IR 05000416/2008004

IR 05000416-08-004, on 06/22/2008 - 09/21/2008, Grand Gulf, Maintenance Effectiveness, Maintenance Risk Assessments and Emergent Work Control, and Problem Identification and Resolution

ML082910566
Person / Time
Site:	Grand Gulf
Issue date:	10/17/2008
From:	Geoffrey Miller NRC/RGN-IV/DRP
To:	Douet J R Entergy Operations
References
EA-08-295 IR-08-004
Preceding documents:	ML083390752 (4 December 2008)
Download: ML082910566 (48)

Text

October 17, 2008

EA-08-295 James R. Douet, Vice President of Operations Grand Gulf Nuclear Station Entergy Operations, Inc. P.O. Box 756 Port Gibson, MS 39150

SUBJECT: GRAND GULF NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000416/2008004

Dear Mr. Douet:

On September 20, 2008 the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Grand Gulf Nuclear Station. The enclosed report documents the inspection results, which were discussed on September 29, 2008, with you and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

One violation is cited in the enclosed Notice of Violation and the circumstances surrounding this violation are described in detail in the enclosed report. The violation involved your failure to perform an adequate inspection of probable maximum precipitation door seals protecting safety-related equipment (EA-08-295). Although determined to be of very low safety significance (Green), this violation is being cited because not all the criteria specified in Section VI.A.1 of the NRC Enforcement Policy for a noncited violation were satisfied. Specifically, Grand Gulf Nuclear Station failed to restore compliance within a reasonable time after the violation was first identified in NRC Inspection Report 05000416/2008002. Please note that you are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements. This report documents two additional NRC identified findings of very low safety significance (Green). Both of these findings were determined to involve violations of NRC requirements. However, because of the very low safety significance and because they were entered into your corrective action program, the NRC is treating these findings as noncited violations consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the subject or severity of a noncited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Entergy Operations, Inc. - 2 -

Administrator, U.S. Nuclear Regulatory Commission - Region IV, 612 E. Lamar Blvd, Suite 400, Arlington, TX 76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Grand Gulf Nuclear Station. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Geoffrey Miller Chief Projects Branch C Division of Reactor Projects Docket: 50-416 License: NPF-29

Enclosure:

Inspection Report 05000416/2008004

w/Attachment:

Supplemental Information

cc w/enclosure Senior Vice President Entergy Nuclear Operations P.O. Box 31995 Jackson, MS 39286-1995 Senior Vice President and COO Entergy Operations, Inc. P.O. Box 31995 Jackson, MS 39286-1995 Vice President, Oversight Entergy Services, Inc. P.O. Box 31995 Jackson, MS 39286-1995 Chief, Energy and Transportation Branch Environmental Compliance and Enforcement Division Mississippi Department of Environmental Quality P.O. Box 10385 Jackson, MS 39289-0385 President Claiborne County Board of Supervisors P.O. Box 339 Port Gibson, MS 39150 Senior Manager Nuclear Safety & Licensing Entergy Nuclear Operations P.O. Box 31995 Jackson, MS 39286-1995 Manager, Licensing Entergy Operations, Inc. Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150 Attorney General Department of Justice State of Louisiana P.O. Box 94005 Baton Rouge, LA 70804-9005

Entergy Operations, Inc. - 3 -

Office of the Governor State of Mississippi Jackson, MS 39201 Attorney General Asst. Attorney General State of Mississippi P.O. Box 22947 Jackson, MS 39225-2947 State Health Officer State Health Board P.O. Box 1700 Jackson, MS 39215 Associate General Counsel Entergy Nuclear Operations P.O. Box 31995 Jackson, MS 39286-1995 Richard Penrod, Senior Environmental Scientist/State Liaison Officer Office of Environmental Services Northwestern State University Russsell Hall, Room 201 Natchitoches, LA 71497

Entergy Operations, Inc. - 4 -

Electronic distribution by RIV: Regional Administrator (Elmo.Collins@nrc.gov) DRP Director (Dwight.Chamberlain@nrc.gov) DRP Deputy Director (Anton.Vegel@nrc.gov) DRS Director (Roy.Caniano@nrc.gov) DRS Deputy Director (Troy.Pruett@nrc.gov)

Senior Resident Inspector Rich.Smith@nrc.gov) Resident Inspector (Andy.Barrett@nrc.gov) Branch Chief, DRP/C (Geoffrey.Miller@nrc.gov) Senior Project Engineer, DRP/C (Wayne.Walker@nrc.gov) GG Site Secretary (Nancy.Spivey@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov) Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov) K. S. Fuller, RC/ACES (KSF) C. A. Carpenter, D:OE (CAC) OEMAIL Resource Senior Enforcement Specialist (Mark.Haire@nrc.gov) Only inspection reports to the following: DRS STA (Dale.Powers@nrc.gov) Mark Cox, OEDO RIV Coordinator (Mark.Cox@nrc.gov) ROPreports

SUNSI Review Completed: _WCW__ ADAMS: Yes No Initials: _WCW

_ Publicly Available Non-Publicly Available Sensitive Non-Sensitive R:\_REACTORS\GG\2008\GG2008-04RP-RLS.doc ML 082910566 RIV:RI:DRP/C SRI:DRP/C C:SPE:DRP/C C:DRS/EB1 C:DRS/PSB1 C:DRS/PSB2 AJBarrett RLSmith WCWalker RLBywater MPShannon GEWerner /RA/ /RA/ /RA/ /RA/ 10/ /08 10/ /08 10/14/08 10/14/08 10/14/08 10/15/08 C:DRS/OB C:DRS/EB2 SES/ACES C:DRP/C RLantz NFOKeefe MSHaire GBMiller

/RA/ /RA GW for/ /RA/ /RA/ 10/14/08 10/14/08 10/14/08 10/15/08 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax ENCLOSURE 1 NOTICE OF VIOLATION Entergy Operations, Inc. Docket: 50-416 Grand Gulf Nuclear Station License: NPF-29 EA-08-295

During an NRC inspection conducted on June 22 through September 20, 2008, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures and Drawings,"

states, in part, that activities affecting quality shall be accomplished in accordance with prescribed procedures.

Contrary to this requirement, from March 16 through July 9, 2008, the licensee failed to accomplish an activity affecting quality in accordance with prescribed procedures. Specifically, the licensee failed to perform an adequate inspection of probable maximum precipitation door seals protecting safety-related equipment as prescribed in Procedure 07-5-14-310, "Inspection of Mechanical Seals on Doors," revision 5.

This violation is associated with a Green SDP finding.

Pursuant to the provisions of 10 CFR 2.201, Entergy Operations, Inc. is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region IV, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation; EA

-08-295" and should include: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must ENCLOSURE 1 specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated this 17th day of October 2008 ENCLOSURE 2 U. S. NUCLEAR REGULATORY COMMISSION REGION IV Dockets: 50-416 Licenses: NPF-29 Report: 05000416/2008004 Licensee: Entergy Operations, Inc.

Facility: Grand Gulf Nuclear Station Location: Waterloo Road Port Gibson, MS Dates: 06/22/2008 - 09/21/2008 Inspectors: R. Smith, Senior Resident Inspector A. Barrett, Resident Inspector E. Uribe, Reactor Inspector I. Anachondo, NSPDP P. Elkmann, Senior Emergency Preparedness Inspector G. Guerra, Emergency Preparedness Inspector Approved By: Dwight D. Chamberlain, Director Division of Reactor Projects ENCLOSURE 2

SUMMARY OF FINDINGS

IR 05000416/2008004; 6/22/2008 - 9/21/2008; Grand Gulf Nuclear Station; Maintenance Effectiveness, Maintenance Risk Assessments and Emergent Work Control, and Problem Identification and Resolution. This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. Three Green findings were identified by the inspectors. One of findings was cited violation and two were noncited violations.

The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance Determination Process." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green noncited violation of 10 CFR 50.65(a)(2) involving the failure to adequately monitor the performance of four Maintenance Rule systems. Several discrepancies in the Maintenance Rule Program were discovered by the inspectors, including unevaluated condition monitoring failures in the neutron monitoring system and an unevaluated functional failure in the standby gas treatment system. Plant personnel implemented additional corrective actions to fully investigate the potential extent of this condition and the apparent weakness in the condition report screening process used for the Maintenance Rule program. As a result, the Maintenance Rule expert panel classified four systems as needing increased monitoring and goal setting, moving these systems from an a(2) to an a(1) status. The licensee entered this issue into the corrective action program as Condition Report CR-GGN-2008-02219.

This finding is more than minor since it was similar to Inspection Manual Chapter 0612, Appendix E, Example 7.b in that the problem involved degraded equipment performance. This finding was characterized under the significance determination process as having very low safety significance because the maintenance rule aspect of the finding did not cause an actual loss of safety function of the system nor did it cause a component to be inoperable. The cause of this finding has a crosscutting aspect in the area of human performance associated with work practices because licensee personnel failed to use proper self-checking and peer-checking to identify repetitive maintenance rule functional failures and also failed to properly document condition report screening activities H.4(a) (Section 1R12).

Green.

The inspectors identified a Green noncited violation of 10 CFR 50.65 (a)(4), involving the failure to perform risk assessments following multiple declared tornado watches affecting Grand Gulf Nuclear Station during the landfall of Hurricane Gustav. On the morning of September 3, 2008, the inspectors noted that the licensee had not evaluated the increased risk from a declared tornado watch for the Claiborne County area. The inspectors brought this to the attention of plant personnel and a risk assessment was performed and plant risk was changed from a 'Green' to a 'Yellow' risk condition. The inspectors then reviewed the tornado watches declared by the National Weather Service that affected Claiborne County during the landfall of Hurricane Gustav, and noted that six separate tornado watches had been declared over the previous three days. A review of the control room logs showed no documentation of changes in plant risk condition. The licensee entered this issue into the corrective action program as Condition Report CR-GGN-2008-04397.

This finding is more than minor because the risk assessments failed to consider unusual external conditions that were present or imminent. Using Manual Chapter 0609, Appendix K, "Maintenance Risk Assessment and Risk Management Significance Determination Process," Flowchart 1, "Assessment of Risk Deficit" and consulting with the regional senior risk analyst, the inspectors determined the finding of very low safety significance due to a calculated incremental core damage probability deficit of 4.38E-08. This finding has a crosscutting aspect in the area of human performance associated with work practices in that plant personnel failed to follow the risk management procedure H.4(b) (Section 1R13).

Green.

The inspectors identified a Green cited violation of 10 CFR Part 50 Appendix B, Criterion V, "Instructions, Procedures, and Drawings," involving the failure to perform an adequate inspection of probable maximum precipitation door seals protecting safety related equipment. The licensee had previously received a noncited violation for inadequate inspections of probable maximum precipitation door seals in NRC Inspection Report 05000416/2008002. On July 9, 2008, the inspectors found the entrance door to the Train B standby service water pump house not meeting the standards of the maintenance procedure because the door seals failed to make contact with the door.

The extent of condition review found seven additional door seals degraded, including the doors to the diesel generator building and control building. The door seal on the Train B standby service water pump house identified by the inspectors on July 9, 2008, had not been identified by plant personnel during an extent of condition review on February 29, 2008. The licensee entered this issue into the corrective action program as Condition Report CR-GGN-2008-03216.

The finding is more than minor since it affects the protection against external factors attribute of mitigating system cornerstone. The door seals also represent a degrading condition that if left uncorrected could affect the availability, reliability, and capability of mitigating systems required to respond to initiating events to prevent undesirable consequences. Using the Manual Chapter 0609, "Significance Determination Process," Phase 1 Worksheet, the inspectors used the seismic, flooding, and severe weather Table 4b and determined it would affect multi-trains of safety equipment. The inspectors consulted the regional senior reactor analyst, who performed a Phase 3 analysis using many bounding and conservative assumptions. The result was a delta-CDF of 3.3E-7/yr and a delta-LERF of 6.6E-8/yr. These results confirmed that the finding had very low safety significance (Green). The cause of this finding has a crosscutting aspect in the area of problem identification and resolution in that the licensee failed to take adequate corrective actions to ensure degraded probable maximum precipitation door seals were properly evaluated and repaired in a timely manner P.1(d) (Section 4OA2).

B. Licensee-Identified Violations

None.

2

REPORT DETAILS

Summary of Plant Status

Grand Gulf Nuclear Station (GGNS) began the inspection period at full rated thermal power. On July 5, 2008, operators reduced power to 90 percent for planned control rod exercise and control blade friction testing. The plant returned to full rated power the same day. On August 1, 2008, operators commenced a power reduction to 76 percent for a planned control rod sequence exchange, control rod exercise and control blade friction testing. The plant returned to 98 percent of rated power on August 4, 2008 and remained there until equipment issues with the leading edge flow meter (LEFM) could be resolved. On August 10, 2008, after the plant resolved the issue with the LEFM, they returned to full rated power. On August 28, 2008, operators commenced a power reduction to 66 percent for a planned control rod sequence exchange, control rod exercise and control blade friction testing. The plant returned to full rated power on August 29, 2008. The plant remained at or near full rated thermal power until September 14, 2008, when the plant began coasting down in power for scheduled Refueling Outage 16 and remained in a power coast down until the end of the quarter.

REACTOR SAFETY

Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

1R01 Adverse Weather Protection

.1 Summer Seasonal Readiness Preparations

a. Inspection Scope

The inspectors reviewed the licensee's preparations for summer weather for selected systems, including conditions that could lead to loss of offsite power and conditions that could result from high temperatures. During the inspection, the inspectors focused on plant specific design features and the licensee's procedures used to mitigate or respond to adverse weather conditions. Additionally, the inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures. Specific documents reviewed during this inspection are listed in the

. The inspectors also reviewed corrective action program items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their corrective action program in accordance with station corrective action procedures. The inspectors' reviews focused specifically on the following plant systems:

• Standby Service Water System

• Engineering Safety Feature Transformers This inspection constitutes one seasonal adverse weather sample as defined in Inspection Procedure 71111.01-05.

ENCLOSURE 2

b. Findings

No findings of significance were identified.

.2 Readiness For Impending Adverse Weather Condition - Hurricane Gustav which Produced High Wind Conditions, and Tornado Watches/Warnings for the Site

a. Inspection Scope

Since Hurricane Gustav, with potential tornados and high winds, was forecast in the vicinity of the facility for September 1 , 2008, the inspectors reviewed the overall preparations and protections for the expected weather conditions. Starting on August 26, 2008, the inspectors walked down the site standby service water cooling towers and pump houses, in addition to the emergency AC power systems, because their safety-related functions could be affected or required as a result of the hurricane high winds or tornado-generated missiles or the loss of offsite power. The inspectors evaluated the plant staff's preparations against the site's procedures and determined that the staff's actions were adequate. During the inspection, the inspectors focused on plant specific design features and procedures used to respond to specified adverse weather conditions. The inspectors also toured the plant grounds to look for any loose debris that could become missiles during a tornado. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. Additionally, the inspectors reviewed the UFSAR and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant specific procedures. The inspectors also reviewed a sample of corrective action program items to verify that the identified adverse weather issues at an appropriate threshold and dispositioned them through the corrective action program in accordance with station corrective action procedures. Specific documents reviewed during this inspection are listed in the attachment. This inspection constitutes one readiness for impending adverse weather condition sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

• July 29, 2008, the inspectors walked down the control room air conditioning (CRAC) Train B and standby fresh air (SBFA) Train B during planned outage on CRAC Train A and SBFA Train A ENCLOSURE 2

• September 15, 2008, the inspectors walked down the Division I standby diesel generator during a planned outage of the Division II standby diesel generator The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, UFSAR, Technical Specification (TS) requirements, Administrative TS, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Documents reviewed are listed in the attachment. These activities constituted two partial system walkdown samples as defined by Inspection Procedure 71111.04-05.

b. Findings

No findings of significance were identified.

.2 Semi-Annual Complete System Walkdown

a. Inspection Scope

On June 24, 2008, the inspectors completed a system alignment inspection of the high pressure core spray system to verify the functional capability of the system. This system was selected because it was considered both safety-significant and risk-significant in the licensee's probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment line ups, electrical power availability, system pressure and temperature indications, as appropriate, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. A review of a sample of past and outstanding work orders (WOs) was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program (CAP)database to ensure that system equipment alignment problems were being identified and appropriately resolved. The documents used for the walkdown and issue review are listed in the attachment. These activities constituted one complete system walkdown sample as defined by Inspection Procedure 71111.04-05.

ENCLOSURE 2

b. Findings

No findings of significance were identified.

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

• Division II Diesel Generator Room (Room 1D303)

• High Pressure Core Spray Room (Room 1A109) and Residual Heat Removal Train B Pipe Penetration Room (Room 1A205)

• Service Water Train B Pump House and Valve Room (Rooms 2M110 and 2M112)

• Auxiliary Building 208' and 245' elevations (Rooms 1A532, 1A602, 1A603, 1A604 and 1A605)

• Control Building HVAC areas (Rooms OC302 and OC303)

• Containment Building 135' elevation (1A311 and 1A313) The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensee's fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed, that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's corrective action program. These activities constituted six quarterly fire protection inspection samples as defined by Inspection Procedure 71111.05-05.

ENCLOSURE 2

b. Findings

No findings of significance were identified.

1R06 Flooding

.1 Internal Flooding

a. Inspection Scope

The inspectors reviewed selected risk important plant design features and licensee procedures intended to protect the plant and its safety related equipment from internal flooding events. The inspectors reviewed flood analyses and design documents, including the UFSAR, engineering calculations, and abnormal operating procedures for licensee commitments. The specific documents reviewed are listed in the attachment. In addition, the inspectors reviewed licensee drawings to identify areas and equipment that may be affected by internal flooding caused by the failure or misalignment of nearby sources of water, such as the fire suppression or the circulating water systems. The inspectors also reviewed the licensee's corrective action documents with respect to past flood-related items identified in the corrective action program to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following plant areas to assess the adequacy of watertight doors and verify drains and sumps were clear of debris and were operable, and that the licensee complied with its commitments:

• High Pressure Core Spray Room

• Low Pressure Core Spray Room

• RHR Train C Pump Room This inspection constitutes one internal flooding sample as defined in Inspection Procedure 71111.06-05.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review

a. Inspection Scope

On July 2, 2008, the inspectors observed a crew of licensed operators in the plant's simulator during licensed operator requalification examinations to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• Licensed operator performance ENCLOSURE 2

• Crew's clarity and formality of communications

• Ability to take timely actions in the conservative direction

• Prioritization, interpretation, and verification of annunciator alarms

• Correct use and implementation of abnormal and emergency procedures

• Control board manipulations

• Oversight and direction from supervisors

• Ability to identify and implement appropriate TS actions and Emergency Plan Actions and notifications The crew's performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. This inspection constitutes one quarterly licensed operator requalification program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

.1 Routine Quarterly Evaluations

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk significant systems:

• Emergency Switchgear and Battery Room Ventilation System (Z77)

• Riley Temperature switches for various safety related systems (E31, T46, X77, and Y47) The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• Implementing appropriate work practices

• Identifying and addressing common cause failures

• Scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule ENCLOSURE 2

• Characterizing system reliability issues for performance

• Charging unavailability for performance

• Trending key parameters for condition monitoring

• Ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or reclassification

• Verifying appropriate performance criteria for structures, systems, and components (SSCs)/functions classified as (a)(2) or appropriate and adequate goals and corrective actions for systems classified as (a)(1) The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the corrective action program with the appropriate significance characterization. Documents reviewed are listed in the attachment. This inspection constitutes two quarterly maintenance effectiveness samples as defined in Inspection Procedure 71111.12-05.

b. Findings

Introduction.

The inspectors identified a Green noncited violation (NCV) of 10 CFR 50.65(a)(2) involving the failure to adequately monitor the performance of four maintenance rule scoped systems.

Description.

In April 2008, the inspectors identified several discrepancies in the maintenance rule program, including several unevaluated condition monitoring failures in the neutron monitoring system and an unevaluated functional failure in the standby gas treatment system. In addition, the inspectors discovered several condition reports documenting equipment issues that had no functional failure evaluations. Due to the absence of documented evidence to determine how these events were erroneously screened or overlooked in the routine condition reports screening process, plant personnel implemented additional corrective actions to fully investigate the potential extent of this condition and the apparent weakness in the condition reports screening process used for the GGNS Maintenance Rule Program. During this review, several maintenance rule scoped systems were identified as having repetitive component failures of Riley temperature switches that spanned multiple systems. These systems included the electrical switchgear and battery room ventilation system, the diesel generator building ventilation system, and the standby service water pump house ventilation system. Further review also identified a repetitive functional failure of an Asco solenoid valve in the emergency switchgear and battery room ventilation system.

As a result, the maintenance rule expert panel classified these systems as needing increased monitoring and goal setting, moving these systems from an a(2) to an a(1) status.

Analysis.

The inspectors determined that the finding is a performance deficiency in that the licensee failed to apply goals and increase the monitoring of systems impacted by repetitive component failures. The finding was more than minor because it was similar to Inspection Manual Chapter 0612, Appendix E, Example 7.b, in that the problem involved degraded equipment performance. This finding was characterized under the ENCLOSURE 2 significance determination process as having very low safety significance because the maintenance rule aspect of the finding did not cause an actual loss of safety function of the system nor did it cause a component to be inoperable. The cause of this finding has a crosscutting aspect in the area of human performance associated with work practices because licensee personnel failed to use proper self-checking and peer-checking to identify repetitive maintenance rule functional failures and also failed to properly document condition report screening activities H.4(a).

Enforcement.

10 CFR Part 50.65(a)(1) requires, in part, that licensees shall monitor the performance or condition of systems, structures and components (SSCs) within the scope of the rule against licensee-established goals in a manner sufficient to provide reasonable assurance the SSCs are capable of fulfilling their intended safety functions.

10 CFR Part 50.65(a)(2) requires, in part, that the monitoring specified in paragraph (a)(1) is not required where it has been demonstrated the performance or condition of an SSC is being effectively controlled through the performance of appropriate preventive maintenance such that the SSC remains capable of performing its intended function. Contrary to the above, the licensee failed to demonstrate that the performance or condition of four maintenance rule scoped systems had been effectively controlled through the performance of appropriate preventive maintenance. Specifically, the licensee failed to properly evaluate the repetitive failures of system components which demonstrated that the performance of the systems were not being effectively controlled and goal setting and monitoring was required. However, because this inspection finding was characterized by the Significance Determination Process as having very low risk significance (Green) and has been entered in the licensee's CAP as CR-GGN-2008-02219, this violation is being treated as an NCV, consistent with Section IV.A.1 of the NRC Enforcement Policy: NCV 05000416/2008004-01, Failure to Monitor Performance of Four Maintenance Rule Systems.

1R13 Maintenance Risk Assessments and Emergent Work Control

.1 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• Division 2 diesel generator out of service due pre-modification work on July 10, 2008

• Reactor protection system Train B work the week of July 21, 2008

• Tornado watch including Claiborne County on September 3, 2008

• Division 1 diesel generator out of service due to lube oil leak on September 9, 2008 and site entering orange risk due to tornado warning in the area on September 13, 2008 ENCLOSURE 2 These activities were selected based on their potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. These activities constituted four samples as defined by Inspection Procedure 71111.13-05.

b. Findings

Introduction.

The inspectors identified a Green noncited violation of 10 CFR 50.65(a)(4) involving the failure to perform risk assessments following multiple declared tornado watches affecting Grand Gulf Nuclear Station during the landfall of Hurricane Gustav.

Description.

On the morning of September 3, 2008, the inspectors noted that the licensee had not evaluated the increased risk from a declared tornado watch for the Claiborne county area. The inspector brought this to the attention of plant personnel and a risk assessment was performed and plant risk was changed from a 'Green' to a 'Yellow' risk condition. The inspectors then reviewed the tornado watches declared by the National Weather Service that affected Claiborne County during the landfall of Hurricane Gustav, and noted the following six separate tornado watches had been declared over the previous three days:

• Tornado Watch 878 at 1550 on 9/1/2008

• Tornado Watch 880 at 2345 on 9/1/2008

• Tornado Watch 881 at 0635 on 9/2/2008

• Tornado Watch 882 at 1550 on 9/2/2008

• Tornado Watch 884 at 2340 on 9/2/2008

• Tornado Watch 885 at 0620 on 9/3/2008 A review of the control room logs showed no documentation of changes in plant risk condition. The inspector questioned operations personnel and determined that no risk evaluations had been completed.

Analysis.

The inspectors determined that the finding is a performance deficiency because the licensee failed to perform risk assessments involving changing environmental conditions that could have negatively impacted offsite power availability. Per Manual Chapter 0612, Appendix B, the deficiency was greater than minor because the risk assessments failed to consider unusual external conditions that are present or imminent. Using Manual Chapter 0609, Appendix K, "Maintenance Risk Assessment ENCLOSURE 2 and Risk Management Significance Determination Process," Flowchart 1, "Assessment of Risk Deficit" and consulting with the regional senior reactor analyst, the inspectors determined the finding of very low safety significance due to a calculated incremental core damage probability deficit of 4.38E-08. This finding has a crosscutting aspect in the area of human performance associated with work practices in that plant personnel failed to follow the risk management procedure H.4(b).

Enforcement.

10 CFR 50.65 (a)(4), states that, before performing maintenance activities (including but not limited to surveillance, postmaintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Contrary to the above, the inspectors identified that, on several occasions, plant personnel failed to assess and mange risk from proposed maintenance activities during unusual external conditions (i.e., severe weather). Because this finding is characterized by the Significance Determination Process as having very low risk significance (Green) and has been entered into the licensee's CAP as CR-GGN-2008-04397, this violation is being treated as an NCV, consistent with Section VI.A of the Enforcement Policy: NCV 05000416/2008004-02, Failure to Perform an Adequate Risk Assessment during Adverse Weather Conditions.

1R15 Operability Evaluations

.1 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• CR-GGN-2008-02819, Residual heat removal Pump A failed to start due to failure to properly rack breaker

• CR-GGN-2008-03584, Containment penetration not drained of water prior to performing pneumatic containment isolation valve local leak rate testing

• CR-GGN-2008-03854, Leading edge flow meter (LEFM) out of service due to Meter 1 pathways #1 and #8 signal reject rate exceeded

• CR-GGN-2008-04271, Standby service water pump house ventilation screens found in a degraded condition

• CR-GGN-2008-04505, Division 3 battery bank having a loose connection on the positive lead on battery cell number one

• CR-GGN-2008-04121, Reactor core isolation cooling steam bypass valve packing leak The inspectors selected these potential operability issues based on the risk-significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the ENCLOSURE 2 appropriate sections of the TS and Updated Safety Analysis Report (USAR) to the licensee's evaluations, to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the attachment. This inspection constitutes six samples as defined in Inspection Procedure 71111.15-05

b. Findings

No findings of significance were identified.

1R18 Plant Modifications

.1 Temporary Modification

a. Inspection Scope

The inspectors reviewed the following temporary modification:

• Change to LEFM software constants The inspectors compared the temporary configuration changes and associated 10 CFR 50.59 screening and evaluation information against the design basis, the UFSAR, and the TSs, as applicable, to verify that the modification did not affect the operability or availability of the affected system. The inspectors also compared the licensee's information to operating experience information to ensure that lessons learned from other utilities had been incorporated into the licensee's decision to implement the temporary modification. The inspectors, as applicable, performed field verifications to ensure that the modifications were installed as directed; the modifications operated as expected; modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modifications did not impact the operability of any interfacing systems. Lastly, the inspectors discussed the temporary modification with operations, engineering, and training personnel to ensure that the individuals were aware of how extended operation with the temporary modification in place could impact overall plant performance. Documents reviewed are listed in the attachment. This inspection constitutes one sample as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings of significance were identified.

ENCLOSURE 2

1R19 Postmaintenance Testing

.1 Postmaintenance Testing

a. Inspection Scope

The inspectors reviewed the following postmaintenance (PM) activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

• Standby liquid control system Pump B surveillance following maintenance

• Reactor protection system motor generator Set B retest following preventive maintenance

• Valve 1P11F131, refuel water transfer pump suction from suppression pool primary containment isolation valve (PCIV), inservice stroke test following replacement of valve actuator and solenoid

• Reactor vessel pressure high (RHR Isolation) Switch 1B21N679D, retest after replacement of failed card

• Division 1 diesel generator postmaintenance operability run after a repair of an oil leak on the right bank number five cylinder These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable): the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion), and test documentation was properly evaluated. The inspectors evaluated the activities against TS, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with postmaintenance tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the attachment. This inspection constitutes five samples as defined in Inspection Procedure 71111.19.

b. Findings

No findings of significance were identified.

ENCLOSURE 2

1R22 Surveillance Testing

.1 Routine Surveillance Testing

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:

• 06-EL-1E61-SA-0002, Hydrogen Ignition System Semi-Annual Tests

• 06-ME-1M61-V-0001, Local Leak Rate Test Flow Air Using Low Flow Rotameter Panel or River Bend Volumetric Leak Rate Monitor

• 06-OP-1C1-V-0003, APRM Functional Test

• 06-CH-1B21-O-002, Reactor Coolant Routine Chemistry and 06-CH-1B21-W-0008, Reactor Coolant Dose Equivalent Iodine

• 06-OP-1E12-Q-0024, LPCI/RHR Subsystem B Quarterly Functional Test The inspectors observed in-plant activities and reviewed procedures and associated records to determine whether: any preconditioning occurred; effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing; acceptance criteria were clearly stated, demonstrated operational readiness, and were consistent with the system design basis; plant equipment calibration was correct, accurate, and properly documented; as left setpoints were within required ranges; the calibration frequency was in accordance with TS, the USAR, procedures, and applicable commitments; measuring and test equipment calibration was current; test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied; test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used; test data and results were accurate, complete, within limits, and valid; test equipment was removed after testing; where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable; where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure; where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished; prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test; equipment was returned to a position or status required to support the performance of the safety functions; and all problems identified during the testing were appropriately documented and dispositioned in the corrective action program. Documents reviewed are listed in the attachment. This inspection constitutes four routine surveillance testing samples and one inservice testing sample as defined in Inspection Procedure 71111.22.

ENCLOSURE 2

b. Findings

No findings of significance were identified. 2. EMERGENCY PREPAREDNESS [EP]

1EP2 Alert and Notification System Evaluation

.1 Alert and Notification System Evaluation

a. Inspection Scope

The inspectors discussed with licensee staff the status of offsite siren and tone alert radio systems to determine the adequacy of licensee methods for testing the alert and notification system in accordance with 10 CFR Part 50, Appendix E. The licensee

=s alert and notification system testing program was compared with criteria in NUREG-0654, ACriteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,@ Revision 1, Federal Emergency Management Agency (FEMA) Report REP-10, AGuide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants,@ and the licensee

=s current FEMA-approved alert and notification system design report. The inspectors also reviewed the references listed in the attachment to this report. This inspection constitutes one sample as defined in Inspection Procedure 71114.02.

b. Findings

No findings of significance were identified.

1EP3 Emergency Response Organization Augmentation Testing

.1 Emergency Response Organization Augmentation Testing

a. Inspection Scope

The inspectors discussed with licensee staff the status of offsite siren and tone alert radio systems to determine the adequacy of licensee methods for testing the alert and notification system in accordance with 10 CFR Part 50, Appendix E. The licensee

=s alert and notification system testing program was compared with criteria in NUREG-0654, ACriteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,@ Revision 1, Federal Emergency Management Agency (FEMA) Report REP-10, AGuide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants,@ and the licensee

=s current FEMA-approved alert and notification system design report. The inspectors also reviewed the references listed in the attachment to this report.

This inspection constitutes one sample as defined in Inspection Procedure 71114.03.

b. Findings

No findings of significance were identified.

ENCLOSURE 2

1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies

.1 Correction of Emergency Preparedness Weaknesses and Deficiencies

a. Inspection Scope

The inspectors reviewed the licensee

=s CAP requirements in Procedure EN-LI-102, "Corrective Action Process," Revision 12. The inspectors reviewed summaries of 233 condition reports assigned to the emergency preparedness department between June 2006 and July 2008, and selected twenty-five for detailed reviews against program requirements. The inspectors evaluated the response to the corrective action requests to determine the licensee

=s ability to identify, evaluate, and correct problems in accordance with the licensee program requirements, 10 CFR 50.47(b)(14), and 10 CFR Part 50, Appendix E. The inspectors also reviewed licensee after-action reports, quality assurance audits, drill and exercise evaluation reports, and licensee assessments as listed in the attachment to this report, to evaluate the licensee's ability to identify emergency preparedness weaknesses and deficiencies. This inspection constitutes one sample as defined in Inspection Procedure 71114.05.

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

.1 Training Observation

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on August 7, 2008, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors' activities was to note any weaknesses and deficiencies in the crew's performance and ensure that the licensee evaluators noted the same issues and entered them into the CAP. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the attachment.

This inspection constitutes one sample as defined in Inspection Procedure 71114.06.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

Other Activities [OA]

ENCLOSURE 2

4OA1 Performance Indicator Verification

.1 Safety System Functional Failures

a. Inspection Scope

The inspectors sampled licensee submittals for the Safety System Functional Failures performance indicator for the period from the third quarter of 2007 through the second quarter 2008. To determine the accuracy of the performance indicator (PI) data reported during those periods, PI definitions and guidance contained in revision 5 of the Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," and NUREG-1022, "Event Reporting Guidelines 10 CFR 50.72 and 50.73" definitions and guidance were used. The inspectors reviewed the licensee's operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, CRs, event reports and NRC Integrated Inspection reports for the period of July 2007 through June 2008 to validate the accuracy of the submittals. The inspectors also reviewed the licensee's CR database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the Attachment to this report. This inspection constitutes one safety system functional failures sample as defined by Inspection Procedure 71151.

b. Findings

No findings of significance were identified.

.2 Reactor Coolant System Specific Activity

a. Inspection Scope

The inspectors sampled licensee submittals for the Reactor Coolant System (RCS) Specific Activity performance indicator for the period from the third quarter of 2007 through the second quarter 2008. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in revision 5 of the Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," were used. The inspectors reviewed the licensee's RCS chemistry samples, TS requirements, issue reports, event reports and NRC Integrated Inspection reports for the period of July 2007 through June 2008 to validate the accuracy of the submittals. The inspectors also reviewed the licensee's CR database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. In addition to record reviews, the inspectors observed a chemistry technician obtain and analyze a reactor coolant system sample. Specific documents reviewed are described in the Attachment to this report. This inspection constitutes one reactor coolant system specific activity sample as defined by Inspection Procedure 71151.

b. Findings

No findings of significance were identified.

ENCLOSURE 2

.3 Reactor Coolant System Leakage

a. Inspection Scope

The inspectors sampled licensee submittals for the RCS Leakage PI for the period from the third quarter of 2007 through the second quarter 2008. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in revision 5 of the Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," were used. The inspectors reviewed the licensee's operator logs, RCS leakage tracking data, issue reports, event reports and NRC Integrated Inspection reports for the period of July 2007 through June 2008 to validate the accuracy of the submittals. The inspectors also reviewed the licensee's CR database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the Attachment to this report. This inspection constitutes one RCS leakage sample as defined by Inspection Procedure 71151.

b. Findings

No findings of significance were identified.

.4 Drill/Exercise Performance, Emergency Response Organization Drill Participation and Alert and Notification System

a. Inspection Scope

The inspectors reviewed licensee evaluations for the three emergency preparedness cornerstone PIs of drill and exercise performance, emergency response organization participation, and alert and notification system reliability, for the period October 2007 through June 2008. The definitions and guidance of Nuclear Energy Institute Report 99-02, ARegulatory Assessment Indicator Guideline,@ Revisions 4 and 5, and the licensee's PI Procedure EN-EP-201, APerformance Indicators,@ Revisions 6 and 7, were used to verify the accuracy of the licensee

=s evaluations for each PI reported during the assessment period. The inspector also performed Temporary Instruction 2515/175, "Emergency Response Organization, Drill/Exercise Performance Indicator, Program Review." The inspectors reviewed a one hundred percent sample of drill and exercise scenarios and licensed operator simulator training sessions, notification forms, and attendance and critique records associated with training sessions, drills, and exercises conducted during the verification period. The inspectors reviewed selected emergency responder qualification, training, and drill participation records. The inspectors reviewed alert and notification system testing procedures, maintenance records, and a one hundred percent sample of siren test records. The inspectors also reviewed other documents listed in the attachment to this report. This inspection constitutes three samples as defined by Inspection Procedure 71151.

ENCLOSURE 2

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection

.1 Selected Issue Followup Inspection:

Probable Maximum Precipitation (PMP) Door Seals

a. Inspection Scope

The inspectors reviewed condition reports documenting probable maximum precipitation (PMP) door seals for

(1) complete and accurate identification of the problem in a timely manner;

(2) consideration of extent of condition;

(3) classification and prioritization of the resolution of the problem;

(4) identification of root and contributing causes of the problem;

(5) identification of corrective actions; and

(6) completion of corrective actions in a timely manner. The inspectors then performed a walk down of doors in the Train B standby service pump house and determined that the seals for those doors appeared to be degraded. The inspectors brought this to the attention of plant personnel. The plant performed an inspection of these door seals and an extent of condition and determined that eight out of eleven PMP doors seals protecting safety related equipment did not meet procedural requirements. The above constitutes completion of one in-depth problem identification and resolution sample.

b. Findings

Introduction.

The inspectors identified a Green violation of 10 CFR Part 50 Appendix B, Criterion V, "Instructions, Procedures, and Drawings," involving the failure to perform an adequate inspection of PMP door seals protecting safety related equipment.

Description.

The licensee had previously received a noncited violation for inadequate inspections of PMP door seals in NRC Inspection Report 05000416/2008002. On July 9, 2008, the inspectors were performing a follow up inspection of the PMP door seals at Grand Gulf from issues previously identified by the NRC in February 2008. The inspectors found the entrance door to the standby service water Train B pump house not meeting the standards of the maintenance procedure because the door seals failed to make contact with the door. The inspectors notified plant personnel of their concerns and an inspection of the standby service water pump house door seal determined that the PMP seal was in a degraded condition. The extent of condition review found seven additional door seals degraded, including the doors to the diesel generator building and control building.

The plant had entered the previous NRC identified violation from February 2008 into the corrective action program and completed actions to address non-compliant PMP door seals by performing an inspection of all PMP door seals and replacing those seals determined to be degraded. The plant also initiated compensatory actions for the ENCLOSURE 2 degraded seals, staging sand bags in the area and requiring monitoring of the affected doors during heavy rainfall. The door seal on the standby service water Train B pump house identified by the inspectors on July 9, 2008, had not been identified by plant personnel during an extent of condition review on February 29, 2008. Based on the replacement of four degraded PMP seals, the plant canceled their compensatory actions on March 16, 2008. The licensee performed an apparent cause evaluation (ACE), which included an extent of condition of all PMP seals. They concluded that they needed to formally put in place a periodic replacement time frame for the seals which was determined to be every five years. Additionally, they revised the inspection procedure by adding a clarifying note to the maintenance procedure for inspection of PMP door seals. Plant personnel restored compliance on July 9, 2008, when they reestablished the previous discussed compensatory actions. The licensee performed another ACE and determined that the PMP seals needed to be inspected quarterly and replacement of the seals should be performed every three years. The plant performed an engineering evaluation showing the amount of water that might have entered the affected areas with the degraded door seals and presented this to the inspectors. The site determined that under conservative assumptions, if a PMP event occurred with the door seals in their degraded conditions, not enough water would have entered the affected areas to disable the ability of the mitigating systems to perform their safety function. The inspectors reviewed the analysis and decided that the plant's assumptions and conclusion were satisfactory.

Analysis.

The inspectors determined that the failure to properly inspect and repair door seals that protect safety-related equipment from a PMP event is a performance deficiency. The finding is more than minor since it affects the protection against external factors attribute of mitigating system cornerstone. The door seals also represent a degrading condition that if left uncorrected could affect the availability, reliability, and capability of mitigating systems required to respond to initiating events to prevent undesirable consequences. Using the Manual Chapter 0609, "Significance Determination Process," Phase 1 Worksheet, the inspectors used the seismic, flooding, and severe weather Table 4b and determined it would affect multi-trains of safety equipment. The inspectors consulted the regional senior reactor analyst, who performed a Phase 3 analysis using many bounding and conservative assumptions. The result was a delta-CDF of 3.3E-7/yr and a delta-LERF of 6.6E-8/yr. These results confirmed that the finding had very low safety significance (Green). The cause of this finding has a crosscutting aspect in the area of problem identification and resolution in that the licensee failed to take adequate corrective actions to ensure degraded PMP door seals were properly evaluated and repaired in a timely manner P.1(d).

Enforcement.

10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures and Drawings," states, in part, that activities affecting quality shall be accomplished in accordance with prescribed procedures. Contrary to this requirement, from March 16 through July 9, 2008, the licensee failed to accomplish an activity affecting quality in accordance with prescribed procedures. Specifically, the licensee failed to perform an adequate inspection of PMP door seals protecting safety-related equipment as prescribed in Procedure 07-S-14-310, "Inspection of Mechanical Seals on Doors," Revision 5. This finding has been entered into the licensee's CAP as CR-GGN-2008-03216. Due to the licensee's failure to restore compliance from the previous NCV 05000416/2008002-01 within a reasonable time after the violation was identified, ENCLOSURE 2 this violation is being cited as a Notice of Violation consistent with Section VI.A of the Enforcement Policy: VIO 05000416/2008004-03, Failure to Perform an Adequate Inspection of PMP Door Seals Protecting Safety Related Equipment.

.2 Routine Review of items Entered Into the CAP

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: the complete and accurate identification of the problem; that timeliness was commensurate with the safety significance; that evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue. Minor issues entered into the licensee's CAP as a result of the inspectors' observations are included in the attached list of documents reviewed. These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings of significance were identified.

.3 Daily CAP Reviews

a. Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's CAP. This review was accomplished through inspection of the station's daily condition report packages. These daily reviews were performed by procedure as part of the inspectors' daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings of significance were identified.

ENCLOSURE 2

.4 Annual Sample Review

a. Inspection Scope

The inspectors reviewed summaries of 233 condition reports associated with licensee emergency preparedness and selected twenty-five condition reports for detailed review. The reports were reviewed to ensure the full extent of issues were identified, that an appropriate evaluation was performed, and appropriate corrective actions were identified and prioritized. The inspectors evaluated the condition reports against the requirements of licensee Procedure EN-LI-102, "Corrective Action Process," Revision 12. The inspectors also reviewed two condition reports generated during the inspection to determine whether the issues were accurately characterized and assigned an appropriate significance.

b. Findings

No findings of significance were identified.

4OA3 Followup of Events and Notices of Enforcement Discretion

.1 Sulfuric Acid Storage Tank A Unisolable Leak

a. Inspection Scope

The inspectors reviewed the plant's response to an un-isolable leak from an acid storage tank. On August 11, 2008, the plant personnel identified a 2-3 gallon per minute sulfuric acid leak from the acid storage Tank A into the berm area around the tank. The inspectors attended meetings, reviewed recovery, safety, and contingency plans. Additionally, they evaluated the decision process involving emergency action levels. Plant personnel along with vendor assistance stopped the leak by pumping the acid from the leaking tank to two other storage tanks on site. The inspectors also observed the interactions with the vendor that assisted the in the recovery. Documents reviewed in this inspection are listed in the Attachment.

This inspection constitutes one sample as defined in Inspection Procedure 71153-05.

b. Findings

No findings of significance were identified.

.2 Suspected Resin Intrusion

a. Inspection Scope

The inspectors reviewed the response by plant personnel to a suspected resin intrusion from the reactor water cleanup demineralizer system. On September 18, 2008, while the plant was coasting down in power prior to RF16, the control room operators identified that the expected coast down power trend flattened out, showing an effective positive power increase in the reactor. The operators had recently attempted to place the reactor water clean up (RWCU) filter/demineralizer in service, but then removed it from service after the post-strainer showed a high differential pressure. The operators ENCLOSURE 2 entered the off-normal event procedure for resin intrusion, suspecting that the power increase had been caused by a resin intrusion from the RWCU system while placing the filter in service. After further review, the reactor engineering staff concluded that the coast down power trend had been displaying the flattening characteristic for some time, hence would not be a result of placing the RWCU filter in service. The inspectors responded to the control room and reviewed the RWCU system pressure and flow trends, reactor power trends, plant chemistry trends, and the operators' execution of the off-normal event procedure. Documents reviewed in this inspection are listed in the Attachment. This inspection constitutes one sample as defined in Inspection Procedure 71153-05.

.3 (Closed) LER 05000416/2008-001-00 "Manual Reactor SCRAM Due to Loss of Main Electrical Output Transformer Cooling"

On January 12, 2008, at 1626 hours0.0188 days <br />0.452 hours <br />0.00269 weeks <br />6.18693e-4 months <br />, the plant operators initiated a manual reactor scram from 99 percent power due to loss of cooling to the main transformers. The cause of this event was the loss of cooling to the main transformers caused by loss of auxiliary power to the main transformer cooling system. Inspection of the complete circuit for main transformer auxiliary power showed that the Phase B power cables were burned in two at the transfer switch panel. The cause of the Phase B power cable failure was attributed to failure of an electrical compression connection on a lug connection. This particular cable and connection had been inservice since plant start-up. The root causes were determined to be use of a compression connection for high current applications versus the preferred crimp type connection and an inadequate preventive maintenance strategy to provide early detection. Corrective actions included an inspection of the power panel and replacement of all damaged cabling. Documents reviewed as part of this inspection are listed in the attachment. No findings of significance were identified. This LER is closed.

.4 (Closed) LER 05000416/2008-002-00 "Reactor SCRAM Due to Main Generator Trip Caused by Unit Differential Lockout"

On March 21,2008 at 1525 hours0.0177 days <br />0.424 hours <br />0.00252 weeks <br />5.802625e-4 months <br />, the plant experienced an actuation of the Reactor Protection System (RPS) which resulted in an automatic scram from 100 percent power. The scram was due to main turbine control valve fast closure. The cause of the event was a main generator trip as the result of a Phase C unit differential lockout. Troubleshooting which included inspection of the high voltage circuit and check of calibration of both Relays A and B was initiated; however, no definitive cause for the trip was identified. As a result of trouble shooting the licensee took the following corrective actions. The low voltage CT circuit wiring and terminations were inspected to the extent possible. The main generator neutral bushing Phase C in the circuit had a replacement CT wired into the circuit. As a precaution, the suspect Phase C unit differential relay was replaced. No evidence of an actual fault condition was found and no evidence of animal intrusion in the high voltage bus work was found. Additionally, the calibration of Relays A and B was checked and found to be acceptable. Documents reviewed as part of this inspection are listed in the attachment. No findings of significance were identified. This LER is closed.

ENCLOSURE 2

.5 (Closed) LER 05000416/2008-003-00 "Increased Bus Voltage Results in Breaker Trip on Over Current of a High Pressure Core Spray Pump Low Flow Valve Resulting in a Non-Compliance with Technical Specification 3.6.1.3, Primary Containment Isolation Valve Function" On March 05, 2008 at 1619, with the plant at about 99 percent reactor power, emergency core cooling system (ECCS) surveillance testing was being performed of the high pressure core spray (HPCS) pump and system.

The HPCS low flow Valve 1E22-F012 (also a primary containment isolation valve), while stroking from closed to open position, de-energized and the HPCS loss or overload status light energized. The valve was found in the non-closed position and the power supply breaker for the motor actuator for the valve was found tripped open. This condition was considered a violation of TS 3.6.1.3, "Primary Containment Isolation Valve," due to exceeding the limiting condition of operation (LCO) required action completion time of four hours to isolate the penetration. The cause of Valve 1E22-F012 failure to close was due to its supply breaker instantaneous over current trip settings being set too low, thus rendering the valve inoperable. The investigation revealed that this condition had existed since the early 1990s when bus voltages had been increased to a higher value to account for under voltage events. Corrective actions were implemented which included replacement of the Valve 1E22-F012 power supply breaker and increasing the instantaneous over current trip settings. Breaker settings for the other ECCS motor operator valves that were susceptible to this condition were checked and found to be acceptable. Documents reviewed as part of this inspection are listed in the attachment. The enforcement aspects of this finding were discussed in NRC Inspection Report 05000416/2008002 in Section 4OA3. This LER is closed.

4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period the inspectors conducted observations of security force personnel and activities to ensure that the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours. These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status reviews and inspection activities.

b. Findings

No findings of significance were identified.

ENCLOSURE 2

4OA6 Management Meetings

.1 Exit Meeting Summary

On August 20, 2008, the branch chief conducted a regulatory performance meeting with Mr. M. Krupa, Director Nuclear Safety Assurance, and other members of the licensee staff to review corrective actions taken related to the White performance indicator for unplanned scrams per 7000 critical hours in the first quarter of 2008.

On August 22, 2008, the emergency preparedness inspector presented the results of the inspection of the onsite emergency preparedness program to Mr. R. Douet, Vice President, Operations, and other members of his staff, who acknowledged the findings. The inspectors confirmed that proprietary, sensitive, or personal information examined during the inspection had been returned to the identified licensee custodian. On September 29, 2008, the inspectors presented the inspection results to Mr. R. Douet and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

D. Barfield, Director, Engineering

J. Browning, General Manager, Plant Operations

M. Causey, Maintenance Rule Engineer

R. Collins, Manager, Corrective Actions and Assessments

D. Coulter, Licensing Specialist, Plant Licensing

P. Different, Senior Lead Engineer, Reactor Engineering

R. Douet, Vice President, Operations

B. Edwards, Minority Owner Specialist

R. Gardner, Manger, Maintenance

E. Harris, Manager, Quality Assurance

R. Jackson, Licensing Specialist, Plant Licensing

D. Jones, Manager, System Engineering

M. Krupa, Director, Nuclear Safety and Assurance

G. Lantz, Supervisor, Design Engineering

M. Larson, Acting Manager, Plant Licensing

M. McAdory, Senior Operations Instructor

J. Owens, Licensing Specialist, Plant Licensing

W. Parman, Manager, Component Engineering

M. Rohrer, Manager, Planning, Scheduling and Outages

T. Tankersley, Manager, Training

T. Thornton, Manager, Design Engineering

F. Wilson, Manager, Operations

M. Wilson, Manager, Emergency Preparedness

R. Wilson, Superintendent, Radiation Protection

D. Wilson, Supervisor, Design Engineering

P. Worthington, Supervisor, Engineering

NRC Personnel

A. Barrett, Resident Inspector

G. Guerra, Senior Project Engineer

R. Smith, Senior Resident Inspector

- 2 - ATTACHMENT

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened

None

Opened and Closed

05000416/2008004-01 NCV Failure to Monitor Performance of Four Maintenance Rule Systems

05000416/2008004-02 NCV Failure to Perform an Adequate Risk Assessment during Adverse Weather Conditions

05000416/2008004-03 VIO Failure to Perform an Adequate Inspection of PMP Door Seals Protecting Safety Related Equipment

Closed

05000416/LER-2008-001-00 LER Manual Reactor SCRAM Due to Loss of Main Electrical Output Transformer Cooling

05000416/LER-2008-002-00 LER Reactor SCRAM Due to Main Generator Trip Caused by Unit Differential Lockout

05000416/LER-2008-003-00 LER Increased Buss Voltages Results in Breaker Trip on Over Current of a High Pressure Core Spray Pump Low Flow Valve Resulting in Non-Compliance with Technical Specification 3.6.1.3, Primary Containment Isolation Valve Function

Discussed

None

- 3 - ATTACHMENT

Section 1R01: Adverse Weather Protection

Condition Report

CR-GNN-2008-1852 Procedures

NUMBER TITLE REVISION 08-S-04-120 Chemistry Evolutions at Standby Service Water 11

ENS-EP-302 Severe Weather Response 08

05-1-02-VI-2 Off Normal Event Procedure Hurricanes, Tornados, and Severe Weather

110

Work Orders

WO123216

WO133131

WO120926

WO 134642

WO 51558087

WO51209213

WO51210133

Other

WTGNN-2008-0138

PL-159, Summer Reliability Plan, Revision 0

GGNS 2008 Summer Reliability Plan

SD Myers-The Transformer Consultants,

TC-9018, Engineering Safety Feature Transformer 21 [07/2005-04/2008]

SD Myers-The Transformer Consultants,

TC-9016, Engineering Safety Feature (ESF) Transformer 12 [07/2005-11/2007]

TC-9017, Engineering Safety Feature (ESF) Transformer 11 [07/2005-07/2007]

TC-9018, Engineering Safety Feature (ESF) Transformer 21 [07/2005-07/2007]

Inside Entergy Newsletter: Title Plant Date Summer Reliability Planning

Grand Gulf 12/17/2002

Summer Reliability - We all Play a Part Grand Gulf 05/20/2003

- 4 - ATTACHMENT

Section 1R04: Equipment Alignment

Condition Report

CR-GGN-2007-03385 Procedures

NUMBER TITLE REVISION 04-1-01-E22-1 High Pressure core Spray System 110 04-1-01-P75-1 Standby Diesel Generator System 076 05-1-02-I-4 Loss of AC Power 035 04-S-01-Z51-1 Control Room HVAC System 044

Work Orders

WO115566

WO50306660

WO142792

WO078891

WO139126

WO139127

Other

Drawing M-1065, P&ID Condensate and Refueling Water Storage and Transfer System, Revision 42

Drawing M-1086, P&ID High Pressure Core Spray System, Revision 30

Drawing M-1070, P&ID Standby Diesel Generator System, Revision 33

Drawing M-0049, P&ID Control Room HVAC System, Revision 42

Section 1R05: Fire Protection

Work Order

WO51554021

Other

Fire Pre-Plan

DG-03, Division II Diesel Generator Room 1D303, Revision 04

Fire Pre-Plan A-06, HPCS Room 1A109, Revision 00

Fire Pre-Plan C-09 Control Building HVAC areas, Rooms OC302 and OC303 Revision 02

Fire Pre-Plan A-04, RHR B Pipe Penetration Room 1A205, Revision 01

- 5 - ATTACHMENT Fire Pre- Plan

SSW-02, SSW B Pump and Valve Room 2M110/2M112, Revision 01

Fire Pre-Plan A-48, Auxiliary Building Elevation 208 Rooms 1A532, 1A602, 1A603, and 1A604, Revision 01, Areas 9 & 10 Auxiliary Building Elevation 208

Fire Pre-Plan A-49, Auxiliary Building Elevation 245 Room 1A605, Revision 01

Fire Pre-Plan A-49, Auxiliary Building Elevation 245 Room 1A605, Revision 01

Section 1R06: Flooding

Condition Report

CR-GGN-2008-03415 Procedures

NUMBER TITLE REVISION 05-1-02-VI-1 Off-Normal Event Procedure Flooding Safety Related 105 07-S-14-310 Inspection of Mechanical Seals on Doors Safety Related 4

07-1-24-T10-1 Periodic Leak Check of Airtight Door Sealing Surfaces Safety Related

Work Orders

WO159095

WO51050074

WO51051315

WO51056158

WO51085767

WO51099498

WO51192074

WO51567301

Other

Drawing M-1094C, PI&D Floor and Equipment Drains System, Revision 21

Drawing M-109B, PI&D Floor and Equipment Drains System, Revision 21

Drawing M-1098E, PI&D Embedded and Suspended Drains Turbine Bldg., Revision 13

UFSAR, Water Level (Flood) Design, Section 3.4, Revision 8

UFSAR, Seismic Category I Components Protected from Environmental Floods, Table 3.4-2, Revision 2.

Section 1R11: Licensed Operator Requalification Program

Other

GSMS-LOR-AEX01, 'C' Level Instrument Failure/ FW Heater 6A Tube Leak/ FW Line Rupture

- 6 - ATTACHMENT in Drywell, Revision 05

GSMS-LOR-AEX08, RCIC Isolation/ 'A' RFP Trip/ Loss of Feedwater/ ATWS, Revision 05

Section 1R12: Maintenance Effectiveness

Condition Reports

CR-GGN-2006-02584

CR-GGN-2006-03561

CR-GGN-2006-03644

CR-GGN-2006-03651

CR-GGN-2006-04828

CR-GGN-2007-02060

CR-GGN-2007-02361

CR-GGN-2007-02391

CR-GGN-2007-02391

CR-GGN-2007-03055

CR-GGN-2007-03714

CR-GGN-2007-05005

CR-GGN-2007-05488

CR-GGN-2007-05492

CR-GGN-2008-00655

CR-GGN-2008-02265

CR-GGN-2008-02615

CR-GGN-2008-02768 Procedures

NUMBER TITLE REVISION

EN-DC-203 Maintenance Rule Program 1

EN-DC-204 Maintenance Rule Scope and Basis 1

EN-DC-205 Maintenance Rule Monitoring 1

EN-DC-206 Maintenance Rule a(1) Process 1

EN-DC-207 Maintenance Rule Periodic Assessment 1

Other

Maintenance Rule Program (a)(1) Evaluation for T46 ESF Electrical SWGR Rooms Cooling System Maintenance Rule Program (a)(1) Evaluation for Y47 SSW Ventilation System Maintenance Rule Program (a)(1) Evaluation for X77 Diesel Generator Ventilation System Maintenance Rule Program (a)(1) Evaluation for Z77 Emergency Switchgear and Battery Room Ventilation System Maintenance Rule Control Rod Drive System C11 (a)(1) Action Plan

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Condition Reports

CR-GGN-2008-03117

CR-GGN-2008-3185

- 7 - ATTACHMENT Procedures

NUMBER TITLE REVISION

EN-WM-101 On-line Work Management Process 3 01-S-18-6 Risk Assessment of Maintenance Activities 5

Other

EN-WM-101, On-Line Emergent Work Deletion Approval Form for

CR-2008-03117

EN-WM-101, On-Line Emergent Work Addition Approval Form for

CR-2008-03117

EN-WM-101, On-Line Emergent Work Addition Approval Form for IRM D

EN-WM-101, On-Line Emergent Work Addition Approval Form for Containment Channel B Hydrogen Analyzer

EN-WM-101, On-Line Emergent Work Addition Approval Form for RPS B Normal and Alternate Feeder Breakers

EN-WM-101, On-Line Emergent Work Addition Approval Form for Division 1 Diesel Generator oil leak Grand Gulf Nuclear Power Station - Weekly Risk Profile, Week July 7, 2008

Grand Gulf Nuclear Power Station - Weekly Risk Profile, Week July 21, 2008

Grand Gulf Nuclear Power Station - Weekly Risk Profile, Week September 8, 2008

Section 1R15: Operability Evaluations

Condition Reports

CR-GGN-2008-02819

CR-GGN-2008-03584

CR-GGN-2008-03854

CR-GGN-2008-04505

CR-GGN-2008-04121

CR-GGN-2008-04271

CR-GGN-2008-04280

CR-GGN-2008-02819

CR-GGN-2008-03584 Procedures

NUMBER TITLE REVISION 06-EL-1L11-R-0001 125 Volt Battery Bank Physical Condition Check 102 04-S-04-2 Operation of Electrical Circuit Breakers 43 04-S-04-2 Operation of Electrical Circuit Breakers

EN-LI-100 Process Applicability Determination 07

- 8 - ATTACHMENT 07-S-74-P71-1 LLRT Valve Alignment Procedure for Plant Chilled Water Penetration

Work Orders

WO164503

WR122465

WO104662

Other

EC 9203

P&ID M-1109D

Letter from Cameron to Grand Gulf Nuclear Station, August, 8, 2008, Revision 1

IEEE-450

Section 1R18: Plant Modifications

Condition Reports

CR-GGN-2007-03342

CR-GGN-2008-02924

CR-GGN-2008-03796 Other

EC-9099

PR-638 Cross Correlation Discussion Presentation

Section 1R19: Post Maintenance Testing

Condition Reports

CR-GGN-2008-00425

CR-GGN-2008-02940

CR-GGN-2008-03519

CR-GGN-2008-03520

CR-GGN-2008-03785

CR-GGN-2008-04025

CR-GGN-2008-04205

CR-GGN-2008-04496 Procedures

NUMBER TITLE REVISION 06-OP-1C41-Q-0001 Standby Liquid Control Functional Test 116 07-S-12-39 General Cleaning and Inspection of Non-Rotating Electrical Equipment

07-S-12-40 General Cleaning and Inspection of Rotating Electrical Equipment

- 9 - ATTACHMENT 07-S-12-55 Insulation Resistance Testing - Meggering

06-ME-1M61-V-0003 Local Leak Rate Test - Low Pressure Water

104 06-OP-1P11-Q-0001 Condensate and Refueling Water Storage and Transfer System Valve Operability Test

116 04-1-01-P75-1 Standby Diesel Generator System

06-OP-1P75-M0001 Standby Diesel Generator 11 Functional Test

29 02-S-01-28 Diesel Generator Start Information Sheet Division 1 DG, September 9, 2008

2

Work Orders

WO133490

WO146529

WO50298744

WO157491

WO161091

WO161098

WO162656

WO164460

Other

WR 135647

EN-WM-101, On-Line work Addition/Deletion Approval Form for 1B21N679D, August 21, 2008

Clearance 1C16-1, P75-067-P75 Lube Oil A, 1-P75-Engine 1P75-E001A

Section 1R22: Surveillance Testing

Condition Report

CR-GGN-2008-02942 Procedures

NUMBER TITLE REVISION 06-CH-1B21-O-002 Reactor Coolant Routine Chemistry 106 06-CH-1B21-W-0008 Reactor Coolant Dose Equivalent Iodine 104 06-EL-1E61-SA-0002 Hydrogen Ignition System Semi-Annual Test 105

06-ME-1M61-V-0001 Local Leak Rate Test Flow Air using Low Flow Rotameter Panel or River Bend Volumetric Leak Rate Monitor

110 06-OP-1C1-V-0003 APRM Functional Test 114 08-S-04-9 Obtaining Liquid Samples 15

- 10 - ATTACHMENT 06-OP-1E12-Q-0024 LPCI/RHR Subsystem B Quarterly Functional Test

110

Work Orders

WO51206187

WO51207164

WO51569738

WO51647770

WO51648866

WO51648868

Other

CEP-IST-2, In-service Testing Plan, Revision 310

In-service Testing Performance database report for E12C002B

Section 1EP2: Alert and Notification System Evaluation

Procedures

NUMBER TITLE REVISION EPIP 10-S-02-2 Maintaining the

VIP 2000 8 EPIP 10-S-03 Emergency Preparedness Department Responsibilities Other

ANS Maintenance Rules and Expectations

Desk Guide, Alert Notification System Emergency Activation, January 2006

Section 1EP3: Emergency Response Organization Augmentation Testing

Procedure

NUMBER TITLE REVISION EPIP 01-S-10-6 Emergency Response Organization 18-19

Quarterly Off-Hours Unannounced

VIP 2000 Test Evaluation Reports

2006 - June 27, August 15, December 5

2007 - March 6, June 28, September 26, December 18

2008 - March 31, June 23

- 11 - ATTACHMENT

Section 1EP5: Correction of Emergency Preparedness Weaknesses and Deficiencies

Condition Reports

CR-GGN-2006-02009

CR-GGN-2006-02904

CR-GGN-2006-03261

CR-GGN-2006-04151

CR-GGN-2006-04274

CR-GGN-2007-00423

CR-GGN-2007-00736

CR-GGN-2007-00737

CR-GGN-2007-02054

CR-GGN-2007-02266

CR-GGN-2007-02607

CR-GGN-2007-02947

CR-GGN-2007-03068

CR-GGN-2007-03087

CR-GGN-2007-03382

CR-GGN-2007-03414

CR-GGN-2007-03823

CR-GGN-2007-03963

CR-GGN-2007-04624

CR-GGN-2007-05335

CR-GGN-2007-05753

CR-GGN-2008-00147

CR-GGN-2008-00675

CR-GGN-2008-01241

CR-GGN-2008-01324

CR-GGN-2008-01673

CR-GGN-2008-02697

CR-GGN-2008-02808

CR-GGN-2008-03002

CR-GGN-2008-03034 Procedure

NUMBER TITLE REVISION EPIP 10-S-26 Offsite Emergency Response 12

Quality Assurance Audits/Surveillances Quality Assurance Audit

QA-7-2006-GGNS-001, July 5, 2006

Quality Assurance Audit

QA-7-2008-GGNS-1, July 29, 2008

Quality Assurance Surveillance

QS-2006-GGNS-005, September 21, 2006

Quality Assurance Surveillance

QS-2006-GGNS-007, October 10, 2006

Quality Assurance Surveillance

QS-2007-GGNS-003, January 11, 2007

Quality Assurance Surveillance

QS-2007-GGNS-012, September 4, 2007

Evaluation Reports for Drills Conducted

2006 - October 10, October 26, December 6

2007 - Feb 21, May 29, May 30, July 9, August 14, September 17, September 19, October 2, October 18 (Yellow Team), October 18 (Red Team), October 23, November 5, November 7, December 4, December 11

2008 - February 6, April 16, May 5, May 14, June 9, June 12

Other

Snapshot Assessment Report,

LO-GG-2008-0036, July 25, 2008

Emergency Preparedness Corporate Assessment, July 5, 2006

- 12 - ATTACHMENT Standing Order 07-01, Siren Maintenance Issues, Revision 0, July 2, 2007

Standing Order 07-03, Maintaining ERO Qualifications

Section 1EP6: Drill Evaluation

Procedures

NUMBER TITLE REVISION 10-S-04-4 Emergency Preparedness Instruction 07 EN-

EP-201 Performance Indicators 07

EN-

LI-114 Performance Indicator Process 03

Other

GSMS-LOR-00195, Emergency Plan Exercises (EP-2, 2A, 3, 4), Revision 05

2008 NRC Performance Indicator Designated Events Memo, January 30, 2008

2008 NRC Performance Indicator Designated Events Memo, March 5, 2008

2008 NRC Performance Indicator Designated Events Memo, March 13, 2008

2008 NRC Performance Indicator Designated Events Memo, March 18, 2008

2008 NRC Performance Indicator Designated Events Memo, July 16, 2008

2008 NRC Performance Indicator Designated Events Memo, August 11, 2008

Section 4OA1: Performance Indicator Verification

Procedures

NUMBER TITLE REVISION

EN-LI-114 Performance Indicator Process 03 06-CH-1B21-W-0008 Reactor Coolant Dose Equivalent Iodine 104

Other Third Quarter 2007 Core Thermal Power March 2008 Core Thermal Power November 2007 Core Thermal Power

June 2008 Core Thermal Power

- 13 - ATTACHMENT

LER 2007-001

LER 2007-002

LER 2007-003

LER 2008-001

LER 2008-002

LER 2008-003

Section 4OA2: Problem Identification and Resolution

Condition Reports

CR-GGN-2008-03183

CR-GGN-2008-03216

Procedures

NUMBER TITLE REVISION EPIP 10-S-01 Activation of the Emergency Plan - Classification 17 EPIP 10-S-03 Emergency Preparedness Department Responsibilities

EPIP 10-S-06 Emergency Response Organization and Offsite Notification

EPIP 10-S-12 Protective Action Recommendations 37-38

GSMS-LOR-00195 Emergency Plan Exercises 5

Other

Grand Gulf Nuclear Station Emergency Plan, Revision 59

Section 4OA3: Followup of Events and Notices of Enforcement Discretion

Condition Reports

CR-GGN-2008-00174

CR-GGN-2008-01201

CR-GGN-2008-01476

CR-GGN-2008-03991

CR-GGN-2008-03995

CR-GGN-2008-04000

CR-GGN-2008-04019

CR-GGN-2008-04024

CR-GGN-2008-04707

CR-GGN-2008-04717 Procedures

NUMBER TITLE REVISION 01-S-12-20 Hazardous Material Emergency Response Plan 05

- 14 - ATTACHMENT 05-1-02-V-12

Condensate/Reactor Water High Conductivity 22 04-1-01-G33-1 Reactor Water Cleanup System 135

Work Order

WO161577

Other

Acid Leak Recovery Schedule

LER 05000416/2008-001-00, Manual Reactor SCRAM Due to Loss of Main Electrical Output Transformer Cooling

LER 2008-002-00, Reactor SCRAM Due to Main Generator Trip Caused by Current Transformer Lockout

LER 05000416/2008-003-00, Increased Bus Voltage Results in Breaker Trip on Over Current of a High Pressure Core Spray Pump Low Flow Valve Resulting in a Non-Compliance with Technical Specification 3.6.1.3, Primary Containment Isolation Valve Function

LIST OF ACRONYMS

USED [[]]

ACE Apparent Cause Evaluation

CAP Corrective Action Program

CR Condition Report

CRAC Control Room Air Conditioner

DRP Division of Reactor Projects

ECCS Emergency Core Cooling System

FEMA Federal Emergency Management Agency

HPCS High Pressure Core Spray

LCO Limiting Condition for Operation

LEFM Leading Edge Flow Meter

LER Licensee Event Report

NCV Non-Cited Violation

NEI Nuclear Energy Institute

NRC U.S. Nuclear Regulatory Commission

PCIV Primary Containment Isolation Valve

PI Performance Indicator

PM Postmaintenance

PMP Probable Maximum Precipitation

RCS Reactor Coolant System

RPS Reactor Protection System

RWCU Reactor Water Clean Up

SBFA Standby Fresh Air

SSC Systems, Structures, and Components

TS Technical Specification

UFSAR Updated Final Safety Analysis Report

USAR Updated Safety Analysis Report

WO Work Order