IR 05000416/2012004

IR 05000416-12-004, on 06/23/2012 09/21/2012, Grand Nuclear Station, Unit 1, Integrated Resident and Regional Report; Operability Evaluations and Functionality Assessments

ML12306A258
Person / Time
Site:	Grand Gulf
Issue date:	11/01/2012
From:	Hagar B NRC/RGN-IV/DRP/RPB-C
To:	Mike Perito Entergy Operations
Hagar B
References
IR-12-004
Download: ML12306A258 (45)

Text

UNITED STATES ber 1, 2012

SUBJECT:

GRAND GULF NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT NUMBER 05000416/2012004

Dear Mr. Perito:

On September 21, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Grand Gulf Nuclear Station, Unit 1. The enclosed inspection report documents the inspection results which were discussed on October 10, 2012, 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.

One NRC-identified finding of very low safety significance (Green) was identified during this inspection. This finding was determined to involve a violation of NRC requirements.

Further, a licensee-identified violation, which was determined to be of very low safety significance is listed in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy. If you contest these non-cited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Grand Gulf Nuclear Station.

If you disagree with a cross-cutting aspect assignment 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.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Document Access and Management 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/

Bob Hagar, Chief (Acting)

Project Branch C Division of Reactor Projects Docket No.: 50-416 License No: NPF-29 Enclosure: Inspection Report 05000416/2012004 w/ Attachment: Supplemental Information cc w/encl: Chairperson, Radiological Assistance Committee Region IV Federal Emergency Management Agency Department of Homeland Security 3003 Chamblee-Tucker Road Atlanta, GA 30341 Chairperson, Radiological Assistance Committee Region VI Federal Emergency Management Agency Department of Homeland Security 800 North Loop 288 Federal Regional Center Denton, TX 76201-3698 Electronic Distribution for Grand Gulf Nuclear Station

SUMMARY OF FINDINGS

IR 05000416/2012004; 06/23/2012 - 09/21/2012; GRAND GULF NUCLEAR STATION, UNIT 1,

Integrated Resident and Regional Report; Operability Evaluations and Functionality Assessments.

The report covered a 3-month period of inspection by resident inspectors and announced baseline inspections by region-based inspectors. One Green non-cited violation of significance was identified. The significance of most findings is indicated by their color (Green, White,

Yellow, or Red) using Inspection Manual Chapter 0609, Significance Determination Process.

The cross-cutting aspect is determined using Inspection Manual Chapter 0310, Components Within the Cross Cutting Areas. 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 two examples of a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, regarding the licensees failure to follow the requirements of Procedure EN-OP-104, Operability Determinations. Specifically, for Condition Report CR-GGN-2012-09690, which documents an oil leak on the standby liquid control pump B, and for Condition Report CR-GGN-2012-09889, which documents degraded bolts on a flanged connection on standby service water B piping, the licensee failed to validate that operability evaluations completed for prior non-conforming conditions bounded the conditions documented in the new condition reports. As immediate corrective actions, the licensee re-performed the evaluations and established an adequate basis for operability for the conditions described in the two condition reports listed above. The licensee entered this issue into their corrective action program as CR-GGN-2012-09735 and CR-GGN-2012-10664.

The finding was more than minor because if left uncorrected, not performing operability determinations in accordance with procedure could lead to a more significant safety concern. Specifically, if a condition renders a safety related system inoperable and because of this performance deficiency the licensee incorrectly determines that the system is operable, then this performance deficiency could result in a safety related system remaining inoperable for a long period of time. Using NRC Inspection Manual Chapter 0609, Attachment 4,

"Initial Characterization of Findings," the inspectors determined that the issue affected the Mitigating Systems Cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, the inspectors determined that the issue has very low safety significance (Green) because although it affected the design or qualification of a mitigating system, the system maintained its operability.

The finding had a cross-cutting aspect in the problem identification and resolution area, corrective action program component because the licensee failed to properly evaluate for operability conditions adverse to quality P.1(c)

(Section 1R15).

Licensee-Identified Violations

A violation of very low safety significance was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and associated corrective action tracking numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Grand Gulf Nuclear Station (GGNS) began the inspection period at 73% thermal power following refueling outage 18 and the plant achieved 100% power on June 24, 2012. During this inspection period GGNS was granted a license amendment to increase power from their current license thermal power (CLTP) of 3898 mwth to the extended power uprate (EPU) level of 4408 mwth.

• On July 3, 2012, the operators reduced power to 73% CLTP due to an elevated temperature on one of the generator stator bars. The licensee determined the cause to be a faulty thermocouple giving false indications, and the plant was returned to 100%

CLTP the same day.

• On July 27, 2012, operators reduced power to 57% CLTP for a planned rod pattern adjustment in preparation to increase power to the EPU power level.

• On July 28, 2012, operators increased power to 90% CLTP for the initial phase of extended power uprate tests (equivalent power of 78% EPU).

• On July 30, 2012, operators increased power to 100% CLTP (equivalent power of 88% EPU).

• On August 1, 2012, operators increased power above 100% CLTP for the first time.

Power was increased to 90% EPU (equivalent power of 102.5% CLTP), and the plant remained at this power level for extended power uprate testing in accordance with the license amendment.

• On August 10, 2012, operators increased power to 92.5% EPU, and the plant remained at this power level for extended power uprate testing in accordance with the license amendment.

• On August 24, 2012, operators increased power to 95% EPU, and the plant remained at this power level for extended power uprate testing in accordance with the license amendment.

• On August 28, 2012, operators increased power to 97.5% EPU, and the plant remained at this power level for extended power uprate testing in accordance with the license amendment.

• On September 8, 2012, operators increased power to 100% EPU and performed extended power uprate testing in accordance with the license amendment.

• On September 15, 2012, operators reduced power to 70% EPU for planned control rod sequence exchange and turbine testing. The plant was returned to 100% EPU power on September 18,

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

Due to Hurricane Isaac, thunderstorms with potential tornados and high winds were forecast in the vicinity of the facility for August 29 and 30, 2012. The inspectors reviewed the plant personnels overall preparations/protection for the expected weather conditions. On August 28, 2012, the inspectors walked down the standby service water system basins because their safety-related functions could be affected, or required, as a result of high winds or tornado-generated missiles or the loss of offsite power. The inspectors evaluated the plant staffs preparations against the sites procedures and determined that the staffs actions were adequate. During the inspection, the inspectors focused on plant-specific design features and the licensees 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 Updated Final Safety Analysis Report and performance requirements for the 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 licensee-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.

These activities constitute completion of one readiness for impending adverse weather condition sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Partial Walkdown

a. Inspection Scope

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

• Division II emergency diesel generator following a surveillance

• Low pressure core injection/residual heat removal C following a surveillance

• Division I emergency diesel generator while division II emergency diesel generator was inoperable due to emergent work

• Standby fresh air A while Standby fresh air B was inoperable due to maintenance on control room air conditioning system B 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 four partial system walkdown samples as defined in Inspection Procedure 71111.04-05.

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 room A119, 93 foot elevation of the auxiliary building

• Division III emergency diesel generator room D304, 133 foot elevation of the diesel generator builing

• Division I switchgear rooms A208 & A219, 119 foot elevation of the auxiliary building

• Division II switchgear rooms A207 & A221, 119 foot elevation of the auxiliary building 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 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 four quarterly fire-protection inspection samples as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors reviewed the Updated Final Safety Analysis Report, the flooding analysis, and plant procedures to assess susceptibilities involving internal flooding; reviewed the corrective action program to determine if licensee personnel identified and corrected flooding problems; inspected underground bunkers/manholes to verify the adequacy of sump pumps, level alarm circuits, cable splices subject to submergence, and drainage for bunkers/manholes; and verified that operator actions for coping with flooding can reasonably achieve the desired outcomes. The inspectors also inspected the areas listed below to verify the adequacy of equipment seals located below the flood line, floor and wall penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, and control circuits, and temporary or removable flood barriers.

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

• July 11, 2012, internal sump pump level switches for reactor core isolation cooling/high pressure core spray rooms and 93 foot elevation of the auxiliary building These activities constitute completion of one flood protection measures inspection sample as defined in Inspection Procedure 71111.06-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Quarterly Review of Licensed Operator Requalification Program

a. Inspection Scope

On June 28, 2012, the inspectors observed a crew of licensed operators in the plants simulator during training. The inspectors assessed the following areas:

• Licensed operator performance during simulator training evaluation at 4408 mwth power

• The ability of the licensee to administer the evaluations

• The quality of post-scenario critiques

• Follow-up actions taken by the licensee for identified discrepancies 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.

.2 Quarterly Observation of Licensed Operator Performance

a. Inspection Scope

On July 3, 2012, the inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity due to an unplanned down power in response to a high temperature alarm on the generator stator slot 55 upper bar. The operators reduced reactor power from 100% to 73% CLTP by decreasing recirculation pump speed and inserting 4 control rods. The operators also verified all other associated parameters, e.g. turbine building cooling water and other stator bar temperatures, were in normal range and stable. The licensee determined the cause of the alarm was a failed thermocouple on the generator stator slot 55 upper bar. The licensee developed an alternate monitoring plan per standing order 12-0005 and returned reactor power to 100% CLTP.

In addition, the inspectors assessed the operators adherence to plant procedures, including EN-OP-115, Revision 12, Conduct of Operations, and other operations department policies.

These activities constitute completion of one quarterly licensed-operator performance 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:

• Maintenance Rule a(3) assessment Review The inspectors reviewed the a(3) assessment report that addressed events 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)

These activities constitute completion of one quarterly maintenance effectiveness sample 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:

• Week of June 25, 2012, due to emergent repair of bypass valves hydraulic trip

• Week of July 30, 2012, due to emergent issue making division II diesel generator inoperable/non-functional and extended power uprate power ascension activities

• Week of August 6, 2012, due to emergent issue concerning a containment vent valve failed surveillance

• Week of August 17, 2012, risk management with divers in standby service water basin

• Week of August 20, 2012, during low pressure core spray outage and extended power uprate power ascension activities 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

No findings were identified.

1R15 Operability Evaluations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed the following assessments:

• Standby liquid control pump B oil leak, CR-GGN-2012-09690

• Standby service water flange bolts degraded, CR-GGN-2012-09889 The inspectors selected these operability and functionality assessments based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure technical specification operability was properly justified and to verify 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 licensees 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. Additionally, the inspectors 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 two operability evaluations inspection samples as defined in Inspection Procedure 71111.15-05.

b. Findings

Introduction.

The inspectors identified two examples of a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, regarding the licensees failure to follow the requirements of Procedure EN-OP-104, Operability Determinations. Specifically, the inspectors identified two examples in which the licensee failed to establish an adequate basis for operability when a degraded or nonconforming condition had been identified.

Description.

Procedure EN-OP-104, Operability Determinations, Revision 6, provides the guidance used by operations staff at Grand Gulf Nuclear Station to perform operability determinations. Paragraph 5.3.7 requires that if a condition report indentifies a degraded condition that has been previously identified and evaluated, the evaluation is validated to confirm that it bounds the condition described in the new condition report.

As described below, the inspectors identified two examples of operability determinations that did not meet this requirement.

In the first example, Condition Report CR-GGNS-2012-09690 was initiated to document an oil leak on a bolted connection on the standby liquid control pump B gear box. The pump was declared operable based on an evaluation performed for Condition Report CR-GGNS-2010-00283, which also described an oil leak on the standby liquid control pump. The inspectors challenged the validity of the previous evaluation because the standby liquid control system was modified in the spring of 2012 during refueling outage 18 and the initial evaluation was for a leak around a loose fitting plug versus a bolted connection. The licensee entered this issue into the corrective action process under Condition Report CR-GGNS-2012-09735. Upon further inspection of the standby liquid control pump, the licensee determined there was no active oil leak on the pump gear box and declared the system operable.

In the second example, Condition Report CR-GGNS-2012-09889 was initiated to document degraded flange bolts on the 24 inch HBC-82 piping in the B standby service system basin. The pipe was declared operable based on an evaluation performed for Condition Report CR-GGNS-2011-05009, which also described degraded flange bolts on 24 inch HBC-82 piping in the B standby service water basin. The inspectors challenged the validity of the previous evaluation because the calculations used the wrong design pressure for calculating the number of bolts required to maintain the integrity of the flange. Mechanical Standard 02 (MS-02) provides two design requirements for 24 inch HBC-82 piping. The design pressure the licensee used for the operability evaluation, 180 psig, is for applications above ground level (133 foot elevation). The pipe that was the subject of the evaluation is below ground level, in which MS-02 requires the design pressure of 195 psig be used. The licensee entered this issue into the corrective action program as Condition Report CR-GGNS -2012-10664. As an immediate corrective action, the license re-performed the evaluation with the correct design parameters and determined the number of non-degraded flange bolts was sufficient to declare the system operable. Also, since the nature of the degradation was such that the material strength of the bolts was not impacted, the bolts were cleaned, re-coated with a protective coating, and will be replaced during the next scheduled inspection.

Analysis.

The failure to perform operability determinations in accordance with procedure was a performance deficiency. The performance deficiency was more than minor and is a finding because if left uncorrected, not performing operability determinations in accordance with procedure could lead to a more significant safety concern. Specifically, if a condition renders a safety related system inoperable and because of this performance deficiency the licensee incorrectly determines that the system is operable, then this performance deficiency could result in a safety related system remaining inoperable for a long period of time. Using NRC Inspection Manual Chapter 0609, 4, "Initial Characterization of Findings," the inspectors determined that the issue affected the Mitigating Systems Cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, the inspectors determined that the issue has very low safety significance (Green) because although it affected the design or qualification of a mitigating system, that system maintained its operability. The inspectors determined that the apparent cause of this finding was that in both examples, the licensee had identified and used previously completed operability evaluations without verifying that the previously completed evaluations were fully applicable to the identified conditions.

Therefore, the finding had a cross-cutting aspect in the problem identification and resolution area, corrective action program component because the licensee failed to properly evaluate for operability conditions adverse to quality P.1(c).

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, that activities affecting quality shall be prescribed by documented instructions or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions or drawings. Procedure EN-OP-140, Operability Determinations, Revision 6, in part, requires the licensee to validate that if an operability evaluation was completed for a prior non-conforming condition, the operability evaluation bounds the condition documented in the new condition report. Contrary to this requirement, on August 7 and August 14, 2012, the licensee failed to validate that if an operability evaluation was completed for a prior non-conforming condition, the operability evaluation bounds the condition documented in the new condition report. Specifically, Condition Reports CR-GGN-2012-09690 and CR-GGN-2012-09889 document non-conforming conditions in which the licensee failed to validate that operability evaluations completed for prior non-conforming conditions bounded the conditions documented in the new condition reports. As an immediate corrective action, the license re-performed the evaluations and established an adequate basis for operability for the conditions described in the two condition reports described above. This violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy because it was of very low safety significance (Green) with no actual safety consequence, and it was entered into the licensees corrective action program as CR-GGN-2012-09735 and CR-GGN-2012-10664 to address recurrence. (NCV 05000416/2012004-02, Failure to Follow Procedure Results in Inadequate Operability Determinations)

1R19 Post-Maintenance Testing

a. Inspection Scope

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

• Plant air compressor B scheduled maintenance

• Standby service water fan A scheduled maintenance

• Diesel driven fire pump A scheduled maintenance

• Containment airlock inner door on the 119' auxiliary building elevation 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 (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 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 post-maintenance 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 four post-maintenance testing inspection samples as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings were identified.

1R22 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

• 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 July 6, 2012, chemistry reactor coolant system sample

• On July 28, 2012, average power range monitoring (APRM) gain adjustment

• On August 14, 2012, scram discharge volume (C51) 1/2 Scram

• On September 18 and 20, 2012, routine low pressure turbine stop and control valve testing and main turbine bypass valve testing Specific documents reviewed during this inspection are listed in the attachment.

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

b. Findings

No findings were identified.

1EP2 Alert and Notification System Evaluation

a. Inspection Scope

The inspector discussed with licensee staff the operability of offsite emergency warning systems and backup alerting methods, to determine the adequacy of licensee methods for testing the alert and notification system in accordance with 10 CFR Part 50, Appendix E. The licensees alert and notification system testing program was compared with the following:

• NUREG-0654, A Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (Revision 1)

• FEMA Report REP-10, A Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants The FEMA-approved design for the licensees alert and notification system is addressed in the following document:

• Grand Gulf Nuclear Station REP-10 Design Review Report dated January 2010.

The specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.02-05.

b. Findings

No findings were identified.

1EP3 Emergency Response Organization Staffing and Augmentation

a. Inspection Scope

The inspector discussed with licensee staff the operability of primary and backup systems for augmenting on-shift staff to determine the adequacy of licensee methods for staffing emergency response facilities in accordance with their emergency plan and the requirements of 10 CFR Part 50, Appendix E, including provisions for staffing alternate or backup facilities. The inspector also reviewed licensee training on augmentation procedures, augmentation system testing programs, and selected entries in the licensee corrective action system related to emergency response facility staffing. The specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.03-05.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes (IP 71114.04)

a. Inspection Scope

The NSIR headquarters staff performed an in-office review of the latest revision of an Emergency Plan Implementing Procedure (EPIP) located under ADAMS accession number ML12129A106 as listed in the Attachment.

The licensee transmitted the EPIP revision to the NRC pursuant to the requirements of 10 CFR 50, Appendix E, Section V, Implementing Procedures. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the Attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.04-05.

b. Findings

No findings were identified.

1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies

a. Inspection Scope

The inspector reviewed the licensees corrective action program requirements as stated in the Grand Gulf Nuclear Station procedures. The inspector reviewed summaries of corrective action program documents assigned to the emergency preparedness department and emergency response organization between November 2010 and September 2012, and selected 29 for detailed review against the program requirements.

The inspector evaluated the response to the corrective action requests to determine the licensees ability to identify, evaluate, and correct problems in accordance with the licensee program requirements, planning standard 10 CFR 50.47(b)(14), and 10 CFR Part 50, Appendix E. The specific documents reviewed during this inspection are listed in the attachment.

The inspector also reviewed:

• Licensee audits, assessments, drill evaluations, and post-event after action reports conducted between November 2010 and September 2012;

• Memorandum of Understanding between the licensee and offsite agencies and organizations relied upon to support site emergency response efforts;

• Licensee procedures and training for the evaluation of changes to the site emergency plans;

• Maintenance records for equipment relied upon to support site emergency response efforts; and,

• Alternate facilities for the licensees Emergency Operations Facility, Technical Support Center, and Operational Support Center.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.05-05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on September 6, 2012, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the Emergency Operations Facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.06-05.

b. Findings

No findings were identified.

.2 Training Observations

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on July 12, 2012, 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 crews performance and ensure that the licensee evaluators noted the same issues and entered them into the corrective action program. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.06-05.

b. Findings

No findings were identified.

OTHER ACTIVITIES

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

4OA1 Performance Indicator Verification

.1 Data Submission Issue

a. Inspection Scope

The inspector reviewed data submitted by the licensee for the fourth quarter 2011, first quarter 2012, and second quarter 2012 emergency preparedness performance indicators to identify any obvious inconsistencies prior to its public release in accordance with Inspection Manual 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.

.13 Drill/Exercise Performance (EP01)

a. Inspection Scope

The inspector sampled licensee submittals for the Drill and Exercise Performance, performance indicator for the period from the 4th quarter 2011 through the 2nd quarter 2012. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revisions 6, was used. The inspector reviewed the licensees records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspector reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator; assessments of performance indicator opportunities during predesignated control room simulator training sessions, performance during the 2011 biennial exercise, and performance during other drills. The specific documents reviewed are described in the attachment to this report.

These activities constitute completion of the drill/exercise performance sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.14 Emergency Response Organization Drill Participation (EP02)

a. Inspection Scope

The inspector sampled licensee submittals for the Emergency Response Organization Drill Participation performance indicator for the period from the 4th quarter 2011 through the 2nd quarter 2012. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, was used. The inspector reviewed the licensees records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspector reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator, rosters of personnel assigned to key emergency response organization positions, and exercise participation records. The specific documents reviewed are described in the attachment to this report.

These activities constitute completion of the emergency response organization drill participation sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.15 Alert and Notification System (EP03)

a. Inspection Scope

The inspector sampled licensee submittals for the Alert and Notification System performance indicator for the period from the 4th quarter 2011 through the 2nd quarter 2012. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, was used. The inspector reviewed the licensees records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspector reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator and the results of periodic alert notification system operability tests. The specific documents reviewed are described in the attachment to this report.

These activities constitute completion of the alert and notification system sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.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 Selected Issue Follow-up Inspection

Review of Technical Rigor of Title 10 CFR 50.59 Screenings

a. Inspection Scope

The inspectors chose to review CR-GGN-2011-08185, which addressed the condition described as 10 CFR 50.59 screenings lack technical rigor to confirm a change has no adverse effects and thus does not require a 10 CFR 50.59 evaluation. As a result, changes to the facility have been implemented without conducting an adequate 10 CFR 50.59 screening/evaluation. The inspectors reviewed the apparent cause evaluation and associated corrective actions for not only CR-GGN-2011-08185, but also several related condition reports. The inspectors also reviewed associated procedures and interviewed several members of the involved licensee staff. Documents reviewed are listed in the attachment.

b. Findings

No findings were identified.

Review of Multiple Control Rod Drive Pump Trips During Mode Switch Surveillance

a. Inspection Scope

The inspectors chose to review CR-GGN-2012-04007, which addressed the condition described as two CRD pump trips while performing the Mode Switch Surveillance. The inspectors reviewed the apparent cause evaluation and associated corrective actions for not only CR-GGN-2011-04007, but also several related condition reports. The inspectors also reviewed associated procedures and interviewed several members of the involved licensee staff. Documents reviewed are listed in the attachment.

These activities constitute completion of two in-depth problem identification and resolution sample as defined in Inspection Procedure 71152-05.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 Power Uprate Related Inspection Activities: Monitor Major Integrated Tests

a. Inspection Scope

During this inspection period, the inspectors observed portions of the power ascension testing which are described in Appendix 9 of the license amendment request. The inspectors reviewed the following:

• Core performance, which included evaluating the core thermal power and flow and determining whether the maximum linear heat generation rate, the minimum critical power ratio, and the maximum average planar linear heat generation rate were within limits

• Water level set point, manual feed water flow changes, which verified that the feedwater system had been adjusted to provide acceptable reactor water level control

• APRM calibration, which calibrated the APRM system to the EPU power level These activities constitute completion of one inspection sample as defined in Inspection Procedure 71004, Section 2.01.

b. Findings

No findings were identified.

.2 Power Uprate Related Inspection Activities: Integrated Plant Operations at the Uprated

Power Level (71004)

a. Inspection Scope

During the inspection period, the inspectors observed operator actions during integrated plant evolutions conducted during the power ascention to uprated power levels. The inspectors also reviewed operating procedures that were amended due to the power uprate. The inspectors observed the operators increase power from the original license power of 3898 MWth to the extended power uprate power level of 4408 MWth by incrementally increasing power by 2.5%. Following each incremental power increase, the inspectors observed operators actions during the power ascension testing program accordance with Appendix 9 of the extended power uprate license amendment. The operator actions observed were:

• Operators adjusted the reactor water level set point to test the response of the feedwater system

• Operators adjusted the feed water flow to test the response of the feedwater system

• Operators calibrated the average power range monitoring system for the new EPU power level These activities constitute completion of one inspection samples as defined in Inspection Procedure 71004, Section 2.01.

b. Findings

No findings were identified.

.3 Power Uprate Related Inspection Activities: Simulator Upgrade and Training for EPU

(71004)

b. Inspection Scope

On June 28, 2012, the inspectors performed a simulator training evaluation at 4408 mwth power. As documented in Section 1R11 of this report, the inspectors verified that EPU upgrades such as the power range neutron monitoring system and the thermohydraulic instability indicators were incorporated in the simulator. The inspectors observed crew performance with in terms of clarity and formality of communication, the crews ability to take timely action in the safe direction, prioritizing, interpreting, and verifying alarms. The inspectors also verified the operators correctly implemented procedures and Technical Specifications that had been updated for EPU. The inspectors determined the crew performed timely control board manipulations and had proper oversight and direction from the shift supervisor. The inspectors also observed the licensees critique of the licensed operators performance following the training scenario.

These activities constitute completion of one inspection sample as defined in Inspection Procedure 71004, Section 2.01.

b. Findings

No findings were identified.

.4 Licensee Strike Contingency Plans

a. Inspection Scope

On September 13, 2012, the bargaining unit security officers at the Grand Gulf Nuclear Station voted against the ratification of the contract due to expire on September 30, 2012. The inspectors initiated inspection procedure 92709, Licensee Strike Contingency Plans. The inspectors evaluated the adequacy of the strike contingency plan by reviewing the plan for required minimum number of qualified personnel available for proper security of the facility. The inspectors attended the meeting in which the onsite safety review committee reviewed the plan for adequacy.The inspectors interviewed security management and security training personnel and observed training excercises to ensure strike contingency personnel met all the requirements to fill in for potential striking staff. Documents reviewed as part of this inspection are listed in the attachment.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On September 14, 2012, the inspector presented the onsite emergency preparedness inspection results to Mr. M. Perito, Site Vice President, and other members of the licensees staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On October 10, 2012, the inspectors presented the inspection results to Mr. Perito and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector 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 violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements, which meets the criteria of the NRC Enforcement Policy for being dispositioned as a Non-Cited Violation.

Title 10 CFR 50.65(a)(4), states, in part, that before performing maintenance activities (including but not limited to surveillance, post maintenance 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, before performing a certain maintenance activity, the licensee failed to assess and manage the increase in risk that may result from that activity. Specifically, on September 5, 2012, the licensee performed Surveillance Procedures 06-IC-1C61-R-0005, RCIC Turbine Speed Calibration, Revision 101, and 06-IC-1C11-Q-0003, Scram Discharge Volume High Water Level Float Switch Functional Test, Revision 103, concurrently without assessing and managing the increase in risk, which resulted in the unplanned occurrence of an Orange risk configuration. The licensee entered this issue into their corrective action program in Condition Report CR-GGN-2012-10454. The finding was more than minor because it was associated with the Initiating Events Cornerstone attribute of human error, and it affected the associated cornerstone objective to limit the likelihood of those events that upset plant stability and that challenge critical safety functions during power operations. Using Inspection 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 that finding has very low safety significance (Green) based on a licensees calculated determination of the incremental core damage probability deficit of 9.36E-11. Using the current revision of the plant-specific SPAR model, an NRC senior reactor analyst validated that result.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Browning, General Plant Manager

J. Dorsey, Security Manager

H. Farris, Assistant Operations Manager

D. Fearn, Emergency Planner

J. Giles, Manager, Training

K. Higgenbotham, Manager, Planning and Scheduling

D. Jones, Manager, Design Engineering

C. Justiss, Licensing

C. Lewis, Manager, Emergency Preparedness

W. Mashburn, EPU Director

J. Miller, Manager, Operations

L. Patterson, Manager, Program Engineering

C. Perino, Licensing Manager

M. Perito, Vice President, Operations

R. Pownall, Quality Assurance

W. Renz, Corporate Director, Emergency Planning

M. Richey, Director, Nuclear Safety Assurance

R. Scarbrough, Specialist and Lead Offsite Liaison, Licensing

J. Seiter, Senior Licensing Specialist

J. Shaw, Manager, System Engineering

T. Trichell, Manager, Radiation Protection

D. Tucker, Emergency Planner

R. VanDenAkker, Senior Emergency Planner

D. Wiles, Engineering Director

NRC Personnel

R. Smith, Senior Resident Inspector

B. Rice, Resident Inspector

Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

Failure to Follow Procedure Results in Adequate Operability

05000416-2012-004-02 NCV Determinations (Section 1R15)