IR 05000416/2005009
| ML051610707 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 06/10/2005 |
| From: | Laura Smith Division of Reactor Safety IV |
| To: | Gerald Williams Entergy Operations |
| References | |
| IR-05-009 | |
| Download: ML051610707 (24) | |
Text
une 10, 2005
SUBJECT:
GRAND GULF NUCLEAR STATION -- NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000416/2005009
Dear Mr. Williams:
On April 28, 2005, the Nuclear Regulatory Commission (NRC) completed a team inspection at your Grand Gulf Nuclear Station. The enclosed report presents the results of this inspection.
On March 25, 2005, we discussed the preliminary inspection results with Mr. W. Brian and other members of your staff. The team continued in-office document reviews and conducted a final exit meeting with Mr. M. Krupa and other members of your staff on April 28, 2005.
This inspection examined activities conducted under your license as they relate to the identification and resolution of problems, compliance with the Commissions rules and regulations and with the conditions of your license. The team reviewed approximately 150 condition reports, apparent cause and root cause analyses, as well as supporting documents. In addition, the team reviewed cross-cutting aspects of NRC and licensee-identified findings and interviewed personnel regarding the safety-conscious work environment.
On the basis of the sample selected for review, the team concluded that your processes to identify, prioritize, evaluate, and correct problems were generally effective; thresholds for identifying issues remained appropriately low and, in most cases, corrective actions were adequate to address conditions adverse to quality. The team concluded that a positive safety-conscious work environment existed at Grand Gulf.
The report documents two findings that were evaluated under the significance determination process as having very low safety significance (Green). The NRC determined that one violation was associated with these findings. The violation is being treated as a noncited violation because it was of very low safety significance and because it has been entered into your corrective action program consistent with Section VI.A of the Enforcement Policy. If you contest the violation or the significance of the noncited violation, you should provide a response within 30 days of the date of the inspection report, with the basis for your denial, to the U.S.
Nuclear Regulator Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Grand Gulf facility.
Grand Gulf Nuclear Station -2-In accordance with 10 CFR 2.390 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 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).
Sincerely,
//RA//
Linda Joy Smith, Chief Engineering Branch 2 Division of Reactor Safety Dockets: 50-416 Licenses: NPF-29
Enclosure:
Inspection Report 05000416/2005009 w/Attachment: Supplemental Information
REGION IV==
Dockets: 50-416 Licenses: NPF-29 Report No.: 05000416/2005009 Licensee: Entergy Operations, Inc.
Facility: Grand Gulf Nuclear Station Location: Waterloo Road Port Gibson, Mississippi 39150 Dates: March 7 through March 25, 2005; Exit April 28, 2005 Inspectors: G. L. Guerra, Senior Resident Inspector, South Texas Project G. B. Miller, Senior Resident Inspector, Grand Gulf G. W. Johnston, Senior Operations Engineer, Region IV G. F. Larkin, Resident Inspector, Waterford 3 H. A. Freeman, Senior Allegations Coordinator, Region IV G. D. Replogle, Senior Reactor Inspector, Region IV Approved by: L. J. Smith, Chief Engineering Branch 2 Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
IR 05000416/2005009; 3/7/05 - 4/28/05; Grand Gulf Station; biennial baseline inspection of the identification and resolution of problems. A violation and one finding was identified in the area of problem identification, evaluation, and effectiveness of corrective actions.
The inspection was conducted by two senior resident inspectors, a senior operations engineer, a senior reactor inspector, a resident inspector, and a senior allegations coordinator. Two Green findings of very low safety significance were identified during this inspection; one of which was classified as a noncited violation. The findings were evaluated using the significance determination process. The significance of most findings is indicated by their color (Green,
White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
A. Identification and Resolution of Problems
- The team reviewed approximately 150 condition reports, apparent and root cause analyses, as well as other documents, to assess problem identification and resolution activities. Over the past two years (the assessment period) the team noted a few instances where problems were not properly identified, evaluated, prioritized or corrected but, overall, the licensees processes were effective.
Based on the interviews conducted, the team concluded that a positive safety-conscience work environment existed at Grand Gulf. The team determined that employees generally felt free to raise safety concerns to their supervision, the employee concerns program and the NRC. The team received a few isolated comments regarding: 1) a reluctance to use the site employee concerns program; 2)production pressure; and 3) the impact of staff reductions on work load and the ability to identify safety issues. Nonetheless, the interviewees all believed that potential safety issues were being addressed. The team determined that licensee management was aware of the perceptions and was taking action to address them.
B. Inspector-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- (Green) The inspectors identified a 10 CFR 50, Appendix B, Criterion XVI violation for the failure to take prompt corrective actions to address a degraded control room air conditioning unit (a condition adverse to quality). Since 1999, Grand Gulf engineers were aware that the Division I control room emergency air conditioning unit could not remove the required heat load under design basis conditions. The engineers failed to take prompt corrective measures to address the problem, because they did not have an accurate understanding of system requirements. The inspectors also identified that the licensee failed to properly address system operability on two occasions, as operability justifications were based on inaccurate or non-applicable information. This issue had cross-cutting aspects in the area of problem evaluation and prioritization.
The failures to: 1) promptly correct a condition adverse to quality; and 2) properly evaluate equipment operability were performance deficiencies. The finding had more than minor significance because it affected the reactor safety mitigating systems objective to ensure the availability of systems that respond to initiating events. The finding was of very low risk significance because it was a design/qualification deficiency that did not result in a loss of function per Generic Letter 91-18, Information to Licensees Regarding NRC Inspection Manual Section on Resolution of Degraded and Nonconforming Conditions, Revision 1 (Section 4OA5).
Cornerstone: Emergency Preparedness
- (Green) The team documented a self-revealing finding for the licensee's failure to take prompt and effective corrective measures to address an emergency operations facility diesel generator failure. The diesel failed to start during two loss of power events to the emergency operating facility. Corrective measures following the first event were not timely. This issue had crosscutting aspects associated with problem identification and resolution.
The failure to take effective corrective measures to address an inoperable emergency operations facility diesel generator was a performance deficiency. This issue is greater than minor because it affected the emergency preparedness cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect public health and safety in the event of a radiological emergency. This issue did not meet the entry conditions for the emergency preparedness significance determination process because it did not constitute a non-compliance with emergency preparedness requirements. Per NRC Manual Chapter 0612, Power Reactor Inspection Reports, dated January 14, 2004, NRC management performed a significance review to ensure that the issue was of very low safety significance (Section 4OA2e(2)ii).
Licensee-Identified Violations
None
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Identification and Resolution of Problems
The team based the following conclusions on their independent inspection and review of issues that were identified by others, during the assessment period. The assessment period ranged from April 3, 2003 (the last biennial problem identification and resolution inspection) to the end of the onsite inspection on March 25, 2005. The examples are divided into two groups. The first group (Current Issues) includes problems that were identified during the assessment period where the performance deficiency also occurred during the same period. The second group (Historical Issues) includes issues that were identified during the assessment period but all the performance deficiencies occurred outside the period of interest.
a. Effectiveness of Problem Identification
- (1) Inspection Scope The inspectors reviewed items selected across the seven cornerstones to determine if problems were being properly identified, characterized, and entered into the corrective action program. Specifically, the team reviewed plant logs and maintenance records and verified that conditions adverse to quality, identified in these processes, were also entered into the corrective action program. In addition, the team reviewed a sample of licensee audits and self assessments, trending reports, system health reports, and various other reports and documents related to the corrective action program.
The team interviewed station personnel and evaluated corrective action documentation to determine the licensees threshold for identifying problems. In addition, in order to assess the licensees handing of operator experience, the team reviewed the licensees evaluation of selected industry operating experience reports, including licensee event reports, NRC Generic Letters, Bulletins and Information Notices, and generic vendor notifications.
- (2) Assessment The team determined that most problems were properly identified and entered into the corrective action program. In a few instances plant personnel failed to initiate condition reports. Overall, however, the licensee maintained an effective problem identification program.
Current Issues Example 1: The NRC identified that operators on rounds had failed to identify unplugged heat traces to fire hose stations during prolonged freezing periods (NRC Inspection Report 05000416/2002006).
Example 2: The NRC identified, during a graded emergency preparedness drill, that the licensee had failed to follow the procedure for issuing potassium iodide to emergency workers. The licensee should have identified this problem during their critique (NRC Inspection Report 05000416/2003003).
Example 3: The licensee failed to initiate condition reports on several occasions when the animal intrusion fence was found de-energized or the gate to the 34.5 KV switchyard was found open. Consequently, on February 11, 2005, an animal crossed the boundary and caused a switchyard fault and reactor scram (self-revealing, see Section 4OA2e(2)i of this report).
Historical Issues Example 4: The licensee identified that they failed to properly address Information Notice 91-85, Potential Failures of Thermostatic Control Valves for Diesel Generator Jacket Cooling Water, December 26, 1991, which addressed limited service lives for certain temperature control valve temperature elements. Consequently, an element that had exceeded its service life was installed on the Division I emergency diesel generator jacket cooling water system. In addition, the same component on the Division III emergency diesel generator had exceed the recommended service life (NRC Inspection Report 05000416/2004004).
b. Prioritization and Evaluation of Issues
- (1) Inspection Scope The team reviewed condition reports and operability evaluations to assess the licensees ability to evaluate conditions adverse to quality. The team reviewed a sample of failure mode analyses, apparent cause analyses and root cause analyses to ascertain whether the licensee identified and considered the full extent of conditions, generic implications, common causes, and previous occurrences. The team also observed management oversight of significant conditions adverse to quality, including attendance at the Pre-Condition Review Group meeting.
In addition, the team reviewed licensee evaluations of selected industry operating experience information, including NRC Information Notices and industry provided information, to assess whether issues applicable to Grand Gulf were appropriately addressed.
The team performed a historical review of condition reports covering the last 5 years regarding the standby service water system and Agastat relay problems to determine if the licensee had appropriately addressed long-standing issues.
- (2) Assessment The team concluded that problems were generally prioritized and evaluated in accordance with the licensees corrective action program guidance and NRC requirements. The team found that for the sample of root cause analyses reviewed, the licensee was self critical and thorough when addressing significant conditions adverse to quality. However, issues related to poor problem evaluation and prioritization periodically challenged the licensee, as self-revealing and NRC identified problems continued to surface.
Current Issues Example 1: The NRC identified that the licensee failed to take prompt corrective actions to address a degraded control room air conditioning unit. The licensee had identified the nonconforming condition in 1999 but failed to correct the problem. In addition, two subsequent operability evaluations were inadequate because they were based on inaccurate or non-applicable information (See Section 4OA5 of this inspection report).
Example 2: The NRC identified that the licensee failed to properly evaluate/control the application of Agastat general purpose relays to ensure that they did not remain in service in excess of their recommended service life. Consequently, numerous relays suffered age related failures (NRC Inspection Report 05000416/2003002).
Example 3: The NRC identified that the licensee failed to properly evaluate Agastat relay failures, in that they did not identify the failure mechanism. Consequently, additional failures occurred (NRC Inspection Report 05000416/2003006).
Example 4: Corrective measures following a June, 2002 emergency operations facility diesel generator failure were not timely. Consequently, during a partial loss of offsite power event in August, 2003, the diesel again failed to start (self-revealing, see Section 4OA2e(2)ii of this report).
Historical Issues Example 5: The NRC identified that the licensee failed to promptly correct areas of known localized corrosion in the standby service water system piping. Consequently, leaks developed in the piping. (NRC Inspection Report 05000416/2004002).
Example 6: The licensee identified that they had failed to promptly correct corroded standby service water system pipe hangers. Subsequently, the hangers suffered from severe corrosion before they were repaired (NRC Inspection Report 05000416/2004004).
c. Effectiveness of Corrective Actions
- (1) Inspection Scope The team reviewed condition reports to verify that corrective actions were identified and implemented in a timely manner commensurate with safety, including corrective actions to address root cause or generic concerns. The team reviewed corrective actions planned and implemented by the licensee and sampled specific technical issues to determine whether adequate decisions related to structure, system, and component operability were made.
In addition, the team reviewed a sample of those condition reports written to address NRC inspection findings to ensure that the corrective actions adequately addressed the issues as described in the inspection reports. The team also reviewed a sample of corrective actions closed to other condition reports and programs, such as work requests, to ensure that the corrective actions were still adequate and timely.
- (2) Assessment The licensees corrective actions were generally effective at addressing the conditions adverse to quality. The licensee had identified that in some instances condition reports were closed to work orders and the work orders were inappropriately closed without action. The inspectors found no examples of a continuing problem during this inspection.
Current Issues Example 1: The NRC identified, during a graded emergency preparedness drill, that the licensee had not taken adequate measures to address recurring performance problems involving weak command and control in one emergency response facility and the untimely manning of another emergency response facility (NRC Inspection Report 05000416/2003003).
Example 2: Corrective actions to address a wild animal induced switchyard fault and reactor scram were inadequate. Following one such event on June 22, 2002, the licensee installed an electrified animal intrusion fence. However, plant personnel failed to re-energize the fence and/or close the gate on numerous occasions. Consequently, on February 11, 2005, an animal crossed the boundary and caused a switchyard fault and reactor scram (self-revealing, see Section 4OA2e(2)i of this inspection report).
Historical Issues None.
d. Assessment of Safety-Conscience Work Environment
- (1) Inspection Scope The team interviewed 20 individuals selected randomly from a variety of organizations within the licensees workforce including both supervisory and non-supervisory individuals. These organizations included maintenance, work planning, engineering, quality organizations and operations as well as others. The purpose of the interviews was to determine whether the licensee had established a safety-conscious work environment where workers felt free to raise safety concerns and pursue resolution without fear of retribution. In addition, the team reviewed a nuclear safety culture survey, conducted by an outside contractor for the licensee, and a safety culture assessment performed by the licensees corporate office.
- (2) Assessment The team concluded that a safety-conscious work environment existed at the Grand Gulf Nuclear Station. All individuals indicated that they felt comfortable raising and pursuing safety concerns. Individuals did not feel intimidated nor were they discouraged from writing condition reports. Individuals also indicated that they were willing to pursue resolution of their concerns to higher levels (even to the Site Vice President and/or the NRC if necessary). The team noted the following observations:
- While all individuals were aware of the Employee Concerns Program, few individuals mentioned the Employee Concerns Program as a viable option for pursuing safety concerns. In addition, some individuals perceived a lack of independence from management by the Employee Concerns Program.
- While all individuals believed that the plant was operated safely, many of the individuals stated that they felt a lot of pressure from management (whether stated or implied) to restore the unit online during an outage and some individuals felt that their ability to identify concerns had been impacted by increased workloads due to reductions in staff.
The team determined that licensee management was aware of the perceptions and was taking action to address them.
e.
Specific Issues Identified During This Inspection
- (1) Inspection Scope During the reviews described in sections 4OA2 a.(1), 4OA2 b.(1), 4OA2 c.(1), and 4OA2 d.(1) the team independently identified the following findings.
- (2) Findings and Observations i Unresolved Item 05000416/2005009-01: Corrective actions to prevent repetitive switchyard ground fault induced scrams
Introduction.
The team documented an unresolved item for inadequate corrective actions to address wild animal induced switchyard faults and reactor scrams. Following one such event on June 22, 2002, the licensee installed an electrified animal intrusion fence. However, on several occasions plant personnel failed to re-energize the fence and/or close the gate. Consequently, on February 11, 2005, an animal crossed the boundary and caused a switchyard fault and reactor scram. In addition, the licensee identified that plant personnel had found the fence de-energized and/or the gate open on several occasions but plant personnel failed to initiate condition reports to address the problems. The finding had cross-cutting aspects associated with problem identification and effectiveness of corrective actions.
Description.
The team reviewed an automatic reactor trip on February 11, 2005, caused by the loss of Bus 11R in the 34.5 kV switchyard. Bus 11R was lost when a raccoon caused a ground fault on the power feed downstream of Transformer ST11. The licensee concluded that no damage was caused to plant equipment. The team noted on June 22, 2002, a raccoon also caused a line to ground fault that resulted in a reactor scram due to loss of equipment powered by transformer ST21.
The licensee determined that the root cause of the June 22, 2002, event was inadequate barriers to prevent animals from intruding into the 34.5 kV switchyard. As a corrective measure, the licensee installed an electrified fence around the 34.5 kV switchyard to prevent future animal intrusion. The inspectors noted on June 20, 2003, and February 17, 2004 (CR-GGN-2003-1888 and 2004-0529) that personnel found the 34.5 kV switchyard electrical fence de-energized. As an additional corrective measure, the licensee notified operations and electrical maintenance personnel to reinforce expectations to keep the gate closed and the fence energized. The licensee also identified that, at other times, the gate was found open or the fence was de-energized but condition reports were not written to document the problems. Procedure EN-LI-102, Corrective Action Process, Revision 1, required that condition reports be written to address the adverse conditions.
Following the reactor scram, on February 12, 2005, the animal intrusion fence was again found turned off, and on February 14, 2005, the gate was again found open.
Analysis.
The failures to: 1) maintain the integrity of the animal intrusion fence to prevent initiating events; and 2) initiate condition reports when the animal intrusion fence was found de-energized (or the gate was found open) were performance deficiencies.
The finding was greater than minor because it affected the initiating events cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions. The team had not completed the significance determination at the close of the inspection. This issue is unresolved pending completion of inspection necessary to support a significance determination.
Enforcement.
The inspectors had not completed the enforcement review at the close of the inspection. This issue is unresolved for compliance pending completion of that review. (URI 05000416/2005009-01).
ii Finding 05000416/2005009-02: Inadequate corrective actions to address multiple emergency operations facility diesel generator failures
Introduction.
The team documented a Green self-revealing finding for the failure to prevent repetitive failures of the emergency operations facility diesel generator. The finding had crosscutting aspects in the area of problem prioritization.
Description.
On June 22, 2002, the emergency operations facility diesel generator failed to start in response to a loss of power to the facility. On August 28, 2003, the emergency operations facility suffered a similar loss of power and the diesel generator again failed to start. The diesel failed in both instances because the starting battery had an insufficient charge. The licensee determined that recommended corrective measures for the first failure, that included preventive maintenance tasks for the battery charger, were not implemented and could have prevented the second failure. The licensee determined that the diesel could have been restored to an operating status in approximately 2.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. Nonetheless, the diesel failure would have complicated the licensees emergency response to events involving a loss of offsite power.
Analysis.
The failure to take effective corrective measures to address an inoperable emergency operations facility diesel generator was a performance deficiency. This issue is greater than minor because it affects the emergency preparedness cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect public health and safety in the event of a radiological emergency. This issue did not meet the entry conditions for the emergency preparedness significance determination process because it did not constitute a non-compliance with emergency preparedness requirements. Per NRC Manual Chapter 0612, Power Reactor Inspection Reports, dated January 14, 2004, NRC management performed a significance review to ensure that the issue was of very low safety significance.
Enforcement.
No violation of regulatory requirements occurred. The finding did not represent a noncompliance because it occurred on nonsafety-related equipment and no emergency preparedness requirements were violated. This finding was entered into the licensees corrective action program as CR-GGN-2003-2527 (FIN 05000416/2005009-02).
4OA5 Review of Open Items
(Closed) URI 05000416/2004005-02: Inadequate Corrective Actions to Address Degraded Control Room Air Conditioning Unit.
Introduction.
The inspectors identified a 10 CFR 50, Appendix B, Criterion XVI violation for the failure to take prompt corrective actions to address a degraded control room air conditioning unit. Since 1999, Grand Gulf engineers were aware that the Division I control room emergency air conditioning could not remove the required heat load under design basis conditions but failed to take prompt corrective measures to address the problem. The inspectors also identified that the licensee failed to properly address system operability on two occasions, as operability justifications were based on inaccurate or non-applicable information. This issue had cross-cutting aspects in the area of problem identification and resolution.
Discussion. In 1999, as documented in CR-GGN-1999-0742, the licensee identified that the Division I control room air conditioning unit could not remove the required heat load under design basis conditions - the unit could not maintain the control room at less than or equal to 90 EF assuming a post-accident heat load. More recent surveillances, conducted on March 19, 2001; August 5, 2002; and February 5, 2004 identified the same problem. The calculations indicated that the control room temperatures would peak at approximately 95 EF and stay above 90 EF for about a week. The Updated Safety Analysis Report, Section 9.4.1.1.2, the Technical Requirements Manual, Section 6.7.3 Temperature Monitoring, and the Technical Specifications 3.7.4 Bases, Section 3.7.4.C.1 and C.2, identified 90 EF as the maximum unconditionally approved temperature for the control room equipment. In addition, Calculation MC-QSZ51-01001, Determination of Control Room Heat Load at 90 EF, Revision 0, and numerous control room equipment design documents identified 90 EF as the maximum control room temperature.
The team also identified that the existing operability determination was inadequate, because it was based on incomplete information. As documented in a Justification for Continued Operations, dated February 5, 2004, engineers stated that the operability limit for control room equipment was 120 EF based on Technical Requirements Manual statements (similar justification was contained in CR-GGN-1999-0742, dated July 20, 1999). The Technical Requirements Manual, Section 6.7.3, required that the equipment be declared inoperable at 120 EF. The team identified that engineers failed to properly consider another Technical Requirements Manual statement, in the same section, that required an operability assessment if the control room temperature exceeded 90 EF. No such operability assessment was performed to address temperatures between 90 EF and 120 EF.
In response to the teams concerns, the licensee performed an additional operability assessment, documented in CR-GGN-2004-4443. The inspectors determined that the second assessment was inadequate, as it was based on inapplicable information. The licensee based operability on a passage from the original NRC Safety Evaluation Report, Supplement 6. The passage stated: ...The NRC staff commented that surveillance requirements should include a requirement to verify that the control room air temperature is < 120 EF every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The licensee inferred from the passage that control room equipment remained operable at ambient temperatures up to 120 EF.
The inspectors identified that the passage did not apply to general control room equipment qualification or to the control room emergency air conditioning system itself.
The passage concerned the control room emergency filtration system, a different system.
In response to the inspectors continued concerns, the licensee performed a third operability evaluation. This evaluation was based on temperature studies performed by the Electric Power Research Institute. The studies demonstrated that electrical equipment, in general, should not be adversely impacted at the temperatures of concern. The inspectors found this operability assessment acceptable.
Analysis.
The failures to: 1) promptly correct a condition adverse to quality (degraded control room air conditioning unit); and 2) properly evaluate equipment operability were performance concerns. The finding had more than minor significance because it affected the reactor safety mitigating systems objective to ensure the availability of systems that respond to initiating events. The finding was of very low risk significance because it was a design/qualification deficiency that did not result in a loss of function per Generic Letter 91-18, Information to Licensees Regarding NRC Inspection Manual Section on Resolution of Degraded and Nonconforming Conditions, Revision 1.
Enforcement.
The team identified a 10 CFR 50 Appendix B, Criterion XVI (Corrective Actions) violation for the failure to promptly correct the degraded control room air conditioning unit (a nonconformance). 10 CFR 50, Appendix B, Criterion XVI (Corrective Action) requires that conditions adverse to quality, including nonconformances, be promptly corrected. Because the violation was of very low safety significance, and was entered into the licensees corrective action program (CR-GGN-2004-04443), this violation is being treated as an NCV, consistent with Section VI.A of the NRC Enforcement Policy (NCV 05000416/2005009-03).
4OA6 Exit Meeting
On March 25, 2005, the team discussed the preliminary findings with Mr. W. Brian, General Manager, Plant Operations and other members of the licensees staff. On April 28, 2005, the team conducted a final telephonic exit meeting with Mr. M. Krupa, Director, Nuclear Safety Assurance, as well as other members of the licensees staff.
The team reviewed some proprietary information during the inspection but that information was returned to the licensee prior to the exit.
4OA7 Licensee Identified Violations
NONE ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED Licensee R. Brian, General Manager, Plant Operations R. Collins, Manager, Operations E. Harris, Manager, Corrective Action and Assessment C. Hayes, Corporate Emergency Preparedness Project Manager M. Krupa, Director, Nuclear Safety Assurance J. Robertson, Manager, Quality Assurance T. Thornton, Manager, Design Engineering D. Wiles, Director, Engineering M. Withrow, Manager, Nuclear Engineering H. Yeldell, Manager, Maintenance NRC personnel R. Lantz, Senior Emergency Preparedness Inspector, DRS A. Barrett, Resident Inspector LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 05000416/2005009-01 URI Corrective actions for repetitive reactor scrams caused by animal intrusion to the switchyard (Section 4OA2e(2)i).
Opened and Closed 05000416/2005009-02 FIN Inadequate corrective actions to preclude repetitive emergency operations facility diesel failures (Section 4OA2e(2)ii). 05000416/2005009-03 NCV Inadequate Corrective Actions to Address Degraded Control Room Air Conditioning Unit (Section 4OA5).
Closed 05000416/2004005-02 URI Inadequate Corrective Actions to Address Degraded Control Room Air Conditioning Unit (Section 4OA5).
Discussed None.
LIST OF
DOCUMENTS REVIEWED
PLANT PROCEDURES
Procedure Title
01-S-06-2 Conduct of Operations, Revision 118
01-S-06-5 Reportable Events or Conditions, Revision 105
01-S-06-44 Operability Assessment, Revision 106
ENLI-102 Corrective Action Process, Revision 1
ENLI-118 Root Cause Analysis Process, Revision 0
ENLI-119 Apparent Cause Evaluation (ACE) Process, Revision 1
15-S-01-101 Conduct of Modification Activities, Revision 5
ENS-DC-112 Engineering Request and Project Initiation Process, Revision 3
ENN Operating Plant Changes and Modification, Revision 1
2-S-01-38 Protective Tagging, Revision 1
04-1-01-B33-1 Reactor Recirculation System, Revision 121
07-S-01-205 Conduct of Maintenance Activities, Revision 108
07-S-04-104 Guidelines for Diving Operations, Revision 3
ENS-DC-121 Maintenance Rule, Revision 2
ME-02 Protective Tagging, Revision 6
ME-09 Pre and Post Job Briefs, Revision 9
ME-19 Pre-Job Walkdowns, Revision 6
ME-25 Control and Monitoring of Maintenance Backlog, Revision 0
Condition reports (CR) :
CR-GGN-2005-00615 CR-GGN-2003-0096 CR-GGN-2004-1755
CR-GGN-2005-00840 CR-GGN-2003-0151 CR-GGN-2004-2011
CR-GGN-2005-00552 CR-GGN-2003-0504 CR-GGN-2004-2069
CR-GGN-2004-00529 CR-GGN-2003-0517 CR-GGN-2004-3339
CR-GGN-2002-01110 CR-GGN-2003-0822 CR-GGN-2004-3388
CR-GGN-2005-00544 CR-GGN-2003-1026 CR-GGN-2004-3390
CR-GGN-2003-3164 CR-GGN-2003-2055 CR-GGN-2004-3766
CR-GGN-2004-0192 CR-GGN-2003-2504 CR-GGN-2004-3986
Attachment
CR-GGN-2004-0331 CR-GGN-2003-2520 ER-2002-0426
CR-GGN-2004-1644 CR-GGN-2003-2987 ER 2004-0169
CR-GGN-2003-01888 CR-GGN-2003-0535
Effectiveness Reviews/Self Assessments MAIs / Work Orders
LO-GLO-2003-0012 327942
LO-GLO-2003-0080 327943
LO-GLO-2003-0122 328020
LO-GLO-2003-0146 41983
LO-GLO-2004-0125 50297524
LO-GLO-2004-0126 50316362
LO-GLO-2004-0184 50321402
Attachment
Information Request 1 - January 2005
Grand Gulf PI&R Inspection (IP 71152; Inspection Report 50-416/05-09)
The inspection will cover the period of March 1, 2003 to March 1, 2005. All requested
information should be limited to this period unless otherwise specified. The information may be
provided in either electronic or paper media or a combination of these. Information provided in
electronic media may be in the form of e-mail attachment(s), CDs, or 3 1/2 inch floppy disks.
The agencys text editing software is Corel WordPerfect 8, Presentations, and Quattro Pro;
however, we have document viewing capability for MS Word, Excel, Power Point, and Adobe
Acrobat (.pdf) text files.
Please provide the following information by January 21, 2005, to:
U.S. Nuclear Regulatory Commission
Resident Inspectors Office - Attn. Gilbert Guerra
South Texas Project Nuclear Operating Company
Miles West of Wadsworth, Tx. 77483
Note: On summary lists please include a description of problem, status, initiating date, and
owner organization
3. Summary list and a copy of all condition reports of significant conditions adverse to
quality opened or closed during the period
4. Summary list of all condition reports of conditions adverse to quality opened or closed
during the period
5. Summary list of all condition reports which were down-graded or up-graded during the
period
6. Summary list of operator work arounds, engineering review requests and/or operability
evaluations, temporary modifications, and control room and safety system deficiencies
7. A list of all corrective action documents that subsume or "roll-up" one or more smaller
issues for the period
8. List of all root cause analyses completed during the period
9. List of root cause analyses planned, but not complete at end of the period
10. List of plant safety issues raised or addressed by the employee concerns program
during the period
11. List of action items generated or addressed by the plant safety review committees
during the period
2. All quality assurance audits and surveillances of corrective action activities completed
during the period
Attachment
13. A list of all quality assurance audits and surveillances scheduled for completion during
the period, but which were not completed
14. All corrective action activity reports, functional area self-assessments, and non-NRC
third party assessments completed during the period
15. Corrective action performance trending/tracking information generated during the period
and broken down by functional organization
16. Current revision of the following procedures: LI-102, 01-S-03-9, 01-S-06-5, 01-S-06-44,
01-S-06-2, 01-S-06-5
17. Any additional governing procedures/policies/guidelines for:
a. Condition Reporting
b. Corrective Action Program
c. Root Cause Evaluation/Determination
d. Deficiency Reporting and Resolution
18. A listing of all external events and operating experience evaluated for applicability at
Grand Gulf during the period
19. Condition Reports or other actions generated for each of the items below:
1. Part 21 Reports
2. NRC Information Notices and Bulletins
3. All LERs issued by Grand Gulf during the period
4. NCVs and Violations issued to Grand Gulf during the period
20. Radiation protection event logs
21. Current system health reports or similar information
2. Current predictive performance summary reports or similar information
23. Corrective action effectiveness review reports generated during the period
Attachment
Information Request 2
Gilbert Guerra Geoff Miller Jim Drake Grant Larkin
2004-3800, 2003-2853, 2003-37, 2004-3899/3922,
NCV2004-05-03 NCV2004-03-02 1999-419, NCV2004-05-01
2004-1354, 2003-3353, 2000-1263, 2004-1644,
NCV2004-03-01 NCV2004-02-04 2002-620/2573, NCV2004-03-04,
2003-61, 2004-31, NCV2004-02-03 LER2004-02
LIV2002-06 NCV2004-02-01 2003-227, 2004-651,
2003-2913, 2004-2620/3352, NCV2002-06-01 NCV2004-02-02
LIV2003-04 LIV2004-04 2002-2426, 2004-1477,
2003-544, 2003-1729, NCV2003-02-01 NCV2004-03-03
NCV2002-06-02 LIV2003-02 2003-873, 2003-1347,
2003-504 2003-109 NCV2003-06-02 NCV2003-07-01
2003-1429 2003-168 2002-3085, 2004-2002
2003-2029 2003-2589 LIV2004-04 2004-1459
2003-2388 2004-2977 2003-300, ER2004-138
2003-2527 2004-4302 NCV2003-03, ECH2003-2
2003-2987 2003-1429 LER2003-01 2003-884
2004-495 2004-4062 2004-1990 2003-1270
2004-506 GLO2003-0080 ER2003-261 2003-2520
2004-502 GLO2003-0096 2003-352 2004-192
2004-331 GLO2003-0110 2003-350 2004-213
2004-1014 GLO2004-0074 2003-1340 2004-651
2004-1013 2003-1345 2004-767
2004-1122 2003-2378 2004-1435
2004-2892 2003-3589 2004-1557
2003-3089 2004-580 2004-2593
2004-210 2004-2575 2003-853
2004-603 2003-1395 2003-1974
2004-3351 2003-1609 2003-2388
GLO2003-0053 2003-2636 2004-555
GLO2004-0016 2003-3577 2004-647
GLO2004-0104 2004-942 2004-1477
2004-1013 2004-1703
2004-2048 GLO2003-0094
2004-2977 GLO2003-0194
Attachment
Additional Information Request 3
Gilbert Guerra Geoff Miller Gary Johnston Grant Larkin
2003-2388 2004-2166 2004-1937
2004-569 2004-4074
2004-1579
2004-442
2003-2750
ER2004-236
2004-640
2003-1732
2003-1753
2003-1953
2003-2386
2003-2444
2003-3363
2003-3640
2004-772
2004-1016
2004-1443
2004-1671
2004-1754
2004-2336
2004-2350
2004-2867
2004-3077
2004-3439
2004-3893
2004-4049
2004-4298
2004-4416
LO-ELO2003-143
Attachment