from recent self assessments and determined that corrective action responsibilities had been assigned. The inspectors noted that the status of the corrective actions were tracked in an informal managernent open items list. The inspectors reviewed licensee Memorandum GIN 97: 01040, " Update to Management Open l' ems List." dated July 21,1997, which documented the status of the management open items list, and noted the following:
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For the " Grand Gulf Nuclear Station Maintenance Department Assessment,"
SA 96 40, issued October 4,1996, approximately 38 management open items assigned to various groups for action were being tracked on the management open items list. The due dates for these 38 management open items had bqen extended at least once. The last entered due date for these 38 management open items was June 1,1997, and as of July 21,1997, they were still open.
As of July 21,1997, the maintenance departmant had been assigned
responsibility for approximately 61 management open items and the due dates for 42 of these open items had been extended at least once. There were 54 open items past their due dates and still open as of July 21,1997.
Th' inspectors discussed these overdue management open items with vuious licensee representatives. Licensee representatives noted that while they were working these management open items, which were past the informal management open item list due dates, higher priority work was preventing closure of these items.
A review of the management open items did not identify any item that appeared to be a plant operational concern.
c.
Conclusions While the reviewed assessments were found to be appropriate, the licensee did not appear to be aggressively following up on recent assessment findings and recommendations identified as management open items for the maintenance area.
M7.2 ManaQumenLQbservation Prqgt.an)
a.
InSRection Scong_L4Q50Q)
The inspectors reviewed the licensee's management observation p;ogram, implemented to provide management observations of the overall work process associated with specific tasks, identify potential problems, and suggest improvements. This review assessed the program's contribution to the licensee's corrective action program. The inspectors interviewed supervisors and other personnelin the mechanical and electrical maintenance departments to determine if the work observation program was implemented.
l b.
Qbservations_and Findinas f
On June 18,1997, the licensee formalized a management work observation program by issuing nonsafety-related Procedure 01-S-0312. " Work Observation Program," Revision O. The i:.spectors reviewed Procedure 01-S-03-12. The
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34-procedure required each department / group to designate an observatiun coordinator who would be assigned the task of scheduling observations to be performed by supervisors, superintendents, managers, and other designated personnel, in addition, the observation coordinator was assigned the responsibility for trending observation results and providing department heads with a periodic summary of the observation results.
As of August 8,1997, maintenance department personnelinformed the inspectors that the new work observation program, and ways to implement it, had been discussed at various meetings, but that the program was not fully implemented, c.
Conclusions The inspectors concluded that the licensea had formalized an excellent tool for assessing and, where necessary, improving the quality of work performance.
However, the inspectors also noted that the work observation program was not fully implemented.
L. Management Meetings X1 Exit Meeting Summary The inspectors presented the inspection results to members of licenseo mar,agement at the conclusion of the inspection on August 22,1997. The licensee personnel stated that they wa ited to further explore all the identified violations. The licensee personnel did not question the accuracy of the information presented, but disagreed with the inspectors conclusions that the conditions were violations of the cited requirements.
The inspectors asked the licensee personnel whether any material examined during the inspection were proprietary. No proprietary :nformation was identified.
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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Litemeo C. Abbott, Quality Supervisor, Quality Programs W. Brown, Fire Trainer, Training Department M. Cumbest, Fire Protection Engineer, Nuclear Plant Engineering B. Eaton, General Manager, Plant Operations W. Garner, Audits Supervisor, Quality Programs J. Hagan, Vice President, Grand Gulf Nuclear Station C. Hayes, Director, Quality Programs B. Hicks, Fire Protection Coordinator, Operations K. Hughey, Director, Nuclear Safety and Regulatory Affairs R. Moomaw, Manager, Plant Maintenance J. Venable, Manager, Operations NRC Jennifer Dixon Herrity, Senior Resident inspector INSPECTION PROCEDURES USED 40500 Ef fectiveness of Licensee Contrds in Identifying, Resolving, and Preventing Problems 62700 Maintenance Program implementation ITEMS OPENED, CLOSED, AND DISCUSSED Onened 9718 01 NCV Failure to perform conuition report operability evaluation for slow control rods, Section 01.2 9718 02 VIO Inadequate corrective actions for inoperable emergency lighting, Section 01.2 9718 03 VIO Failure to report numerous fire protection program deficiencies, Section 07.2 I
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Closed 9718 01 NCV Failure to perform condition report operability evaluation for slow control rods, Section 01.2
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DOCUMENTS REVIEWED P.Losedutch 01-S-013, " Plant Safety Review Committee," Revision 102 01 S 03 9, *GGNS Corrective Action Review Board," Revision O 01 S 0310, "GGNS Conditic,n Report (CR)," Revision 0 01-S 0312, " Work Observation Program," Revision 0 01 S-05 4, " Control of Vendor / Technical Manuals," Revision 14 (TCN15)
01 S 06 5, " Incident Reports / Reportable Events," Revision 103 01 S-06 44, " Operability Determination," Revision 101 01 S 07-1, " Control of Work on Plant Equipment and Facilities," Revision 31 (TCN89)
01 S 181, " Work Planning and Coordination," Revision 0 07 S-01205, " Conduct of Maintenance Activities," Revision 102 07 S 1718, " Predictive Maintenance Program," Revision 0 09 S 0310, " Industry Operating Experience Review Program," Revision 3 09 S-0314. " Administration Of ISEG Activities," Revision 100 G2.501, " Safety Review Committee," Revision 6 QV 103, " Corporate Sponsored Self Assessment Process," Revision 1
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A11P.tSSIneDis and Audits Document number GIN 97 00424, "NS&RA Report OA 97 01, Assessment of the Leading Edge Flowmeter (LEFM) Flow Measuring System," dated March 10,1997 Document number GIN 97-00929, "NS&RA Report OA 97 03, Assessment Of The Furmanite Process (SER 97-05)," dated May 5,1997 Document number GIN 96 02992, "NS&RA Report OA 9610, RF08 Post Outage Critique,"
drited Decernber 18,1996 Document number GIN 96-02842, "NS&RA Report OA 96 08, Safety Assessment Of Shutdown Cooling issues," dated November 20,1996 Document number GIN 96-02787, "NS&RA Report OA 96-09, Scrams & Forced Shutdowna within 60 Days Following a Refueling Outage," dated November 15,1996 Document number Giu 96/02570, " Maintenance Supervisor Training Self Assessment Report," dated October 16,1996 Self assessment 96 40, " Grand Gulf Nuclear Station Maintenance Department Assessment," dated October 4,1996 Self assessment 96-41, " Grand Gulf Nuclear Station Organization and Administration Assessment," dated September 19,1996 Self Assessment " Grand Gulf Nuclear Station (Operations) Training Program Self Assessment," dated May 1997 Grand Gulf Nucleaf Station, Quality Programs Surveillance, GIN 97/01204, " Review of Non-Licensed Operator Rounds " June 24,1997 Grand Gulf Nuclear Station, Quality Programs Department Audits Group, GIN 97/01181,
" Protective Tagging Assessment Report" June 10,1997 Grand Gulf Nuclear Station, Health Physics Assessment, " Surveys, Condition Reports, Radiation Work Permits, and Lost and Damaged Dosimetry Reports," July 10,1997 Grand Gulf Nuclear Station, Operations Assessment, July 15 19,1996 GIN 97: 00765, " Quality Systems Audit Report OPA 09,0197," April 14,1997
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Condition Reoorts
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1996 0134 00 Standby Diesel Generator 1P75EOO1/.
1996-0213 00 Containment isolation Valve 1E51F077 1996 0300-00 RHR Check Valve 1E12F050A 1996-0447-00 Standby Diesel Generator 1P75EOO18 1996 0592 00 Standby Diesel Generator 1P75EOO1 A 1997 0013 00 RHR Valve Positioner 1E12R130A and Solenoid Valve 1E12F530A 1997-0013 01 Removal of Parts from Permanent Plant Equipment 1997-0014 00 Standby Diesel Generator 1P75E001B 1997-0171-00 Standby Diesel Generator 1P75E0018 1997-0292 00 HPCS Valve Actuator E22F015 1997 0319 00 Refueling Water Pump 1P11 COO 2B 1997 0417 00 Wire-Brushing on Contaminated Bell Reducer 1997 0458 00 Standby Diesel Generator 1P75E001 A Fuel Oil Piping 1957-0491 00 Process Deficiencies With Material Procurement 1*'97-0867-00 Instrument Air Compressor SP53-C001 1997 0909-00 Instrument Air Compressor SP53 C001 1997-0242 00 During performance of division i diesel generator monthly surveillance, operator skipped from Step 5.3.3 to 5.3.5 of procedure 06 OP-1P75 M 0001-03 1997-0193 00 Door lef t unsecured 1997-0176 00 During an on shif t technical review of Protective Equipment Clearance GG 97-0308, it was discovered that the tagging boundary was not adequate l
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1996 0013 00 Eighteen examples of configuration control problems 1996 0070-00 SSW pump performance declines af ter rebuild 1996 0110 03 Unable to confirm correct bolt material grade for MOV operator upper bearing housing covers 1996 0179 01 Slow CRD response time 1996 0257-00 Drain valve in N4 ?A001 drain line not shown on Print M 1121 nor included in sol 04101 N421 1996-0256-00 MSL drain valve F016 went closed af ter 821K003B replacement during MWO 163683 performance (logic was never reset)
1996-0248 00 The Radwaste handling crane was operated multiple times over the period of 8/11/96 to 10/24/96 with an information tag that stated
"Do not operate" 1996-0158-00 Door lef t unsecured 1996-0130-00 P44F009C was found closed during filling and venting of CCW HX ("C" valve was restored to incorrect position)
1996 0112 00 The incorrect radiation monitor reading was recorded and verified for liquid radiological waste discharge batch Number 145 1996-0076-00 TS TRM requirements of LCO 96-0990. Channel check surveillance requirements can be met by reading the associated trip units, however the wrong trip units were specified on the information tag posted 1996-0002-00 Two red tags hao components restored not in accordance with the sol position 1996-0006 00 Tuo cases of equipment being out of position 1996-0007 00 Two valves out of sol position P71-FA55 cooler drain for the CRD maintenance f acility found open 1996-0378-00 Red tag clea.ance sheet and red tag for Valve 1E32F003J indicate the valve is open, the valve is closed
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6-r 1996 0471 00 Relief Valve SS15S647 not installed on original primary water LW cooler and not shown on drawing but shown installed by vendor manual 1996 0476-00 DC Busses 11DK and 11DL deenergized using wrong procedure 1996 0512 00 Operations surveillance procedure not updated following implementation of a design chan00 1996-0513 00 Requirement to stroke Valves 1E12F024A and 1E12F0248 riat entered on the test / retest control forms 1996 0517-00 During startup following RF08, CST level went below CRD pump suction connection causing loss of suction and multiple HCU accumulator f aults and a scram 1996 0548 00 Document control not notified to install drawing changes as required per 01 S-06 3 for temporary ALT 95-0011 1996 0558-00 RHR 'A' line break alarm received and LCO 96 1287 was initiated.
New ' Normal' value is established af ter each refuel outage. Not understanding the impact of not obtaining this data in the required time period has caused problems 1996 0574-00 Insecure Door 1996-0599 00 Security keys removed from site 1997 0016-00 Attachment VI of 01-S-07-9 (plant services containment start up inspection report) was not completed before plant start-up as required by Step 3.3.1J of 03101 1 which was completed by operations 1997 0026 00 Red tag was cleared from red tag program with tags still in place in the field 1997 0027 00 As part of RE ATS work activities, the WO for E12F290A was ATS'ed and LCO 970051 generated and held in the control room. Prewritten LCO for F290A only documented the feedwater feakage control TS and not the primary containment isolation valve TS 1997-0064-00 Painter entered the CAA and RHR 'C' without logging onto RWP 1997-0069-00 Door will not secure properly
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1997-0070-00 Partial clearance for Red Tag f 970124, tags 13 and 14 had the verifier sign off completec without the performer spar.e sign off
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completed 1997 0146 00 Fire barrier deficiency, %" diameter through wall hose
1997-0180-00 Fire brigade fire drill exceeds specified frequency limit 1997-0218 00 Fire barrier deficiencies, eight %" diameter through wall holes, two 3/8" diameter through wal: holes, and missing conduit seal 1997-222 00 120 condition ioentifiers had not been fully assigned 1997-0243-00 Division separation cr;teria violated by blocking open cover of penetration enclosure bcx 1997-0261-00 Design fire wall penetration no-w 1997 0916 00 Failure to perform conditien r
,u.ubility evaluation Condition identifiers 006207
" Perform preventive maintenance un standby diesel generator room fan motor 1 X77C001 B" 020220
" Hydraulic control unit (1C11D001MM) for HCU 48-49 contu.' rod drive, requires rework" 051668
" Inspect RHR A discharge header check valve 1E12F050A and rework valve as required" 057535
" Packing le3k on RHR A heat exchanger bypass valve 1E12F048A"
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058564
"ESF switchgear room couler supply line drein valve 1P41F230 leaks past seat" 058938
" Water leaking upstream of root valve for standby diesel generator auxiliary jacket water pump discharge pressure indicator 1P75R050A" 061139
" Air contrclier pulled off RHR A heat exchanger level control valve 1E12F065A" l
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8-g 062449
"There appears to be an abandoned wire termination for standby diesel generator engine 1P75E001 A" 063222
" Service air compressor SP52C0018 has higher than normal vibration, h
Compressor needs to be rebuilt" 063427
" Minor jacket water leak at the 90 degree dresser coupling over the number 6 right bank cylinder of standby dicsci generator engine 1P75EOO1 A" 063481
" Repair fuel oil pipe supports for standby diesel generator engine 1P75E001A" 063545
"It appears thai standby service water pump COO 1 A relief valve 1P41F299A is not lif ting" 064610
"lnerument air compressor SPS3 COO 1 ha3 a high frequency second stage axial vibration, indicating a 2nd stage thrust bearing problem" 064704
"While troubleshooting Division 1 standby diesel generator instrument panel
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1H22P400 control fuse f ailure, annu iciator came in" l
066132
" Division 1 "andby diesel generator.notor driven compressor air dryer air trap 1P75D024B is stuck open, not allowing receiver tank to reach set pressure" 066134
" Division 1 stundby diesel generator tube oil outlet temperatuce trip switch 1P75NC33A tripped" 066146
" Light fixture inside Division 1 standby diesel generator instrument panel 1H22P400 is missing the glass and metal globe" 066147
" Division 1 standby diesel generator engine 1P75E001 A jacket water dresaer
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coupling over number 6 right bank cylinder is leaking excessively" 066182
" Door sticking open, Please fix before another operator gets a SDR" 065909
" Northeast corner, second cable tray penetration has some type of brown fluid /t.ubstance on the penetration material that looks like it came from cable tray. Investigate and clean penetration" 065760
" Perform recertification of valve B21 160811 using nitrogen as the test medium. Seat reccnditioning will also be required af ter testing" l
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9-065874
" Valve B331833F1084 - Handwheel retaining nut is missing on valve needs to be replaced" -
065368
" Valva C11 1C11F083 - Replace Upper bearing housing cover eyebolts and/or un approved buiting with approved fasteners" 066216
" Valve C11 1C11F164A - Has no positior, indication" 064761
" Pump C41 1C41C0018 - Inspect pump stuffing box. Oil / water under box area. May be concern" 064931
"XCabnt C51 1C51J001D - TIP 'D' sticking during withdrawa' and insertion.
Also, TIP 'D' is slow during movement" 065921
"APRM 'E' give half scram when taken out of bypass. No inop on !ocal panel or any signs of f ault. Need to investigate problem" 066213
" Level indicator 1C61R400B is reading at high end of acceptance band when compared with 1C61R400A per 06 OP-1C61-M-0001" 064964
"EHC fit.id dripping from press point instrument block, appears to be very small leak" 064966
"EHC fluid leaking from press point instrument block, appears to be very sma!! leak" 064798
" Annunciator C821C82J122 RONAN Number 1 is sealed,in on this module.
Identified during shif t togs and records 02-S-01-5" 064766
" Relay found to bc tripped along with 12?N 2, conditions do not exist. 152-1704 open at the Mme relay found tripped found by operator doing normal rounds" 065519
" Valve N11 1N11F009 - was documented to have an on-line leak repair adapter stillinstalled on the packing gland. The adapter is to be removed and replaced with a 3/8" furmanite plug" 065920
" Valve N11 1N11F003B is leaking / blowing steam. Furmanite did not hnid" 066171
" Valve N221N22FA28 (manual) hardie has f allen off valve. Handle is kept near valve as valve cannot be opened without it" 065695
" Valve P21 SP21F077 is leaking by into the CST at a rate of about 1 GPM"
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"On 7 25 97 at 1500 hr Div 2 Diesel was air rolled and the motor driven air comp did not start on low press. The after cooler did start. The breaker was cycled twice to get the compressor to start. We suspect the thermal overload device needs to be recalibrated" 064968
"Several cables in cable tray with open ends" 065162
" Valve manifolds are installed incorrectly. The test ports are not lined up with the instrument when isolated from the precess" 065943
" Motor is leaking oil and water. Kossen contacted to repair" 065952
" Heat Exchanger SX47B002 f ail to start upon initiation" 065752
" Perform recirtification of valve B21 1601818 u.cing nitrogen as the test medium. Seat reconditioning will also be required after testing" 065360
" Replace upper bearing housing cover eyebolts and/or un-approved bolting with approved fasteners" 065878
" Filter choke alarm received. Filter needs te be replaced" 065639
" Replace SSPV including coils during sequence exchange on 7/12/97. SSPV has surf ace corrosion identified on Cl 64467. This Cl written to separate SSPV from other HCU work" 065699
" Valve pegged high indicating greater than 16 GPM flow'
065722
"Levelindication is increasing with no water addition. Bubbler needs blowing out" 065972
" Dual indication (OPEN and CLOSE) for 1E12F048A on remote shutdown panel with valve full opun" 065407
" Remove valve, replace seat, and reinstall valve per SFC work package 9-06000-300 during RF09" 061826
"1T92S222A emergency light found on, would not cut off" 06:048
"1Z92S001-A emergency light does not work" 062871
"1Z92S3028 emergency light did not work when tested"
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064800
"FZOS40 fire detector is in alarm on the fire computer with no local problems" 065685
"FZ1572 fire detector is in alarm on the fire computer /wont reset.. alarm carne in during perf o. 06-OP-SP64 R 0002" 065779
"FZ1230 doctor fire alarm in for no apparent reason" 065457
"FZO931 came into alarm approx.14 times during saif t briefing. This i. a distraction for control room business" 065938
" Trouble alarm came in on fire computer for no apparent reason, No alarm or fire lights on at panel" Maintenance Work Order Packaags 00157899
" Rework hydraulic control unit (1C11D001MM) for HCt.148-49 Control Rod Drive" 00164743
" Inspect RHR A discharge header check valve 1E12F050A and rework valve as 'equired" 00172029
" Adjust packing on RHR A heat exchanger bypass valve 1E12F048A" 00175152
" Correct coupling water leak for standby diesel generator auxiliary jacket water puma discharge pressure indicator 1P75R050A" 00175602
" Repair EvF switchgear room cooler supply line drain valve 1P41F230" 00179951
" Reinstall air controller on RHei A heat exchanger level control valve 1E12F065A" 00183350
" Investigate as-built wiring configuratic, for standby diesel generator engine 1P75E001A" 00183495
- Perform preventative maintenance on standby diesel generator room f an motor 1X77C001B" 00185456
" Correct jacket water leak (dresser couplings /etc.) on standby diesel generator engine 1P75E001 A" 00185492
" Repair fuel oil pipe supports for standby diesel generator engine 1P75E001A" l
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12-00185673
" Repair standby service water pump C001 A relief valve 1P41F299A" 00187660
" Rebuild second stage of instrument air compressor SP53 COO 1" 00187890
" Troubleshooting Division 1 standby diesel generator instrument panel 1H22P400 control fuse f ailure" 00191700
" Repair Division 1 standby diesel generator motor driven compressor air dryer air trap 1P75D024B" 00191701
" Troubleshoot Division 1 Otandby diesel generator tube oil temperature trip switch 1P75NO33 A" 00191757
" Repair Division 1 standby diesel generator engine 1P75E001 A jacket water leak at dresser coucling" Other Documents Document Qate Subiect/ Title Numbat GIN 37: 01040 07/21/97
" Update to Management G,can items List" GEXO 97/00872 07/21/97
"SRC Meeting Minutes for Meeting 97-02" GEXO 97/00730 04/15/97
"SRC Meeting Minutes for Meeting 97-01" GIN /01352 07/29/97
" Quarterly Summary of Plant and Industry Operating Experience" GIN 96: 03042 12/16/96
" Annual Audit Schedule" GIN 96: 03062 12/17!96
"1997 Audit Program Plan" GIN 97: 01488 8/04/97
" Review of Condition Reports Greater Than Two Years Old" NO DOCUMENT NUMBER 07/28/97
"GGNS Site Focus Meeting Monthly Agenda" NO DOCUMENT NUMBER MISC. DAYS " Daily Plant Status Report" Grand Gulf Nuclear Gererating Statica Updated Final Safety Analysis Report, Section 9.5.1,
" Fire Protection System," Revision 10.
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i-13-Grand Gulf Nuclear Generation Station Technical Requirements Manual Section 6.2, " Fire Systems," Revision 6.
" Amendment 82 to Facility Operating License NPF-29, Grand Gulf Nuclear Station Unit 1.
Regarding the Fire Protection Program (TAC No. 77505)," dated August 23,1991.
Specification M-500.0, " Grand Gulf Nuclear Station Fire Hazards Analysis," 3evision 9.
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