IR 05000416/2010003

IR 05000416-10-003, on 03/28/2010 - 06/27/2010, Grand Gulf Nuclear Station, Integrated Resident and Regional Report, Maintenance Risk Assessments and Emergent Work Control, and Operability Evaluations

ML102000453
Person / Time
Site:	Grand Gulf
Issue date:	07/19/2010
From:	Vincent Gaddy NRC/RGN-IV/DRP/RPB-C
To:	Douet J Entergy Operations
References
IR-10-003
Download: ML102000453 (71)

Text

July 19, 2010

James Vice President Operations Entergy Operations, Inc.

Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150

Subject: GRAND GULF - NRC INTEGRATED INSPECTION REPORT 05000416/2010003

Dear Mr. Douet:

On June 27, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Grand Gulf Nuclear Station. The enclosed integrated inspection report documents the inspection findings, which were discussed on July 13, 2010, with you and other members of your staff.

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

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents one NRC-identified violation and one self-revealing violation of very low safety significance (Green). Both of these findings were determined to involve violations of NRC requirements. Additionally, three licensee-identified violations, which were determined to be of very low safety significance, are listed in this report. However, because of the very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as a noncited violations, consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the violations or the significance of the noncited violations, 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, D.C. 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 E. Lamar Blvd, Suite 400, Arlington, Texas, 76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the Grand Gulf Nuclear Station. In addition, if you disagree with the crosscutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV, and the NRC Resident Inspector at Grand Gulf Nuclear Station.

UNITED STATES NUCLEAR REGULATORY COMMISSION R E GI ON I V 612 EAST LAMAR BLVD, SUITE 400 ARLINGTON, TEXAS 76011-4125

Entergy Operations, Inc.

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In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, and its enclosure, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Vincent Gaddy, Chief Project Branch C Division of Reactor Projects

Docket: 50-416 License: NPF-29

Enclosure:

NRC Inspection Report 05000416/2010003 w/Attachment: Supplemental Information

REGION IV==

Docket:

05000416 License:

NPF-29 Report:

05000416/2010003 Licensee:

Entergy Operations, Inc.

Facility:

Grand Gulf Nuclear Station Location:

7003 Baldhill Road Port Gibson, MS 39150 Dates:

March 28 through June 27, 2010 Inspectors:

R. Smith, Senior Resident Inspector A. Barrett, Resident Inspector J. Drake, Senior Reactor Inspector P. Elkmann, Senior Inspector B. Hagar, Senior Project Engineer N. Hernandez, Project Engineer R. Kumana, Project Engineer L. Ricketson, P.E., Senior Health Physicist D. Stearns, Health Physicist M. Williams, Reactor Inspector Approved By:

Vincent Gaddy, Chief, Project Branch C Division of Reactor Projects

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Enclosure

SUMMARY OF FINDINGS

IR 05000416/2010003; 03/28/2010 - 06/27/2010; Grand Gulf Nuclear Station, Integrated

Resident and Regional Report; Maintenance Risk Assessments and Emergent Work Control, and Operability Evaluations.

The report covered a 3-month period of inspection by resident inspectors and announced baseline inspections by regional based inspectors. Two findings of very low safety significance were identified. The significance of most findings is indicated by their color (Green, White,

Yellow, or 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: Barrier Integrity

Green.

The inspectors reviewed a self-revealing noncited violation of Technical Specifications 5.4.1(a), involving a loss of decay heat removal in the spent fuel pool due to station operators failing to follow the fuel pool cooling and cleanup system operating instruction. The licensee entered this issue into the corrective action program as Condition Report CR-GGN-2010-02172.

This finding is more than minor because it is associated with the human performance attribute of the Barrier Integrity Cornerstone and adversely affects the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Using the Manual Chapter 0609, Significance Determination Process,

Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the inspectors determined that the finding has a very low safety significance because it only represented a loss of spent fuel pool cooling that would not preclude restoration of cooling to the spent fuel pool prior to pool boiling. 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 adequate self-and peer-checking techniques to remove the filter/demineralizer from service H.4(a) (Section 1R15.b).

Cornerstone: Mitigating Systems

Green.

The inspectors identified a noncited violation of 10 CFR 50.65 a(4) for failure to perform adequate risk assessments prior to flushing the reactor heat removal systems suction piping and filling and venting of the alternate decay heat removal system. The licensee entered this issue into the corrective action program as Condition Report CR-GGN-2010-02553.

This finding is more than minor because it is associated with the human performance attribute of the Mitigating Systems Cornerstone, adversely affecting the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Using IMC 0609, Significance Determination Process, Attachment 0609.04,

Phase 1 - Initial Screening and Characterization of Findings, the inspectors evaluated the finding using IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process. Using Appendix K, the inspectors determined that the finding has a very low safety significance because the finding was related only to the performance of risk management actions and did not exceed the threshold for core damage probability and large early release probability. The cause of this finding has a crosscutting aspect in the area of human performance associated with resources, because the licensee failed to provide adequate training on the implementation of the new risk management procedure H.2(b) (Section 1R13.b).

Licensee-Identified Violations

Violations of very low safety significance, which were identified by the licensee, have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and condition report numbers are listed in Section 4OA7.

REPORT DETAILS

Summary of Plant Status

Grand Gulf Nuclear Station began the inspection period at 97 percent power, coasting down to Refueling Outage 17. On April 9, 2010, operators reduced power from 93 percent power to 60 percent power to perform channel bow surveillance testing. On April 10, 2010, operators increased power to 88 percent. On April 25, 2010, operators reduced power and shut down the reactor to begin Refueling Outage 17. On May 26, 2010, the plant was brought to critical and began power ascension. The plant reached 100 percent power on May 30, 2010. The plant remained at or near full rated thermal power for the remainder of the inspection period.

REACTOR SAFETY

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

1R01 Adverse Weather Protection

.1 Summer Readiness for Offsite and Alternate-ac Power

a. Inspection Scope

The inspectors performed a review of 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. The inspectors reviewed the procedures affecting these areas and the communications protocols between the transmission system operator and the plant to verify that the appropriate information was being exchanged when issues arose that could affect the offsite power system. Examples of aspects considered in the inspectors review included:

• The coordination between the transmission system operator and the plants operations personnel during off-normal or emergency events

• The explanations for the events

• The estimates of when the offsite power system would be returned to a normal state

• The notifications from the transmission system operator to the plant when the offsite power system was returned to normal

During the inspection, the inspectors focused on plant-specific design features and the procedures used by plant personnel to mitigate or respond to adverse weather conditions. Additionally, the inspectors reviewed the Updated Final Safety Analysis Report 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 attachment. 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:

• Division I and II standby diesel generators

• High pressure core spray diesel generator

• 500 kV switchyard

These activities constitute completion of one readiness for summer weather affect on offsite and alternate-ac power sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

.2 Readiness to Cope with External Flooding

a. Inspection Scope

The inspectors evaluated the design, material condition, and procedures for coping with the design basis probable maximum flood. The evaluation included a review to check for deviations from the descriptions provided in the Updated Final Safety Analysis Report for features intended to mitigate the potential for flooding from external factors. As part of this evaluation, the inspectors checked for obstructions that could prevent draining, checked that the roofs did not contain obvious loose items that could clog drains in the event of heavy precipitation, and determined that barriers required to mitigate the flood were in place and operable. Additionally, the inspectors performed an inspection of the protected area to identify any modification to the site that would inhibit site drainage during a probable maximum precipitation event or allow water ingress past a barrier.

The inspectors also reviewed the abnormal operating procedure for mitigating the design basis flood to ensure it could be implemented as written. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one external flooding sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignments

.1 Partial Walkdown

a. Inspection Scope

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

• Alternate decay heat removal system while it was aligned as backup for shutdown cooling while the residual heat removal system B was inoperable during the refueling outage

• Review of safety related snubbers in inaccessible areas that were tested during the sites refueling outage

• Low pressure core spray system following refueling outage

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 affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Final Safety Analysis Report, technical specification requirements, administrative technical specifications, 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 inspected 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. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three partial system walkdown samples as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

From April 7 through June 22, 2010, the inspectors performed a complete system alignment inspection of the residual heat removal 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 licensees probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment lineups, electrical power availability, system pressure, and temperature indications.

When appropriate, inspectors also reviewed component labeling, component lubrication, component and equipment cooling, hangers and supports, and operability of support systems. It was also ensured that ancillary equipment or debris did not interfere with equipment operation. A review of a sample of past and outstanding work orders was performed to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program database to ensure that system equipment alignment problems were being identified and appropriately resolved. Documents reviewed are listed in the attachment.

Additional activities were performed during this system walkdown that were associated with Temporary Instruction (TI) 2515/177, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems. These activities are described in

.3 of this section.

These activities constituted one complete system walkdown sample as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

.3 System Walkdown associated with TI 2515/177, Managing Gas Accumulation in

Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems

a. Inspection Scope

On April 7 and May 20, 2010, the inspectors conducted a walkdown of the residual heat removal system in sufficient detail to reasonably assure the acceptability of the licensees walkdowns (TI 2515/177, Section 04.02.d). The inspectors also verified that the information obtained during the licensees walkdown was consistent with the items identified during the inspectors independent walkdown (TI 2515/177, Section 04.02.c.3).

In addition, the inspectors verified that the licensee had isometric drawings that describe the residual heat removal system configurations and had acceptably confirmed the accuracy of the drawings (TI 2515/177, Section 04.02.a). The inspectors verified the following related to the isometric drawings:

• High point vents were identified

• High points that do not have vents were acceptably recognizable

• Other areas where gas can accumulate and potentially impact subject system operability, such as at orifices in horizontal pipes, isolated branch lines, heat exchangers, improperly sloped piping, and under closed valves, were acceptably described in the drawings or in referenced documentation

• Horizontal pipe centerline elevation deviations and pipe slopes in nominally horizontal lines that exceed specified criteria were identified

• All pipes and fittings were clearly shown

• The drawings were up-to-date with respect to recent hardware changes and that any discrepancies between as-built configurations and the drawings were documented and entered into the corrective action program for resolution The inspectors verified that piping and instrumentation diagrams accurately described the subject systems, that they were up-to-date with respect to recent hardware changes, and any discrepancies between as-built configurations, the isometric drawings, and the piping and instrumentation diagrams were documented and entered into the corrective action program for resolution (TI 2515/177, Section 04.02.b).

Documents reviewed are listed in the attachment to this report.

This inspection effort counts towards the completion of TI 2515/177 which will be closed in a later inspection report.

b. Findings

No findings were identified.

1R05 Fire Protection

Quarterly Fire Inspection Tours

a. Inspection Scope

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

• Low pressure core spray and pipe penetration rooms (1A119 and 1A115)

• Residual heat removal C and pipe penetration rooms (1A118 and 1A116)

• Drywell during the refueling outage

• Walk down of fire doors in the auxiliary and turbine buildings during the refueling outage

• Independent spent fuel storage installation

The inspectors reviewed areas to assess if licensee personnel 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 licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plants 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 that 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 licensees corrective action program.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five quarterly fire-protection inspection samples as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings were identified.

1R08 Inservice Inspection Activities

.1 Inspection Activities Other Than Steam Generator Tube Inspection, Pressurized Water

Reactor Vessel Upper Head Penetration Inspections, and Boric Acid Corrosion Control (71111.08-02.01)

a. Inspection Scope

The inspectors observed eight nondestructive examination activities and reviewed 11 nondestructive examination activities that included five types of examinations. The licensee did not identify any relevant indications accepted for continued service during the nondestructive examinations.

The inspectors directly observed the following nondestructive examinations:

SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Condenser Air Removal FW564C1 Visual (VT-1)

SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Condenser Air Removal FW564C1 Penetrant Condenser Air Removal FW564C1 Radiograph (Repair)

Reactor Pressure Vessel Head B13-N08-KA Ultrasonic Reactor Pressure Vessel Head B13-N08-IR Ultrasonic Reactor Pressure Vessel Head B13-N07-KA Ultrasonic Reactor Pressure Vessel Head B13-N07-IR Ultrasonic Reactor Recirculation 1B33G10-B1-C Ultrasonic

The inspectors reviewed records for the following nondestructive examinations:

SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Reactor Pressure Vessel AG Magnetic Particle Residual Heat Removal 1E12C002B-SB-3 Magnetic Particle Residual Heat Removal 1E12C002B-SB-4 Magnetic Particle Residual Heat Removal 1E12C002B-SB-5 Magnetic Particle Condenser Air Removal FW564C1 Radiograph (Initial)

Nuclear Boiler System 1B21 F028D Ultrasonic Nuclear Boiler System 1B21G001W1 Loop C Ultrasonic Reactor Recirculation 1B33G10-B1-A Ultrasonic Reactor Recirculation 1B33C001B Visual (VT-1)

Reactor Recirculation Q1B33G006S351A Visual (VT-3)

Reactor Recirculation Q1B33G006S306A Visual (VT-3)

During the review and observation of each examination, the inspectors verified that activities were performed in accordance with the ASME Code requirements and applicable procedures. The inspectors verified that the qualifications of all nondestructive examination technicians performing the inspections were current.

The inspectors did not observe any welds on the reactor coolant system pressure boundary, but did observe one weld on the condenser air removal system piping.

The inspectors directly observed a portion of the following welding activities:

SYSTEM WELD IDENTIFICATION WELD TYPE Condenser Air Removal FW564C1 Manual Gas Tungsten Arc Welding

The inspectors verified, by review, that the welding procedure specifications and the welders had been properly qualified in accordance with ASME Code,Section IX, requirements. The inspectors also verified, through observation and record review, that essential variables for the welding process were identified, recorded in the procedure qualification record, and formed the bases for qualification of the welding procedure

specifications. Specific documents reviewed during this inspection are listed in the attachment.

These actions constitute completion of requirements as defined in Inspection Procedure 71111.08-02.01.

b. Findings

No findings were identified.

.2 Identification and Resolution of Problems (71111.08-02.05)

a. Inspection scope

The inspectors reviewed 18 condition reports which dealt with inservice inspection activities and found the corrective actions for inservice inspection issues were appropriate. The specific condition reports reviewed are listed in the documents reviewed section. From this review the inspectors concluded that the licensee has an appropriate threshold for entering inservice inspection issues into the corrective action program and has procedures that direct a root cause evaluation when necessary. The licensee also has an effective program for applying industry inservice inspection operating experience.

These actions constitute completion of requirements as defined in Inspection Procedure 71111.08-02.05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

a. Inspection Scope

On June 21, 2010, the inspectors observed a crew of licensed operators in the plants simulator 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

• Crews clarity and formality of communications

• Crews ability to take timely actions in the conservative direction

• Crews prioritization, interpretation, and verification of annunciator alarms

• Crews correct use and implementation of abnormal and emergency procedures

• Control board manipulations

• Oversight and direction from supervisors

• Crews ability to identify and implement appropriate technical specification actions and emergency plan actions and notifications

The inspectors compared the crews performance in these areas to pre-established operator action expectations and successful critical task completion requirements.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one quarterly licensed-operator requalification program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

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

• Emergency diesel generator jacket water heat exchangers

• Safety-related motor control center and load center stab/bus connection adequacy

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)

• Characterizing system reliability issues for performance

• Charging unavailability for performance

• Trending key parameters for condition monitoring

• Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)

• Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described in 10 CFR 50.65(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. Specific documents reviewed during this inspection are listed in the attachment.

This inspection activity represents a Review of Operating Experience Smart Sample FY2009-01, related to issues associated with inspections of electrical connections for motor control centers, circuit breakers, and interfaces. The inspectors searched the licensees corrective action database for issues involving inadequate stab/bus connections. The inspectors also reviewed the licensees inspection and maintenance processes, which ensure that motor control center and load center electrical connections are adequate.

These activities constitute completion of two quarterly maintenance effectiveness samples as defined in Inspection Procedure 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed licensee personnel'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:

• On April 7, 2010, during the breaker replacement, causing emergency core cooling system rooms sump pumps to be nonfunctional resulting in yellow risk condition

• On April 8, 2010, during plant air compressor capacity control valve maintenance

• Week of April 12, 2010, during the emergent work for flushing of the low pressure coolant injection trains suction piping and alternate decay heat removal system filling and venting resulting in the plant entering yellow risk

• Week of April 25, 2010, during plant shutdown and entry into shutdown cooling for refueling outage

• Week of May 10, 2010, during the core shuffle for the refueling outage

The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. 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 the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five maintenance risk assessments and emergent work control inspection samples as defined in Inspection Procedure 71111.13-05.

b. Findings

Introduction.

The inspectors identified a Green noncited violation of 10 CFR 50.65 a(4)for failure to perform adequate risk assessments prior to flushing the residual heat removal system suction piping and filling and venting of the alternate decay heat removal system.

Description.

On April 13, 2010, station personnel made three work activity additions to the plant work schedule to do the following:

• fill and vent the alternate decay heat removal system (residual heat removal C nonfunctional)

• flush the residual heat removal A system pump suction piping (residual heat removal A nonfunctional)

• flush the residual heat removal B system pump suction piping (residual heat removal B nonfunctional)

On April 14, 2010, the inspectors noted during the morning plant status meeting that emergent work had been added to the schedule. The inspectors requested the

emergent work documentation and associated risk assessments. On April 15, 2010, a review of the online risk assessment worksheets found a question under the category of nuclear safety risk assessment queried as to whether the, Activity removes from service redundant equipment where coincidental failure of one other component would reduce defense in depth. This particular question was answered no for all three assessments.

The inspectors determined that the emergent work would make the systems nonfunctional; therefore the worksheet question should have been answered with the affirmative. As such, per the online risk assessment procedure, a further risk assessment shall be performed to determine if the emergent work constituted a Medium or High risk to the station. This was not performed.

For work activities designated as Medium risk, the procedure required the responsible craft supervisors and coordinators, work management senior reactor operator, engineering, and the work week manager to specify risk management actions to manage the emergent work activity. For work activities designated as High risk, the procedure required a critical evolution meeting to specify risk management actions to manage the emergent work activity. The minimum risk management actions that must be considered for work activities designated as a Medium risk include:

• Performance of a pre-job brief to include why the activity is designated as higher risk

• Craft supervisors provide field supervisory monitoring

• System engineer is available for support

• No activities to be performed on redundant safety-related equipment at the same time

• Operational experience review of events related to work activities

• Task-experienced leaders selected to perform or directly oversee the activity The inspectors concluded that station personnel did not perform procedurally required risk management actions due to the failure to perform a risk assessment that would have placed the plant into a higher risk category.

The licensee documented this violation in Condition Report CR-GGN-2010-02553. Its short term corrective actions included implementing training to all responsible departments to ensure they understood the requirements of the new risk management procedure.

Analysis.

Failure of station personnel to perform an adequate risk assessment is a performance deficiency. The performance deficiency is more than minor because it is associated with the human performance attribute of the Mitigating Systems Cornerstone, adversely affecting the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using IMC 0609, Significance Determination Process, 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the inspectors evaluated the finding using IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process. Using Appendix K, the inspectors determined that the finding has very low safety significance because the finding was related only to the performance of risk management actions and did not exceed the threshold for core damage probability and large early release probability. The cause of this finding has a crosscutting aspect in the area of human performance associated with resources, because the licensee failed to provide adequate training on the implementation of the new risk management procedure H.2(b).

Enforcement.

Title 10 of the Code of Federal Regulations 50.65a(4) requires 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 this, on April 13, 2010, the licensee assessed an increase in station risk caused by planned flushing of the reactor heat removal suction lines and the filling and venting of the alternate decay heat removal system, but failed to take procedurally required actions to manage the increased risk. Because the violation was of very low safety significance and was entered into the licensee's corrective action program as Condition Report CR-GGN-2010-02553, this violation is being treated as a noncited violation consistent with Section VI.A.1 of the NRC Enforcement Policy:

NCV 05000416/2010003-01, Failure to Perform an Adequate Risk Assessment for Emergent Work Activities.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• Control room air conditioning B trip on compressor low oil pressure, CR-GGN-2010-02000

• Fuel pool cooling and cleanup pump trip on low suction flow, CR-GGN-2010-02172

• Quality control hold point demonstration of required inspections following plant modifications, CR-GGN-2009-06505

• Hydrogen analyzer alarm in the main control room with no condition report or operability performed, CR-GGN-2010-03016

• Standby service water gearbox inspection port cover degraded, CR-GGN-2010-02427

• Global Nuclear Fuel 2 bent corner tabs, CR-GGN-2010-02645

• Standby service water relief valves for pumps A and B, CR-GGN-2010-01333

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 technical specification 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 appropriate sections of the technical specifications and Updated Final Safety Analysis Report to the licensee personnels 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. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of seven operability evaluations inspection samples as defined in Inspection Procedure 71111.15-04

b. Findings

Introduction.

The inspectors reviewed a Green, self-revealing noncited violation of Technical Specifications 5.4.1(a), involving a loss of decay heat removal in the spent fuel pool due to station operators failing to follow the fuel pool cooling and cleanup system operating instruction.

Description.

On April 5, 2010, the control room dispatched a field operator to place the fuel pool cooling and cleanup system filter-demineralizer into the hold mode per the system operating instruction. The hold mode ensured that the filter bed is secured with flow from the holding pump when fuel pool cooling pump flow is bypassed around the filter/demineralizer. The procedure required the field operator to slowly reduce filter/demineralizer flow in either AUTO or MANUAL to approximately 500-600 gpm by adjusting the local flow controller that reads in percent. The operator was briefed that 500-600 gpm equates to approximately 37 percent on the flow controller. The operator began reducing the flow rate and, per the procedure, verified that the holding pump started automatically at approximately 66 percent. The operator continued to lower flow to 37 percent and then notified the control room. The procedure then required the control room reactor operator to raise bypass flow to approximately 500-600 gpm.

Based on erroneous communications, the operator in the field assumed this step had been completed. The field operator notified the control room that he was placing the flow controller in MANUAL to reduce the filter/demineralizer flow to zero. Again, due to an error in communication and the reactor operator mistakenly thinking that the field operator was on the previous step, the reactor operator responded in the affirmative.

Upon hearing the acknowledgement, the field operator reduced flow to zero percent.

The reactor operator had yet to establish the required bypass flow resulting in a low flow condition and a trip of the fuel pool cooling and cleanup system pump A. The main

control room entered the off-normal event procedure for inadequate decay heat removal, and approximately one hour later, spent fuel pool cooling was re-established. During this event spent fuel pool temperature did not exceed the limits required by Technical Requirements Manual Section 6.7.4.

The licensee documented this violation in Condition Report CR-GGN-2010-02172. Its short term corrective actions included the performance of a human performance review of the event. Operations management then used the results of this review to issue an operations learning to all operations department personnel reviewing the event and its causes.

Analysis.

Failure of operators to follow the fuel pool cooling and cleanup system operating instructions to ensure proper system alignment and function is a performance deficiency. The performance deficiency is more than minor because it is associated with the human performance attribute of the Barrier Integrity Cornerstone and adversely affects the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.

Using the Manual Chapter 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the inspectors determined that the finding has a very low safety significance because it only represented a loss of spent fuel pool cooling that would not preclude restoration of cooling to the spent fuel pool prior to pool boiling. 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 adequate self-and peer-checking techniques to remove the filter/demineralizer from service H.4(a).

Enforcement.

Technical Specification 5.4.1(a) requires written procedures to be implemented as recommended by Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Specifically, Regulatory Guide 1.33, Section 4.k Fuel Storage Pool Purification and Cooling System, requires instructions for controlling the storage and cooling of spent fuel pools. Section 4.3 of 04-1-01-G41-1, Fuel Pool Cooling and Cleanup System, Revision 59, requires a bypass flow to be established prior to isolating filter/demineralizer flow. Contrary to this, on April 5, 2010, the operators failed to establish a bypass flow prior to isolating filter/demineralizer flow. This caused the running fuel pool cooling and cleanup pump to trip, resulting in a loss of decay heat removal to the spent fuel pool. Because the violation was of very low safety significance and was entered into the licensee's corrective action program as Condition Report CR-GGN-2010-02172, this violation is being treated as a noncited violation consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000416/2010003-02, Failure to Follow Procedure Results in Loss of Decay Heat Removal to the Spent Fuel Pool.

1R18 Plant Modifications

.1 Temporary Modifications

a. Inspection Scope

To verify that the safety functions of important safety systems were not degraded, the inspectors reviewed the temporary modification identified as temporary modification to install bypass signals for turbine A first stage pressure sensor.

The inspectors reviewed the temporary modification and the associated safety-evaluation screening against the system design bases documentation, including the Updated Final Safety Analysis Report and the technical specifications, and verified that the modification did not adversely affect the system operability/availability. The inspectors also verified that the installation was consistent with the modification documents and that configuration control was adequate. Additionally, the inspectors verified that the temporary modification was identified on control room drawings, appropriate tags were placed on the affected equipment, and licensee personnel evaluated the combined effects on mitigating systems and the integrity of radiological barriers.

These activities constitute completion of one sample for temporary plant modifications as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings were identified.

.2 Permanent Modifications

a. Inspection Scope

The inspectors reviewed key parameters associated with materials, replacement components, heat removal, equipment protection from hazards, operations, flow paths, structural, process medium properties, licensing basis, and failure modes for the permanent modification identified as EC-15156 to restore the operating margin to the affected standby service water cooling towers.

The inspectors verified that modification preparation, staging, and implementation did not impair emergency/abnormal operating procedure actions, key safety functions, or operator response to loss of key safety functions; postmodification testing will maintain the plant in a safe configuration during testing by verifying that unintended system interactions will not occur; systems, structures and components performance characteristics still meet the design basis; the modification design assumptions were appropriate; the modification test acceptance criteria will be met; and licensee personnel identified and implemented appropriate corrective actions associated with permanent plant modifications. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample for permanent plant modification as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings were identified.

1R19 Postmaintenance Testing

a. Inspection Scope

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

• For division 2 loss of offsite power test following maintenance

• For residual heat removal minimum flow valve 1E12-F064C after the valve was replaced

• For control rod drive mechanism and control rod blade replacements

• For intermediate range nuclear instruments C and H after maintenance

• For the leading edge flow measurement following transducer replacement and electronic upgrades

• For main steam isolation valves following maintenance

• For reactor vessel inservice leak test following refueling outage

The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following:

• 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

The inspectors evaluated the activities against the technical specifications, the Updated Final Safety Analysis Report, 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 corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of seven postmaintenance testing inspection samples as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

The inspectors reviewed the outage safety plan and contingency plans for the Grand Gulf Refueling Outage 17, conducted from April 25 through May 27, 2010, to confirm that licensee personnel had appropriately considered risk, industry experience, and previous site-specific problems in developing and implementing a plan that assured maintenance of defense in depth. During the refueling outage, the inspectors observed portions of the shutdown and cooldown processes and monitored licensee controls over the outage activities listed below.

• Configuration management, including maintenance of defense in depth, is commensurate with the outage safety plan for key safety functions and compliance with the applicable technical specifications when taking equipment out of service

• Clearance activities, including confirmation that tags were properly hung and equipment appropriately configured to safely support the work or testing

• Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication, accounting for instrument error

• Status and configuration of electrical systems to ensure that technical specifications and outage safety-plan requirements were met, and controls over switchyard activities

• Monitoring of decay heat removal processes, systems, and components

• Verification that outage work was not impacting the ability of the operators to operate the spent fuel pool cooling system

• Reactor water inventory controls, including flow paths, configurations, and alternative means for inventory addition, and controls to prevent inventory loss

• Controls over activities that could affect reactivity

• Maintenance of secondary containment as required by the technical specifications

• Refueling activities, including fuel handling

• Startup and ascension to full power operation, tracking of startup prerequisites and walkdown of the drywell (primary containment) to verify that debris had not been left which could block emergency core cooling system suction strainers

• Licensee identification and resolution of problems related to refueling outage activities

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one refueling outage and other outage inspection sample as defined in Inspection Procedure 71111.20-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

.1 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the Updated Final Safety Analysis Report, procedure requirements, and technical specifications to ensure that the surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the following:

• Preconditioning

• Evaluation of testing impact on the plant

• Acceptance criteria

• Test equipment

• Procedures

• Jumper/lifted lead controls

• Test data

• Testing frequency and method demonstrated technical specification operability

• Test equipment removal

• Restoration of plant systems

• Fulfillment of ASME Code requirements

• Updating of performance indicator data

• Reference setting data

• Annunciators and alarms setpoints

The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.

• On March 13, 2010, control rod drive friction testing for control rod 16-21

• On April 30, 2010, primary containment isolation valves 1G36-F101 and 1G36-F106

• On April 27, 2010, thermal performance testing for residual heat removal heat exchanger A

• On May 7, 2010, loss of cooling accident/loss offsite power test for division 2

• On May 22, 2010, intermediate range nuclear instrument channels A, B, D, E, F, and G functional tests

• On May 24, 2010, reactor core isolation cooling low pressure vessel injection inservice test

• On May 28, June 1, and June 13, 2010, low pressure coolant injections/residual heat removal subsystems A, B, and C monthly functional tests

• On June 1, 2010, reactor coolant system leakage detection surveillance

Additional activities were performed during the review of low pressure coolant injection/residual heat removal monthly functional tests that were associated with TI 2515/177, Managing gas accumulation in emergency core cooling, decay heat removal, and containment spray systems. These activities are described in bullet

.2 of

this section.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of eight surveillance testing inspection samples as defined in Inspection Procedure 71111.22-05.

b. Findings

No findings were identified.

.2 Surveillance Testing Associated with TI 2515/177, Managing Gas Accumulation in

Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems

a. Inspection Scope

When reviewing Procedures 06-OP-1E12-M-0001/0002/0003, Low Pressure Coolant Injection/Residual Heat Removal Functional Test the inspectors verified that the procedures were acceptable for

(1) testing low pressure coolant injection/residual heat removal systems with power operation, shutdown operation, maintenance, and subject system modifications,

(2) void determination and elimination methods, and

(3) postevent evaluation.

The inspectors reviewed procedures used for conducting surveillances and determination of void volumes to ensure that the void criteria was satisfied and will be reasonably ensured to be satisfied until the next scheduled void surveillance (TI 2515/177, Section 04.03.a). Also, the inspectors reviewed procedures used for filling and venting following conditions which may have introduced voids into the subject systems to verify that the procedures acceptably addressed testing for such voids and provided acceptable processes for their reduction or elimination (TI 2515/177, Section 04.03.b). Specifically, the inspectors verified that:

• Gas intrusion prevention, refill, venting, monitoring, trending, evaluation, and void correction activities were acceptably controlled by approved operating procedures (TI 2515/177, Section 04.03.c.1)

• Procedures ensured the system did not contain voids that may jeopardize operability (TI 2515/177, Section 04.03.c.2)

• Procedures established that void criteria were satisfied and will be reasonably ensured to be satisfied until the next scheduled void surveillance (TI 2515/177, Section 04.03.c.3)

• The licensee entered changes into the corrective action program as needed to ensure acceptable response to issues. In addition, the inspectors confirmed that a clear schedule for completion is included for corrective action program entries that have not been completed. (TI 2515/177, Section 04.03.c.5)

• Procedures included independent verification that critical steps were completed (TI 2515/177, Section 04.03.c.6)

The inspectors verified the following with respect to surveillance and void detection:

• Specified surveillance frequencies were consistent with Technical Specification surveillance requirements (TI 2515/177, Section 04.03.d.1)

• Surveillance frequencies were stated or, when conducted more often than required by technical specifications the process for their determination was described (TI 2515/177, Section 04.03.d.2)

• Surveillance methods were acceptably established to achieve the needed accuracy (TI 2515/177, Section 04.03.d.3)

• Surveillance procedures included up-to-date acceptance criteria (TI 2515/177, Section 04.03.d.4)

• Procedures included effective follow-up actions when acceptance criteria are exceeded or when trending indicates that criteria may be approached before the next scheduled surveillance (TI 2515/177, Section 04.03.d.5)

• Measured void volume uncertainty was considered when comparing test data to acceptance criteria (TI 2515/177, Section 04.03.d.6)

• Venting procedures and practices utilized criteria such as adequate venting durations and observing a steady stream of water (TI 2515/177, Section 04.03.d.7)

• An effective sequencing of void removal steps was followed to ensure that gas does not move into previously filled system volumes (TI 2515/177, Section 04.03.d.8)

• Qualitative void assessment methods included expectations that the void will be significantly less that allowed by acceptance criteria (TI 2515/177, Section 04.03.d.9)

• Venting results were trended periodically to confirm that the systems are sufficiently full of water and that the venting frequencies are adequate. The inspectors also verified that records on the quantity of gas at each location are maintained and trended as a means of preemptively identifying degrading gas accumulations (TI 2515/177, Section 04.03.d.10)

• Surveillances were conducted at any location where a void may form, including high points, dead legs, and locations under closed valves in vertical pipes (TI 2515/177, Section 04.03.d.11)

• The licensee ensure that systems were not pre-conditioned by other procedures that may cause a system to be filled, such as by testing, prior to the void surveillance (TI 2515/177, Section 04.03.d.12)

The inspectors verified the following with respect to filling and venting and with respect to void control:

• Revisions to fill and vent procedures to address new vents or different venting sequences were acceptably accomplished (TI 2515/177, Section 04.03.e.1)

• Fill and vent procedures provided instructions to modify restoration guidance to address changes in maintenance work scope or to reflect different boundaries from those assumed in the procedure (TI 2515/177, Section 04.03.e.2)

• Void removal methods were acceptably addressed by approved procedures (TI 2515/177, Section 04.03.f.1)

Documents reviewed are listed in the attachment to this report.

This inspection effort counts towards the completion of TI 2515/177 which will be closed in a later inspection report.

b. Findings

No findings were identified.

2RS0 1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

This area was inspected to:

(1) review and assess licensees performance in assessing the radiological hazards in the workplace associated with licensed activities and the implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures,

(2) verify the licensee is properly identifying and reporting Occupational Radiation Safety Cornerstone performance indicators, and

(3) identify those performance deficiencies that were reportable as a performance indicator and which may have represented a substantial potential for overexposure of the worker.

The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensees procedures required by technical specifications as criteria for determining compliance. During the inspection, the inspectors interviewed the radiation protection manager, radiation protection supervisors, and radiation workers. The inspectors performed walkdowns of various portions of the plant, performed independent radiation dose rate measurements and reviewed the following items:

• Performance indicator events and associated documentation reported by the licensee in the Occupational Radiation Safety Cornerstone

• The hazard assessment program, including a review of the licenses evaluations of changes in plant operations and radiological surveys to detect dose rates, airborne radioactivity, and surface contamination levels

• Instructions and notices to workers, including labeling or marking containers of radioactive material, radiation work permits, actions for electronic dosimeter alarms, and changes to radiological conditions

• Programs and processes for control of sealed sources and release of potentially contaminated material from the radiologically controlled area, including survey performance, instrument sensitivity, release criteria, procedural guidance, and sealed source accountability

• Radiological hazards control and work coverage, including the adequacy of surveys, radiation protection job coverage, and contamination controls; the use of electronic dosimeters in high noise areas; dosimetry placement; airborne radioactivity monitoring; controls for highly activated or contaminated materials (nonfuel) stored within spent fuel and other storage pools; and posting and physical controls for high radiation areas and very high radiation areas

• Radiation worker and radiation protection technician performance with respect to radiation protection work requirements

• Audits, self-assessments, and corrective action documents related to radiological hazard assessment and exposure controls since the last inspection

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.01-05.

b. Findings

No findings were identified.

2RS0 2 Occupational ALARA Planning and Controls

a. Inspection Scope

This area was inspected to assess performance with respect to maintaining occupational individual and collective radiation exposures ALARA. The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensees procedures required by technical specifications as criteria for determining compliance.

During the inspection, the inspectors interviewed licensee personnel and reviewed the following items:

• Site-specific ALARA procedures and collective exposure history, including the current 3-year rolling average, site-specific trends in collective exposures, and source-term measurements

• ALARA work activity evaluations/post-job reviews, exposure estimates, and exposure mitigation requirements

• The methodology for estimating work activity exposures, the intended dose outcome, the accuracy of dose rate and man-hour estimates, and intended versus actual work activity doses and the reasons for any inconsistencies

• Records detailing the historical trends and current status of tracked plant source terms and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry

• Radiation worker and radiation protection technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas

• Audits, self-assessments, and corrective action documents related to ALARA planning and controls since the last inspection

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.02-05.

b. Findings

No findings were identified.

2RS0 3 In-plant Airborne Radioactivity Control and Mitigation

a. Inspection Scope

This area was inspected to verify that in-plant airborne concentrations are being controlled consistent with ALARA to the extent necessary to validate plant operations as reported by the performance indicator and to verify that the practices and use of respiratory protection devices on-site do not pose an undue risk to the wearer. The inspectors interviewed licensee personnel and reviewed the following:

• The licensees use, when applicable, of ventilation systems as part of its engineering controls

• The licensees respiratory protection program for use, storage, maintenance, and quality assurance of NIOSH certified equipment, qualification and training of personnel, and user performance

• The licensee=s capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, status of SCBA staged and ready for use in the plant and associated surveillance records, and personnel qualification and training

• Self-assessments, audits, corrective actions, and reports related to the respiratory protection program and devices

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one sample as defined in Inspection Procedure 71124.03-05.

OTHER ACTIVITIES

Cornerstones: Occupational Radiation Safety and Public Radiation Safety

4OA1 Performance Indicator Verification

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the performance indicator data submitted by the licensee for the first quarter 2010 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, Performance Indicator Program.

This review was performed as part of the inspectors normal plant status activities and, as such, did not constitute a separate inspection sample.

b. Findings

No findings were identified.

.2 Safety System Functional Failures (MS05)

a. Inspection Scope

The inspectors sampled licensee submittals for the safety system functional failures performance indicator for the period from the second quarter 2009 through the second quarter 2010. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5,

and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73." The inspectors reviewed the licensees operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports, and NRC integrated inspection reports for the period of April 2009 through June 2010, to validate the accuracy of the submittals. The inspectors also reviewed the licensees condition report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of one safety system functional failures sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.3 Reactor Coolant System Specific Activity (BI01)

a. Inspection Scope

The inspectors sampled licensee submittals for the reactor coolant system specific activity performance indicator for the period from the second quarter 2009 through the second quarter 2010. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5. The inspectors reviewed the licensees reactor coolant system chemistry samples, technical specification requirements, issue reports, event reports, and NRC integrated inspection reports for the period of April 2009 through June 2010, to validate the accuracy of the submittals. The inspectors also reviewed the licensees condition report database to determine if any problems had been identified with the performance indicator 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.

These activities constitute completion of one reactor coolant system specific activity sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.4 Reactor Coolant System Leakage (BI02)

a. Inspection Scope

The inspectors sampled licensee submittals for the reactor coolant system leakage performance indicator for the period from the second quarter 2009 through the second

quarter 2010. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5.

The inspectors reviewed the licensees operator logs, reactor coolant system leakage tracking data, condition reports, event reports, and NRC integrated inspection reports for the period of April 2009 through June 2010, to validate the accuracy of the submittals.

The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of one reactor coolant system leakage sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.5 Occupational Exposure Control Effectiveness (OR01)

a. Inspection Scope

The inspectors reviewed performance indicator data for the third quarter 2009 through the first quarter 2010. The objective of the inspection was to determine the accuracy and completeness of the performance indicator data reported during these periods. The inspectors used the definitions and clarifying notes contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, as criteria for determining whether the licensee was in compliance.

The inspectors reviewed corrective action program records associated with high radiation area (greater than 1 R/hr) and very high radiation area non-conformances. The inspectors reviewed radiological, controlled area exit transactions greater than 100 millirems. The inspectors also conducted walkdowns of high radiation areas (greater than 1 R/hr) and very high radiation area entrances to determine the adequacy of the controls of these areas.

These activities constitute completion of the occupational exposure control effectiveness sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.6 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual

Radiological Effluent Occurrences (PR01)

a. Inspection Scope

The inspectors reviewed performance indicator data for the third quarter 2009 through the first quarter 2010. The objective of the inspection was to determine the accuracy and completeness of the performance indicator data reported during these periods. The inspectors used the definitions and clarifying notes contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, as criteria for determining whether the licensee was in compliance.

The inspectors reviewed the licensees corrective action program records and selected individual annual or special reports to identify potential occurrences such as unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose.

These activities constitute completion of the radiological effluent technical specifications/offsite dose calculation manual radiological effluent occurrences sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings 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 Routine Review of Identification and Resolution of Problems

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 licensees corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective actions. Minor issues entered into the licensees corrective action program because 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 were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection 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 licensees corrective action program. The inspectors accomplished this through review of the stations daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees corrective action program and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused their review on repetitive equipment issues, but also considered the results of daily corrective action item screening discussed in Section 4OA2.2, above, licensee trending efforts, and licensee human performance results. The inspectors nominally considered the 7-month period of November 1, 2009 through May 31, 2010, although some examples expanded beyond those dates where the scope of the trend warranted.

The inspectors also included issues documented outside the normal corrective action program in major equipment problem lists, repetitive and/or rework maintenance lists, departmental problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self-assessment reports, and Maintenance Rule assessments.

The inspectors compared and contrasted their results with the results contained in the licensees corrective action program trending reports. Corrective actions associated with a sample of the issues identified by NRC inspectors were reviewed for adequacy.

These activities constitute completion of one semi-annual trend inspection sample as defined in Inspection Procedure 71152-05.

b. Findings and Observations

No findings were identified.

The inspectors reviewed 394 condition reports and identified potential adverse trends in the following areas:

• Problem identification

• Procedure compliance

• Implementation of regulations

• Attention to detail

• Inadequate documentation of corrective actions

• Housekeeping

• License compliance

• Configuration control

• Corrective action program effectiveness

• Licensing document inaccuracy

• Work practices

The inspectors selected 78 out of 394 condition reports on issues identified by NRC inspectors for follow-up of corrective actions. The inspectors evaluated the licensees corrective action program for complete and timely corrective actions. The inspectors observed that the licensee had performed detailed reviews of developing issues and had taken appropriate actions. In addition to those trends identified by the licensee, the inspectors noted the following:

Procedure Compliance. The inspectors reviewed 19 condition reports documenting procedure compliance concerns, most of which did not result in plant events. The inspectors reviewed the corrective action plans to prevent recurrence and methods to produce improvement in the area of human performance. Although some improvement was noted, the inspectors concluded that continued focus in this area is required.

Housekeeping. The inspectors identified numerous examples of housekeeping and general plant cleanliness well below industry standards. The inspectors reviewed the

licensees improvement plan and received a briefing from the maintenance manager on plans to improve lighting, material conditions, and plant cleanliness.

Problem Identification. The inspectors reviewed over 40 condition reports initiated to address concerns brought to the licensees attention by NRC inspectors. These concerns varied across multiple organizations, examples include: a training record deficiency, several condition reports not written in a timely manner, several examples of oil on equipment/floor, loose cables in cable trays, and a caution tag hung incorrectly, and condensation on temporary power units.

Conclusion. In conclusion it appears the standards at the Grand Gulf Nuclear Station have taken a step back from second quarter 2009 to present with a noted negative trend during the most recent refueling outage. The licensee is aware of this and is continuing to make improvement plans to correct this adverse trend.

4OA5 Other Activities

(Open) NRC TI 2515/177, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems (NRC Generic Letter 2008-01)

As documented in Sections 1R04 and 1R22, the inspectors confirmed the acceptability of the described licensees actions. This inspection effort counts towards the completion of TI 2515/177 which will be closed on a later inspection report.

4OA6 Meetings

Exit Meeting Summary

On July 13, 2010, the inspectors presented the inspection results to Mr. R. Douet, Vice President, Operations, 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.

On May 7, 2010, the inspectors presented the radiation safety inspection results of the inspection above, to Mr. R. Douet, Vice President, Operations, 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.

On May 12, 2010, the inspectors presented the inspection results of the review of inservice inspection activities to Mr. R. Douet, Vice President, Operations, 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.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by the licensee and are violations of NRC requirements which meet the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as noncited violations.

• Grand Gulf Nuclear Power Stations fire protection program requires control of transient combustible materials in the plant. Contrary to the above, between May 5 and May 11, 2010, plant personnel failed to maintain control of transient combustible materials in accordance with the fire protection program. Specifically, the licensee identified several improperly controlled items in combustible control zones (transient combustible exclusion areas) on the 166 foot, 139 foot, and 119 foot elevations of the auxiliary building. Items included: plastic signs on the 166 foot elevation; yellow gloves on the 139 foot elevation; a rolling work bench with combustible items on top, as well as various loose plastic and paper items in the area, a hand cart on the 119 foot elevation; and, other various transient combustibles stored outside approved combustible storage areas without transient combustible evaluation permits. These issues were entered into the corrective action program as Condition Reports CR-GGN-2010-03232, CR-GGN-2010-03330, CR-GGN-2010-03601, CR-GGN-2010-03604, CR-GGN-2010-03147, CR-GGN-2010-03151, CR-GGN-2010-03783, and CR-GGN-2010-03822. Corrective actions for these issues included removing the materials from the combustible exclusion zones, providing additional oversight of the transient combustibles control program, and reinforcing the requirements of a transient combustible exclusion zone with the workers. This finding is of very low safety significance because although it violated the licensees program for the control of transient combustibles in an exclusion zones, it was determined to be of low degradation due to the amount of material found in the areas was negligible.

• Title 10 CFR Part 72.122(c), Protection against Fires and Explosions, states that Noncombustible and heat-resistant materials must be used wherever practical throughout the Independent Spent Fuel Storage Installation. Contrary to this, on May 10, 2010, the licensee identified lumber being staged inside the transient combustible exclusion zone near the independent spent fuel storage installation. The licensee had the material removed from the area and restored compliance. This issue was documented in the licensees corrective action program in Condition Report CR-GGN-2010-03739. This finding is of very low safety significance because although it violated the licensees program for the control of transient combustibles in an exclusion zone, it was determined to be of low degradation due to the amount of material staged was approximately 200 pounds of fire resistant wood and material location was greater than 70 feet away from the dry fuel storage pad.

• Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states that Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Contrary to this, on June 27, 2009, the licensee identified a degraded inspection port gasket on the fan B gearbox of service water cooling tower A which was weeping oil. A work order was modified to add

steps to perform a repair of the gearbox by replacing the defective gasket. Maintenance personnel signed the work order as complete without performing the additional instructions. This issue was documented in the licensees corrective action program in Condition Report CR-GGN-2010-02427. This finding is of very low safety significance because it did not represent a loss of system safety function, did not represent the actual loss of safety function of a single train for greater than its technical specification allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Browning, General Plant Manager

A. Cockrum, Site Welding Engineer

D. Coulter, Licensing

R. Douet, Site Vice President

G. Giles, Corrective Action Program Manager

R. James, Containment Examinations

J. Keir, Snubbers and Supports

A. Kelly, ISI Implementer

D. Maye, Repair and Replacement Program Manager

R. McGaha, ISI Engineering

C. Perino, Licensing Manager

P. Rescheske, Licensing

T. Trichell, Radiation Protection Manager

R. Williams, Corporate Fleet ISI Lead

D. Wiles, Engineering Director

NRC Personnel

R. Kumano, Project Engineer

B. Hagar, Senior Project Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

TI 2515/177

Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems (NRC Generic Letter 2008-01) (Section 4OA5)

Opened and Closed

05000416/2010003-01 NCV Failure to Perform an Adequate Risk Assessment for Emergent Work Activities (Section 1R13)

05000416/2010003-01 NCV Failure to Follow Procedure Results in Loss of Decay Heat Removal to the Spent Fuel Pool (Section 1R15)