IR 05000416/2013007
| ML14016A466 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 01/16/2014 |
| From: | Ray Kellar Division of Reactor Safety IV |
| To: | Kevin Mulligan Entergy Operations |
| References | |
| IR-13-007 | |
| Download: ML14016A466 (20) | |
Text
UNITED STATES NUC LEAR REGULATOR Y C OMMI SSI ON ary 16, 2014
SUBJECT:
GRAND GULF NUCLEAR STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000416/2013007
Dear Mr. Mulligan On December 5, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution Biennial Inspection at Grand Gulf Nuclear Station Unit 1. The enclosed inspection report documents the inspection results discussed on December 5, 2013, with Thomas Coutu, Director, Regulatory Assurance and Performance Improvement, and other members of your staff.
This inspection was an examination of activities conducted under your license as they relate to problem identification and resolution and compliance with the Commissions rules and regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
Based on the inspection sample, the inspection team concluded that the implementation of the corrective action program and overall performance identifying, evaluating, and resolving problems at Grand Gulf Nuclear Station was generally effective. Licensee identified problems were generally entered into the corrective action program at a low threshold. Problems were generally prioritized and evaluated commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner. Lessons learned from industry operating experience were effectively reviewed and applied when appropriate. Audits and self-assessments were effectively used to identified problems and appropriate actions. A safety-conscious work environment has generally been maintained but there are indications of challenges to this environment.
No findings were identified during this inspection.
K. Mulligan -2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (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/
Ray L. Kellar, P.E., Chief Technical Support Branch Division of Reactor Safety Docket No.: 05000416 License No.: NPF-29 Enclosure: Inspection Report 05000416/2013007 w/Attachments:
1. Supplemental Information 2. Information Request Electronic Distribution to Grand Gulf Nuclear Station
K. Mulligan -3-S:\DRS\REPORTS\Reports Final\GG 2013007-PI&R-HAF.docx ML14016A466 SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials HAF Publicly Avail. Yes No Sensitive Yes No Sens. Type Initials HAF SRI:DRS/TSB SSI:DRS/PSB1 RI:DRP/PBC SRI:DRS/TSB C:DRP/PBC C:DRS/TSB HAFreeman JRLarsen BBRice LRWilloughby DBAllen RLKellar
/RA/ /E/ /E/ /E/ /RA/ /RA/
1/13/14 1/13/14 1/13/14 1/14/14 1/14/14 1/16/14 OFFICIAL RECORD COPY
OFFICIAL RECORD COPY U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 05000416 License: NPF-29 Report: 05000416/2013007 Licensee: Entergy Operations, Inc.
Facility: Grand Gulf Nuclear Station, Unit 1 Location: 7003 Baldhill Road Port Gibson, MS 39150 Dates: September 23 through December 5, 2013 Team Leader: H. Freeman, Senior Reactor Inspector Inspectors: J. Larsen, Senior Physical Security Inspector B. Rice, Resident Inspector L. Willoughby, Senior Reactor Inspector Approved By: R. Kellar, P.E., Chief Technical Support Branch Division of Reactor Safety-1- Enclosure
SUMMARY OF FINDINGS
IR 05000416/2013007; September 23, 2013 - December 5, 2013; Grand Gulf Nuclear Station
Biennial Baseline Inspection of the Identification and Resolution of Problems.
Two regional senior reactor inspectors, one regional senior physical security inspector, and one resident inspector performed this team inspection. No findings of significance were identified during this inspection. 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.
Identification and Resolution of Problems The team reviewed approximately 950 condition reports, work orders, engineering evaluations, root and apparent cause evaluations, and other supporting documentation to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. The team reviewed a sample of system health reports, self-assessments, trending reports and metrics, and various other documents related to the corrective action program. Licensee identified problems were entered into the corrective action program at a low threshold. Problems were generally prioritized and evaluated commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner. Corrective actions were generally implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of problems.
The licensee appropriately evaluated industry operating experience for relevance to the facility and had entered applicable items in the corrective action program. The licensee used industry operating experience when performing root cause and apparent cause evaluations. The licensee performed effective quality assurance audits and self-assessments, as demonstrated by self-identification of poor corrective action program performance and identification of ineffective corrective actions.
NRC-Identified and Self-Revealing Findings
No findings of significance were identified.
Licensee-Identified Violations
None
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
The team based the following conclusions on the sample of corrective action documents initiated during the assessment period, which ranged from October 21, 2011, to the end of the on-site portion of the inspection on December 5, 2013.
.1 Assessment of the Corrective Action Program Effectiveness
a. Inspection Scope
The team reviewed 950 condition reports, including associated root cause, apparent cause, and direct cause evaluations, from approximately 20,000 that had been issued during the assessment period to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. The team reviewed a sample of system health reports, operability determinations, self-assessments, trending reports and metrics, and various other documents related to the corrective action program. The team evaluated the licensees efforts in establishing the scope of problems by reviewing selected logs, work requests, self-assessments results, audits, system health reports, action plans, and results from surveillance tests and preventive maintenance tasks. The team reviewed work requests and attended the licensees daily condition review group meeting and the management review committee meetings to assess the reporting threshold, prioritization efforts, and significance determination process, as well as observing the interfaces with the operability assessment and work control processes when applicable. The team assessed the timeliness and effectiveness of corrective actions, completed or planned, and looked for additional examples of similar problems.
The team also reviewed corrective action documents that addressed past NRC-identified violations to ensure that the corrective action addressed the issues as described in the inspection reports. The inspectors reviewed a sample of corrective actions closed to other corrective action documents to ensure that corrective actions were still appropriate and timely.
The team considered risk insights from both the NRCs and Grand Gulf Nuclear Station risk assessments to focus the sample selection and plant tours on risk significant systems and components. The team selected the following risk significant systems: Reactor Protection System, Divisions I & II Emergency Diesel Generator.
The samples reviewed by the team focused on, but were not limited to, these systems. The team also expanded their review to include five years of evaluations involving these systems to determine whether problems were being effectively addressed. The team conducted a walkdown of the emergency diesel generators to assess whether problems were identified and entered into the corrective action program.
b. Assessments 1. Assessment - Effectiveness of Problem Identification The team concluded that the licensee generally identified problems at a low threshold and entered them into the corrective action program in accordance with the licensees corrective action program guidance and the NRC requirements.
The licensee had written approximately 20-thousand corrective action documents during the two year period of review, 30 percent of which had been identified by the licensee as conditions adverse to quality. The team noted that the licensee had failed to identify and address four conditions adverse to quality in the corrective action program during the assessment period as documented in the NRC inspection reports that would indicate that additional attention may be warranted in this area.
- Finding 2012003 was issued for failure to ensure material is stored properly in the 500 KV switchyard.
- Non-cited violation 2012008-04, was issued for failure to promptly enter an NRC violation regarding the standby service water system into the corrective action program.
- Non-cited violation 2012301-01, was issued for inadequate procedure for aligning nitrogen backup to automatic deressurization system.
- Non-cited violation 2013002-04, was issued for failure to correct a scaffold affecting fire brigade access.
2. Assessment - Effectiveness of Prioritization and Evaluation of Issues The team concluded that the licensee was generally effective in performing and/or documenting evaluations of conditions adverse to quality during this assessment period. The team reviewed corrective action documents that involved operability reviews to assess the quality, timeliness, and prioritization of operability assessments. The team concluded that operability assessments were generally completed in an appropriate manner.
The team monitored the licensees action request review committee and the corrective action review board meetings. The team found that the licensee was effectively reviewing and prioritizing conditions adverse to quality.
The team found that in general, condition reports were appropriately prioritized and evaluated; however, the team noted three examples of ineffective prioritization or evaluation that had been documented during the assessment period.
- Non-cited violation 2012008-02 was issued for failure to establish a testing program for safety-related 125 Vdc circuit breakers. Specifically, the licensee failed to thoroughly evaluate the extent of condition associated with previously identified NRC violation involving the failure to test 480 Vac molded case circuit breakers that had been identified during the 2009 component design basis inspection.
- Non-cited violation 2012008-05 was issued for failure to follow procedures which resulted in inadequate operability determinations. Specifically, the licensee failed to validate that the operability evaluations associated with an oil leak on the standby liquid control pump B and with degraded bolts on a flanged connection on standby service water B piping completed for prior non-conforming conditions bounded the conditions documented in the new condition.
- Non-cited violation 2012005-02 was issued for failure to make timely corrective actions to repair the degraded auxiliary building water intrusion barrier. This was because the licensee failed to properly classify these conditions as adverse to quality.
3. Assessment - Effectiveness of Corrective Action Program Overall, the team concluded that the licensee did develop appropriate corrective actions to address problems based on a sample size of 950. The team identified one corrective actions associated with conditions adverse to quality that was not completed in a timely manner (see previous section).
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The team examined the licensee's program for reviewing industry operating experience (OE), including reviewing the governing procedure and self-assessments.
A sample of operating experience notifications that had been issued during the assessment period were reviewed to assess whether the licensee had appropriately evaluated the notification for relevance to the facility. The team then examined whether the licensee had entered those items into their corrective action program and assigned actions to address the issues. The team reviewed root cause evaluations and corrective action documents to verify if the licensee had appropriately included industry-operating experience.
b. Assessment Overall, the team determined that the licensee was adequately evaluating industry operating experience for relevance to the facility. The licensee had entered applicable items in the corrective action program in accordance with station procedures. While the team found that the licensee was generally implementing operating experience into the corrective action program, one example was documented during the assessment associated with the use of operating experience.
- Non-cited violation 2012008-06 was issued for failure to incorporate test and inspection requirements for 4160 Vac Circuit Breakers into Preventive Maintenance Procedures. Specifically, the licensee did not implement and institutionalize vender information and industry guidance into their maintenance and testing procedure.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The team reviewed a sample size of five licensee self-assessments, surveillances, and audits to assess whether the licensee was regularly identifying performance trends and effectively addressing them. The team reviewed audit reports to assess the effectiveness of assessments in specific areas. The team evaluated the use of self- and third party assessments, the role of the quality assurance department, and the role of the performance improvement group related to licensee performance.
b.
Assessment The team found that the internal self-assessments and audits were generally thorough, detailed, and critical. Corrective actions were initiated and implemented in a timely manner.
.4 Assessment of Safety-Conscious Work Environment
a. Inspection Scope
The inspection team conducted individual and focus group interviews with over 50 individuals. The interviewees represented various functional organizations and ranged across contractor, staff, and supervisor levels. The team conducted these interviews to assess whether conditions existed that would challenge the establishment of a safety conscious work environment at the Grand Gulf Nuclear Station. The team also reviewed the results of the most recent site-wide safety culture survey taken in February 2012 and aspects of the employee concerns program.
b.
Assessment Overall, the licensee has a safety conscious work environment at the Grand Gulf Nuclear Station. During interviews, personnel indicated they felt free to raise safety issues and enter them in the corrective action program. If not satisfied with the resolution, the majority of the personnel did indicate that they would raise issues beyond their immediate supervisor or would use other avenues such as going to the employee concerns coordinator or the NRC. The majority of the personnel felt they could raise issues without fear of retaliation; however, some indicated that would not raise issues past their immediate supervisor for fear of retaliation. This minority set of personnel did not provide examples but they felt if they went beyond their immediate supervisor, they would be labeled as troublemakers and would receive some form of retaliation. An increase in the number of anonymous condition reports submitted during the period of January 2008 to November 2013 may be an indicator of this perception. The ongoing human capital management efforts by Entergy where many employees were concerned with remaining employed may also have contributed to this perception.
The results of the licensees 2012 safety culture survey also indicated that challenges to the safety conscious work environment may exist at the facility.
The results placed the Grand Gulf Nuclear Station in the bottom quartile when compared to the nuclear industry and last (eighth out of eight) when compared to the rest of the Entergy fleet. The results also showed a declining trend in all areas as compared to the previous survey taken in 2009.
A high-level review of the employee concerns program revealed a higher number of harassment, intimidation, retaliation, and discrimination cases during the two-year period than is typical of most programs. The program had received and addressed eight such cases and substantiated three. The program also had received and addressed four cases involving an adverse safety-conscious work environment and substantiated three. The team noted that all of these cases were associated with the extended power uprated in 2012, and involved contract employees.
Senior licensee management acknowledged the less than favorable results from the 2012 safety culture survey and the employee concerns program cases.
Management described the actions that had been taken or that were in progress to improve the environment. These actions included forming employee-working groups to address potential causes, focusing on long-standing equipment issues, and leadership changes. However, while employees interviewed by the NRC were aware of the 2012 safety culture results and knew of managements initial actions to address them, they were not aware of any ongoing efforts to improve the environment.
The team concluded that while a work environment where employees feel free to raise safety concerns without fear of retaliation generally exists at the Grand Gulf Nuclear Station; there are indications of challenges to this environment based on the licensees safety culture assessment and NRC interviews.
4OA5 Other Activities
(Closed) Followup of Corrective Actions for Violation 05000416/2011006-04 Inadequate Corrective Action for a Leak on the Division II Emergency Diesel Generator Lube Oil Sump The team reviewed the status of the corrective actions to address a violation cited in January 2012, for failure to implement adequate corrective actions to address an oil leak on the Division II emergency diesel generator lube oil sump. The condition had been discovered and documented by the licensee in 2004, and was initially determined by the NRC to be a minor violation in 2009. However, by late 2011, the licensee had still not taken actions to correct the condition or characterize the flaw. In response, the NRC concluded the finding more than minor because if left uncorrected, the failure to restore the lube oil sump to design conditions had the potential to lead to a more significant safety concern, specifically, the leak could worsen and potentially affect operability of the emergency diesel generator.
The team found that the licensee has made progress in addressing the leak. The licensee had entered the condition into their corrective action program and assigned an appropriate priority.
The licensee initiated a method to evaluate the leak rate and was able to determine that it did not affect the operability of the diesel and was not increasing. Because the leak was in a location not easily accessible, they have not been able to pinpoint the source of the leak and fully characterize the flaw but they do believe that the leak is likely to be from a bolted flange on the side of the tank. The licensee has a work order planned to replace the gasket in the bolted connection and to verify the integrity of the welded connections during the next available diesel outage.
The team concluded that while the licensee has yet to correct this condition, their efforts to locate, and characterize the flaw and to monitor the leak rate provided reasonable assurance that the condition did not affect the operability of the diesel generator and would not degrade without notice. Additionally, the team concluded that the amount of time that has elapsed since being cited for this violation was not unreasonable given the few available opportunities that have occurred and was in line with the low safety significance of the condition. This open action item is being closed based upon the condition being in the licensees corrective action program, and based upon actions already taken and planned to address the condition.
4OA6 Meetings
Exit Meeting Summary
On December 5, 2013, the team presented the inspection results to Thomas Coutu, Director, Regulatory Assurance and Performance Improvement, and other members of the licensee staff.
The licensee acknowledged the issues presented. The licensee advised that no materials examined during the inspection were considered to be proprietary.
4OA7 Licensee-Identified Violations
None ATTACHMENTS:
1. Supplemental Information 2. Information Request
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
Richard Scarborough Licensing Specialist
Kevin Christian Production Manager
Paul Salgado Production Outage Manager
Jeff Gerard Operations Manager
Roy Miller Radiation Protection Manager
Michael Milly Maintenance Manager
James Nadeau Corrective Actions and Assessment Manager
Gerald Giles Training Manager
Thomas Coutu Director, Regulatory Assurance and Performance Improvement
Dennis Wiles Director, Engineering
Thomas Thornton Manager, Design Engineering
Jeff Seiter Acting Manager, Licensing
James Owen Coordinator, Employee Concerns Program
NRC personnel
Richard Smith Senior Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Closed
- 05000416/2011006-04 VIO Inadequate Corrective Action for a Leak on the Division II Emergency Diesel Generator Lube Oil Sump