IR 05000416/2002002

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IR 05000416-02-002, on 03/31/2002 - 06/29/2002, Entergy Operations, Inc., Grand Gulf Nuclear Station. Maintenance Risk Assessments and Emergent Work Evaluation, Permanent Plant Modifications, Identification and Resolution of Problems
ML022000275
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 07/19/2002
From: Johnson W
NRC/RGN-IV/DRP/RPB-A
To: Eaton W
Entergy Operations
References
IR-02-002
Download: ML022000275 (25)
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Text

uly 19, 2002

SUBJECT:

GRAND GULF NUCLEAR STATION NRC INSPECTION REPORT 50-416/02-02

Dear Mr. Eaton:

On June 29, 2002, the NRC completed an inspection at your Grand Gulf Nuclear Station. The enclosed report documents the inspection findings which were discussed on July 3, 2002, with you and other members of your staff.

This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.

There were three findings of very low safety significance (Green) identified in the report.

The NRC has increased security requirements at Grand Gulf Nuclear Station in response to terrorist acts on September 11, 2001. Although the NRC is not aware of any specific threat against nuclear facilities, the NRC issued an Order and several threat advisories to commercial power reactors to strengthen licensees capabilities and readiness to respond to a potential attack. The NRC continues to monitor overall security controls and will issue temporary instructions in the near future to verify by inspection the licensee's compliance with the Order and current security regulations.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Entergy Operations, Inc. -2-Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

/RA/

William D. Johnson, Chief Project Branch A Division of Reactor Projects Docket: 50-416 License: NPF-29 Enclosure NRC Inspection Report 50-416/02-02 cc w/enclosure:

Executive Vice President and Chief Operating Officer Entergy Operations, Inc.

P.O. Box 31995 Jackson, Mississippi 39286-1995 Wise, Carter, Child & Caraway P.O. Box 651 Jackson, Mississippi 39205 Winston & Strawn 1400 L Street, N.W. - 12th Floor Washington, DC 20005-3502 Sam Mabry, Director Division of Solid Waste Management Mississippi Department of Natural Resources P.O. Box 10385 Jackson, Mississippi 39209 President, District 1 Claiborne County Board of Supervisors P.O. Box 339 Port Gibson, Mississippi 39150

Entergy Operations, Inc. -3-General Manager Grand Gulf Nuclear Station Entergy Operations, Inc.

P.O. Box 756 Port Gibson, Mississippi 39150 The Honorable Richard Ieyoub Attorney General Department of Justice State of Louisiana P.O. Box 94005 Baton Rouge, Louisiana 70804-9005 Office of the Governor State of Mississippi Jackson, Mississippi 39201 Mike Moore, Attorney General Frank Spencer, Asst. Attorney General State of Mississippi P.O. Box 22947 Jackson, Mississippi 39225 Dr. F. E. Thompson, Jr.

State Health Officer State Board of Health P.O. Box 1700 Jackson, Mississippi 39215 Robert W. Goff, Program Director Division of Radiological Health Mississippi Dept. of Health P.O. Box 1700 Jackson, Mississippi 39215-1700 Vice President Operations Support Entergy Operations, Inc.

P.O. Box 31995 Jackson, Mississippi 39286-1995 Director, Nuclear Safety and Regulatory Affairs Entergy Operations, Inc.

P.O. Box 756 Port Gibson, Mississippi 39150

Entergy Operations, Inc. -4-Electronic distribution by RIV:

Regional Administrator (EWM)

DRP Director (KEB)

DRS Director (EEC)

Senior Resident Inspector (TLH4)

Branch Chief, DRP/A (WDJ)

Senior Project Engineer, DRP/A (CJP)

Staff Chief, DRP/TSS (PHH)

RITS Coordinator (NBH)

Scott Morris (SAM1)

GG Site Secretary (MJS)

Dale Thatcher (DFT)

R;\_GG\2002\GG2001-02RP-RWD.wpd RIV:RI:DRP/A SRI:DRP/A SPE:DRP/A C:CRP/A RWDeese TLHoeg CJPaulk WDJohnson WDJohnson for WDJohnson for /RA/ /RA/

07/12/02 07/12/02 07/19/02 07/19/02 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 50-416 License: NPF-29 Report No: 50-416/02-02 Licensee: Entergy Operations, Inc.

Facility: Grand Gulf Nuclear Station Location: Waterloo Road Port Gibson, Mississippi 39150 Dates: March 31 through June 29, 2002 Inspectors: T. L. Hoeg, Senior Resident Inspector R. W. Deese, Acting Senior Resident Inspector C. J. Paulk, Senior Project Engineer Approved By: W. D. Johnson, Chief, Project Branch A Division of Reactor Projects Attachment: Supplemental Information

SUMMARY OF FINDINGS IR 05000416-02-02, on 3/31/02 - 06/29/02; Entergy Operations, Inc., Grand Gulf Nuclear Station. Maintenance risk assessments and emergent work evaluation, permanent plant modifications, identification and resolution of problems.

The inspection was conducted by resident inspectors and a senior project engineer. The inspectors identified three Green findings. The significance of any findings are indicated by their color (Green, White, Yellow, or Red) using IMC 0609 "Significance Determination Process." Findings for which the Significant Determination Process does not apply are indicated by No Color or by the severity level of the applicable violation. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described at its Reactor Oversight Process website at http://www.nrc.gov/NRR/OVERSIGHT/index.html.

A. Inspector Identified Findings Cornerstone: Initiating Events

  • Green. Grand Gulf Nuclear Station engineers failed to perform an adequate technical evaluation for Engineering Request 1997-0615-0000 to address the removal of lubricating water flow from upper internals of circulating water Pump A, which had a zero leakage packing installed on the pump shaft. This failure resulted in an unanticipated rise in pump vibrations after commencing maintenance, and placed the plant in a condition where, for 4 minutes, alarm response procedures directed reducing power and securing circulating water Pump A. Condition Report GGNS 2002-0768 was written to document this finding.

This finding is more than minor because it was a precursor to a significant event and could have increased the frequency of an initiating event. However, the safety significance was very low (Green) because although an emergency down-power was called for by procedure, increased licensee oversight allowed the operators to restore lubrication and cooling water quickly enough to mitigate the rise in pump vibration eliminating the need for the emergency down-power necessitated by securing the circulating water pump (Section 1R17).

Cornerstone: Mitigating Systems

  • Green. Work control center personnel failed to assess and manage the increase in risk for scheduled main steam line flow transmitter maintenance with control rod drive system maintenance already in progress. Concurrent performance of these maintenance jobs would have resulted in the licensee unknowingly placing the plant in a much higher risk condition. Condition Report GGNS 2002-0684 was written to document this inspector finding.

This finding is more than minor because it had a potential to create a higher risk condition than was anticipated by the work control center personnel. However, the safety significance was very low (Green) because, upon recognition of the potential for a higher risk condition, work control center personnel canceled the main steam line flow transmitter maintenance and the two maintenance activities were never performed concurrently (Section 1R13).

-2-Cornerstone: Barrier Criteria

  • Green. Nondestructive examination personnel failed to perform periodic inspections of a residual heat removal system non-Code repair location, preventing them from determining the rate or extent of future degradation to the elbow location, contrary to the non-Code repair commitment made to the NRC. Condition Report GGNS 2002-0597 was written to document this finding.

The finding is more than minor because, following the non-Code piping repair, the nondestructive examination personnel did not have the required ultrasonic test information to diagnose further piping degradation, and may not have taken the appropriate action prior to the development of another residual heat removal system piping through-wall leak. The safety significance of this finding was very low (Green)

because, although the elbow wall thickness was not inspected, the subject train was not relied upon for extended operation and the final ultrasonic test results showed no measurable elbow wall thinning (Section 4OA2).

B. Licensee Identified Findings None

Report Details Summary of Plant Status: The plant was operated at or near 100 percent rated thermal power except for periodic planned power reductions for monthly control rod exercising and periodic control rod pattern adjustments until June 1, 2002, when a partial loss of feedwater heating necessitated a down-power to 60 percent of rated power for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. Following the recovery of feedwater heating, the plant returned to 100 percent power and remained there until an automatic scram was received on June 22, 2002. The plant was restarted on June 25, 2002, and returned to full power on June 27, 2002, where it remained for the remainder of this inspection period.

1. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity 1R01 Adverse Weather Protection (71111.01)

a. Inspection Scope The inspectors reviewed one sample of the Grand Gulf Nuclear Station (GGNS)

personnels preparations for hot weather conditions for the standby service water and fire protection water systems before the onset of summer. This review included walkdowns of the systems focusing on hot weather susceptibilities, reviews of the systems designed ventilation and cooling features, and a review of the licensees actions to ensure these systems remain operable in hot weather.

The inspectors reviewed the sites readiness for potential tornado strikes during the spring when these weather events were more likely. Specifically, the inspectors reviewed Engineering Report GGNS-93-0048, "Grand Gulf Nuclear Station Engineering Report for High Wind and Tornado Assessment for Individual Plant Examination for External Events," Revision 0, and Calculation CC-Q1111-94004, "Probabilistic Evaluation of Tornado Missile Strike for Individual Plant Examination for External Events Study," Revision 1, to determine if GGNS personnels assumptions were still valid for the sites vulnerability to tornado damage in light of an increased number of potential tornado missiles generated on site by recent auxiliary cooling tower construction and the tear down and removal of the sites Bechtel building.

b. Findings No findings of significance were identified.

1R04 Equipment Alignment (71111.04)

a. Inspection Scope The inspectors performed partial system walkdown inspections and reviews of a train in each of three systems important to reactor safety in order to verify the operability of the systems. The inspectors reviewed system operating instructions, system valve and breaker lineups, operator logs, and system control room indications. The inspectors also verified valves, breakers, and control circuits were in their required positions for operability. The following systems were inspected:

-2-

  • Suppression pool makeup system, Train A b. Findings No findings of significance were identified.

1R05 Fire Protection (71111.05Q)

a. Inspection Scope The inspectors reviewed area fire plans and performed walkdowns of nine plant areas to assess the materiel condition and operational status of fire detection, suppression systems and equipment; the materiel condition of fire barriers; and the control of transient combustibles. Specific risk-significant plant areas included:

  • Auxiliary building corridor - elevation 139 feet, Corridor 1A301
  • Auxiliary building corridor - elevation 185 feet, Corridor 1A401
  • Central alarm station, Room OC604
  • Control building stairwell, Stair OC01
  • Piping penetration room, Room 1A220
  • Unit 2 switchgear room, Room OC214
  • Upper cable penetration room, Room OC702 b. Findings No findings of significance were identified.

1R06 Flood Protection (71111.06)

a. Inspection Scope The inspectors reviewed one sample of the GGNS's internal flooding protection features dealing with the potential flooding of the circulating water pump area and its likelihood of initiating a unplanned down-power event. The inspectors performed a walkdown of the area, reviewing internal flooding vulnerabilities and the protective features installed to mitigate the impact of any flooding.

b. Findings No findings of significance were identified.

-3-1R07 Heat Sink Performance (71111.07A)

a. Inspection Scope The inspectors reviewed a video of the GGNS personnels inspection of spent fuel pool Pump A room Cooler T51B007A, to assess the cleanliness of the heat exchanger. The inspectors also reviewed the trend data for the standby service water system chemistry analyses to assess the effectiveness of the GGNSs biological fouling controls for the standby service water system.

b. Findings No findings of significance were identified.

1R11 Licensed Operator Requalification (71111.11Q)

a. Inspection Scope On April 25, 2002, the inspectors observed operator requalification training activities in the simulator to assess GGNS personnels effectiveness in evaluating the requalification program and to ensure that licensed individuals received the appropriate level of training required to maintain their licenses. The observed training consisted of a loss of the Class 1E electrical Bus 21, followed by a steam leak in the drywell, in accordance with GGNSs licensed operator training scenario Procedure GSMS-LOR-AEX22, "Loss of Service Transformer 21 With a Steam Leak in the Drywell," Revision 0.

b. Findings No findings of significance were identified.

1R12 Maintenance Rule Implementation (71111.12Q)

a. Inspection Scope The inspectors reviewed performance-based problems involving six selected in-scope structures, systems, or components (SSCs) to assess the effectiveness of the Maintenance Rule Program. Reviews focused on: (1) proper Maintenance Rule scoping in accordance with 10 CFR 50.65; (2) characterization of failed SSCs; (3) safety significance classifications; (4) 10 CFR 50.65 (a)(1) and (a)(2) classifications; and, (5) the appropriateness of performance criteria for SSCs classified as (a)(2), and goals and corrective actions for SSCs classified as (a)(1). The inspectors reviewed the most recent system health reports and system functional failures for the last 2 years. The following SSCs were reviewed:

  • Control room heating, ventilation, and air conditioning system
  • Engineered safety features electrical switchgear rooms cooling system
  • Process radiation monitoring system

-4-

  • Standby service water system, Train B b. Findings No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation (71111.13)

a. Inspection Scope Throughout the inspection period, the inspectors reviewed weekly and daily work-schedules to determine when risk-significant activities were scheduled. The inspectors discussed six selected activities with operations and work control personnel regarding risk evaluations and overall plant configuration control. The inspectors discussed emergent work issues with work control center personnel and reviewed the prioritization of scheduled activities. The inspectors verified the performance of plant risk assessments related to planned and emergent maintenance activities as required by 10 CFR 50.65(a)(4) and plant Procedure 01-S-18-6, "Risk Assessment of Maintenance Activities," Revision 1.

Specific maintenance items reviewed during this period included:

  • MAI 312878, Train B RHR system
  • MAI 313967, Division II engineered safety features diesel generator b. Findings The inspectors identified a green finding when the work control center personnel failed to assess and manage the added risk associated with performing maintenance on main steam line flow instrumentation.

On April 16, 2002, the GGNS personnel were performing maintenance on control rod drive system Pump A which had been tagged out of service and appropriately assessed for risk. The inspectors noticed the work control center personnel had scheduled maintenance on the Main Steam Line B Channel 2C high flow transmitter for later that day without calculating its contribution to risk to plant safety.

Prior to these maintenance activities, work control center personnel had performed a risk assessment which only included the control rod drive pump maintenance. This risk assessment evaluated the plant as being in an acceptable risk condition. The work control center personnel did not assess the effect of the addition of the main steam line flow transmitter maintenance on plant risk. Prior to the work control center personnel authorizing work on the flow transmitter, the inspectors questioned the adequacy of the

-5-risk assessment. The inspectors concluded that the work control center personnel had not assessed the risk of concurrently performing both the control rod drive and main steam line maintenance activities. The work control center personnel confirmed the inspectors observation that the combination of the two maintenance activities would have placed the plant in a higher risk condition, requiring additional guidance and contingency planning to perform the work. The work control center personnel subsequently canceled the main steam line flow transmitter maintenance because, as a practice, they do not voluntarily enter higher risk conditions and had not met their procedural requirements for managing maintenance activities in that higher risk configuration.

The inspectors determined that the failure to assess the risk more than minor because it had a potential to create a higher risk condition than was anticipated by the work control center personnel. However, the safety significance was very low (Green) because, upon recognition of the potential for a higher risk condition, work control center personnel canceled the main steam line flow transmitter maintenance and the two maintenance activities were never performed concurrently. The finding affected the mitigating systems cornerstone and did not screen as potentially risk significant due to a seismic, fire, flooding, or severe weather initiating event and therefore is considered a Green finding.

GGNS personnel entered this deficiency into their corrective action program as Condition Report GGNS 2002-0684. No violation of regulatory requirements occurred.

1R14 Personnel Performance During Nonroutine Events (71111.14)

a. Inspection Scope On June 22, 2002, GGNS received an automatic reactor scram signal and shutdown. A raccoon climbed on the grounding transformer on the 34.5 kV side of Service Transformer 21, one of the two 500 kV dedicated offsite feeder transformers for the site, and created a phase-to-ground current path which actuated protective relays for the transformer that removed the offsite feeder from service. As a result, the main turbine electro-hydraulic control system experienced a dip in pressure which acted to fast close the turbine control valves and scram the reactor. The inspectors responded to the plant and observed plant operations personnel placing the reactor plant in a shutdown condition and reviewed nuclear steam supply system responses to the scram. The inspectors reviewed Procedures 03-1-01-4, "Scram Recovery," Revision 106, and 03-1-01-3, "Plant Shutdown," Revision 110, and observed operator actions for procedural compliance.

The inspectors reviewed unexpected system responses, including the failure of the emergency operations facility emergency diesel generator to start, the failure of control room air conditioning system Train B to automatically load on the Division II emergency diesel generator, and the failure of the reactor protection system Channel C high pressure scram alarm to annunciate. The inspectors also reviewed operator actions with regard to 10 CFR 50.72 and 10 CFR 50.73 reporting requirements. GGNS personnel actions were documented in Condition Report GGNS 2002-1105.

-6-b. Findings No findings of significance were identified.

1R15 Operability Evaluations (71111.15)

a. Inspection Scope The inspectors selected four operability evaluations conducted by GGNS personnel during the report period involving risk-significant SSCs. The inspectors evaluated the technical adequacy of the operability determinations, determined whether appropriate compensatory measures were implemented, and determined whether GGNS personnel considered all other pre-existing conditions, as applicable. Additionally, the inspectors evaluated the adequacy of GGNSs problem identification and resolution program as it applied to operability evaluations. Specific operability evaluations reviewed are listed below.

  • CR-GGN-2002-1011, Diesel driven fire pumps b. Findings No findings of significance were identified.

1R16 Operator Workarounds (71111.16)

.1 Review of Selected Operator Workarounds a. Inspection Scope The inspectors evaluated significant operator workarounds to determine if the functional capability of the system or human reliability in responding to an initiating event was affected. The inspectors evaluated the effect of operator workarounds on the operator's ability to implement applicable abnormal and emergency operating procedures. The following workaround was reviewed:

  • Significant Operator Workaround No. 3, dated 3/30/99. Ladders must be used to operate RHR Valves E12-FO24 A and B.

b. Findings No findings of significance were identified.

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.2 Review of the Cumulative Effects of Operator Workarounds a. Inspection Scope The inspectors evaluated the cumulative effects of all the plants significant operator workarounds for the following attributes: (1) the reliability, availability, and potential for misoperation of safety-related systems; (2) the ability of the operators to respond in a correct and timely manner to plant transients and accidents; and (3) the potential for increasing an initiating event frequency or affecting multiple mitigating systems.

b. Findings No findings of significance were identified.

1R17 Permanent Plant Modifications (71111.17A)

a. Inspection Scope The inspectors reviewed the modification to remove a flow indicator from the lubricating water line to the circulating water pumps as described in Engineering Request (ER) 1997-0615-0000, Evaluate trip function of the Circ Water pump," Revision 0.

The inspectors verified that: (1) the design bases, licensing bases, and performance capability of the component would not be degraded as a result of the modification; (2) the modification did not place the reactor plant in any unsafe conditions; and, (3) adequate postinstallation testing was performed to verify the modification functioned as expected.

b. Findings Initiation of an unanticipated down-power event nearly occurred when GGNS personnel attempted to complete a modification to the circulating water pump lubricating water system. The inspectors considered the incomplete technical evaluation for implementation of the modification a Green finding.

On April 30, 2002, GGNS personnel were performing a design change as documented in ER 1997-0615-0000, "Evaluate Trip Function of the Circ Water Pump," Revision 0, to remove an old flow indicator from the lube water system supply to circulating water Pump A. The lubricating water system provides clean water to the upper circulating water pump bearing for lubrication and to the pump stuffing box for cooling. In order to remove the flow indicator, GGNS personnel had to align the lubricating water system such that the circulating water Pump A would have no lubrication or cooling water flow.

The GGNS engineers justified the removal of all lubrication and cooling water flow through conversations with the pump vendor and incorrectly concluded that packing leakage from the circulating water pump packing would be sufficient to lubricate, cool, and vent the pump internals, even though this packing was designed to be a zero-leakage packing. Additionally, the GGNS engineers had not quantified the actual packing leakage.

-8-Attention was given to the pump stuffing box temperature which was specially instrumented during the maintenance to check for any unforseen temperature rises.

The GGNS engineers did not expect any effect on pump bearing vibrations because they did not analyze the effects of removal of lubricating water flow to the pump internals with a zero-leakage packing installed. Specifically, the GGNS engineers did not fully consider the magnitude of any increase in temperature or the effect on bearing vibration.

Shortly after removal of the lubricating water flow and a period of monitoring temperature, the maintenance began for the implementation of the modification. The GGNS personnel then observed a significant rise in stuffing box temperature from 91 to 165EF and pump upper bearing vibrations increased from 10.5 mils to 19.45 mils (which is above the alarm setpoint of 14 mils). GGNS personnel concurrently restored lubricating water flow and entered Alarm Response Instruction 04-1-02-1H13-P680-10A-E12, "Circulating Water Pump A Vibration High,"

Revision 121, which instructs operators to reduce reactor power and secure the circulating water pump at 18 mils. Pump vibration was above 18 mils for approximately 4 minutes while the operators were preparing to reduce reactor power. The bearing vibration returned to an allowable level and alarm response was no longer required.

The maintenance activity was being treated as an infrequently-performed-evolution and was being closely monitored by licensee personnel. This allowed the operators to quickly back out of the maintenance lineup and restore lube water flow upon the escalation of troubling indications. Temperatures and vibrations lowered to levels acceptable for continued circulating water pump operation after operator action. This alert action averted initiating a plant transient event.

The inspectors determined that this lack of technical justification was a precursor to a significant event that could have increased the frequency of an initiating event, therefore impacting the initiating events cornerstone. The inspectors determined that the finding did not increase the likelihood of fire or flooding and, therefore, considered this a Green finding.

GGNS personnel immediately backed out of the maintenance and canceled similar maintenance planned for Train B of the lubricating water system. GGNS personnel documented this discrepancy in Condition Report GGNS 2002-0824. Maintenance personnel later performed the maintenance during a forced outage which allowed the circulating water pumps to be secured while performing the maintenance. No violation of regulatory requirements occurred.

1R19 Postmaintenance Testing (71111.19)

a. Inspection Scope The inspectors reviewed postmaintenance test procedures and associated testing activities for six selected risk-significant mitigating systems. In each case, the associated work orders and test procedures were reviewed against the attributes in Inspection Procedure 71111, Attachment 19, to determine the scope of the maintenance

-9-activity and determine if the testing was adequate to verify equipment operability. The reviewed activities were:

C MAI 307430, Division II engineered safety features switchgear fan C MAI 313014, Division I standby service water flow indicator C MAI 313885, Reactor recirculation pump hydraulic power Unit A, Subloop 2 oil pump C MAI 313967, Division II emergency diesel generator temperature switch C MAI 314390, Drywell chiller skid Unit A C MAI 314765, Division II standby service water system basin level b. Findings No findings of significance were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope The inspectors observed performance of surveillance test procedures and reviewed test data of five selected risk-significant SSCs to assess whether the SSCs satisfied the Technical Specifications, the Updated Final Safety Analysis Report, the Technical Requirements Manual, and licensee procedural requirements; and, to determine if the testing appropriately demonstrated that the SSCs were operationally ready and capable of performing their intended safety functions. The following tests were inspected:

Revision 101

  • 06-RE-SB13-V-0017, "Reactivity Anomalies," Revision 102
  • 06-OP-1C41-M-0001, "Standby Liquid Control Operability," Revision 108 b. Findings No findings of significance were identified.

-10-1R23 Temporary Plant Modifications (71111.23)

a. Inspection Scope The inspectors reviewed the temporary alterations listed below to assess the following attributes: (1) the adequacy of the safety evaluation; (2) the consistency of the installation with the modification documentation; (3) the updating of drawings and procedures, as applicable; and, (4) the adequacy of the postinstallation testing.

  • No. 2002-003, Division II emergency diesel generator jacket water cooling temperature switch b. Findings No findings of significance were identified.

4. OTHER ACTIVITIES (OA)

4OA1 Performance Indicator Verification (71151)

a. Inspection Scope The inspectors verified the accuracy and completeness of the data used to calculate and report performance indicator information for two indicators from the second calendar quarter 2001 through the first calendar quarter 2002. The inspectors used Nuclear Energy Institute 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 2, as guidance and interviewed licensee personnel responsible for compiling the information.

4OA2 Identification and Resolution of Problems (71152)

a. Inspection Scope The inspectors reviewed corrective actions associated with the recent American Society of Mechanical Engineers (ASME) non-Code repair case of a piping elbow in Train A of the RHR system minimum flow line to the suppression pool.

-11-b. Findings The inspectors identified a Green finding resulting from the failure of nondestructive examination personnel to implement a schedule of ultrasonic testing that was committed to as part of obtaining NRC approval of an ASME non-Code repair on RHR system Train A.

On May 9, 2001, GGNS personnel identified a pin hole leak in the Train A of the RHR system minimum flow line at a piping elbow location in the auxiliary building. The leak resulted from flow accelerated corrosion which was not previously monitored in this elbow area. The pin hole leak created a potential open pathway from the containment suppression pool to the auxiliary building. On May 11, 2001, a GGNS representative requested NRC authorization to use ASME Non-Code Repair Case N-561-1 to repair the leak using a weld overlay on the pipe elbow.

On May 12, 2001, following a verbal authorization from the NRCs Office of Nuclear Reactor Regulation, GGNS maintenance personnel performed the weld repair to the piping and returned the system to service. The weld repair was authorized by the NRC with an understanding that it was a temporary repair method for the identified leak and that the elbow containing the leak would be replaced prior to startup from the next refueling outage. Additionally, the NRC understood that GGNS personnel would perform periodic followup inspections of the repaired area with nondestructive examination ultrasonic testing to determine the rate or extent of future degradation.

On April 2, 2002, the inspectors met with GGNS personnel to discuss flow accelerated corrosion of RHR system piping and existing compensatory actions associated with the recent non-Code repair. The inspectors understood that GGNS Standing Night Order 2001-18 directed shift personnel to log all Train A RHR pump starts and to initiate a maintenance activity to perform nondestructive examination following every three pump starts in order to comply with the non-Code repair case. The inspectors determined that eight pump starts had been recorded by the licensee since August 2, 2001, without performing the required nondestructive examination. GGNS personnel initiated Condition Report GGNS 2002-0597 to document this condition.

The failure of the nondestructive examination personnel to perform periodic inspections of the RHR system non-Code repair location prevented nondestructive examination personnel from determining the rate or extent of future degradation to the elbow location which was contrary to the NRCs understanding, as identified in the June 21, 2001, letter approving the use of the non-Code repair case. The inspectors determined this failure to meet the subject examinations to be a finding.

The finding was more than minor because, following the RHR non-Code piping repair, GGNS personnel did not have the required nondestructive examination information, nor the ability to diagnose further piping degradation, and may not have taken the appropriate action prior to the development of another RHR piping through-wall leak.

The safety significance of this finding was very low (Green) because, although the elbow wall thickness was not inspected, the subject train was not relied upon for extended

-12-operation and the final nondestructive examination results showed no measurable elbow wall thinning. No violation of regulatory requirements occurred.

4OA3 Event Followup (71153)

(Closed) Unresolved Item 05000416/2001-007-01, "Notice of Enforcement Discretion from Technical Specification 3.8.1 Required Action B.4 for Division II Emergency Diesel Generator" (Closed) Licensee Event Report 50-416/02-001-00, "Follow-up to Division II Diesel Generator Notice of Enforcement Discretion" The inspectors reviewed: the apparent cause, as identified by GGNS personnel; the corrective actions identified in Condition Report 2002-0555; the safety assessment; and the reporting requirements associated with Licensee Event Report 50-416/02-001-00 and Notice of Enforcement Discretion 02-4-001. The inspectors did not identify any findings of significance. This licensee event report is closed. Also, Unresolved Item 05000416/2001-007-01, associated with the Notice of Enforcement Discretion 02-4-001, is closed.

4OA6 Meetings, including Exit On July 3, 2002, the acting senior resident inspector presented the inspection results to Mr. W. Eaton, Vice President of Operations, and members of his staff.

The inspector asked if any materials examined during the inspections should be considered proprietary. No proprietary information was identified by the licensee.

ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED Licensee C. Abbott, Quality Assurance Supervisor D. Barfield, Manager, System Engineering R. Barnes, Manager, Training and Development C. Bottemiller, Manager, Plant Licensing K. Christian, Superintendent, Mechanical Maintenance W. Deck, Security Superintendent W. Eaton, Vice President, Operations J. Edwards, General Manager, Plant Operations C. Ellsaesser, Manager, Corrective Action and Assessment M. Guynn, Manager, Emergency Preparedness R. Moomaw, Manager, Outage Planning and Scheduling J. Roberts, Director, Nuclear Safety Assurance J. Robertson, Manager, Quality Assurance E. Rogers, Manager, Site Support M. Rohrer, Manager, Maintenance G. Sparks, Manager, Operations D. Wiles, Director, Engineering R. Wilson, Superintendent, Radiation Protection H. Yeldell, Manager, Design Engineering NRC T. Hoeg, Senior Resident Inspector R. Deese, Resident Inspector C. Paulk, Senior Project Engineer ITEMS OPENED, CLOSED, AND DISCUSSED Closed 05000416/2001-007-01 URI Notice of Enforcement Discretion from Technical Specification 3.8.1 Required Action B.4 (Section 4OA3)

05000416/2002-001-00 LER Voluntary LER for NOED 02-4-001 (Section 4OA3)

02-4-001 NOED Division II Emergency Diesel Generator

-2-LIST OF DOCUMENTS REVIEWED Procedures:

01-S-18-6, "Risk Assessment of Maintenance Activities," Revision 1 01-S-07-43, "Control of Loose Items, Temporary Electrical Power and Access to Equipment,"

Revision 3 04-1-01-E12-1, "Residual Heat Removal System Operating Instruction," Revision14 04-1-01-N71-1, "Circulating Water System Operating Instruction," Revision 60 04-1-02-1H13-P680-10A-B12, "Circulating Water Pump A Lube Water Trouble," Revision 134 06-RE-SB13-V-0017, "Reactivity Anomalies," Revision 102 08-S-03-10, "Chemistry Sampling Program," Revision 32 MP-AD-SR-01, "Material Issues and Returns," Revision 3 10-S-04-4, "Performance Indicators," Revision 2 Condition Reports:

1999-0232 2002-0552 2002-0620 2002-0725 2001-0285 2002-0553 2002-0622 2002-0726 2001-0303 2002-0555 2002-0624 2002-0755 2001-0393 2002-0587 2002-0644 2002-0768 2002-0044 2002-0588 2002-0658 2002-0803 2002-0081 2002-0589 2002-0661 2002-0826 2002-0540 2002-0600 2002-0679 2002-0857 2002-0543 2002-0604 2002-0680 2002-1003 2002-0544 2002-0618 2002-0684 2002-1011 2002-0551 2002-0619 2002-0724 Maintenance Action Items:

275413 300302 303672 309299 313702 295851 301703 305035 311966 298634 302589 306211 313022 299185 302684 308068 313461

-3-Maintenance Work Orders 00079761 00117030 00127585 00217453 Other Miscellaneous Documents:

Drawing C-1500, "Unit 1 Diesel Generator Building 12 Reinforced Concrete Plan Foundation Mat at Elevation 133-0"," Revision 15 Engineering Request 2000-0792-000, "Auxiliary Cooling Tower Modification," Revision 0 Engineering Request 96-0731, "Circulating Water Pump Stuffing Box Refurbishment,"

Revision 0 Grand Gulf Maintenance Rule Desktop Guide and Scoping Documents Material Tracking Report for Stock Code GG82152005, dated June 11, 2002 Purchase Order MP416712 Security Operations Bulletin 37

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