IR 05000416/2014004

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IR 05000416/2014004, July 1, 2014 Through September 30, 2014, Grand Gulf, Unit 1; Equipment Alignment and Follow-up of Events and Notices of Enforcement Discretion
ML14301A364
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 10/28/2014
From: Gerond George
NRC/RGN-IV/DRP/RPB-C
To: Kevin Mulligan
Entergy Operations
George G
References
IR-2014004
Download: ML14301A364 (30)
v • d • e


Text

October 28, 2014

SUBJECT:

GRAND GULF NUCLEAR STATION - NRC INSPECTION REPORT 05000416/2014004

Dear Mr. Mulligan:

On September 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Grand Gulf Nuclear Station, Unit 1. On October 2, 2014, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented two findings of very low safety significance (Green) in this report.

One of these findings involved a violation of NRC requirements.

If you contest the violation or significance of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Grand Gulf Nuclear Station.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 the Grand Gulf Nuclear Station.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents 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).

SUNSI Review By: GGeorge ADAMS Yes No Publicly Available Non-Publicly Available Non-Sensitive Sensitive

OFFICE SRI:DRP/C RI:DRP/C SPE:DRP/C C:DRS/EB1 C:DRS/EB2 C:DRS/OB C:DRS/PSB1 NAME MWilliams/dll BParks RAzua TFarnholtz GWerner VGaddy MHaire SIGNATURE

/RA/E-George

/RA/E-George

/RA/

/RA/

/RA/

/RA/

/RA/

DATE 10/28/14 10/27/14 10/17/14 10/20/14 10/20/14 10/20/14 10/22/14 OFFICE C:DRS/PSB2 C:DRS/TSB BC:DRP/C

NAME HGepford GMiller GGeorge

SIGNATURE

/RA/

/RA/

/RA/

DATE 10/20/14 10/20/14 10/28/14 DISTRIBUTION:

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

DRP Acting Deputy Director (Jason.Kozal@nrc.gov)

DRP Director (Troy.Pruett@nrc.gov)

DRS Director (Anton.Vegal@nrc.gov)

Deputy DRS Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector, Acting (Megan.Williams@nrc.gov)

Resident Inspector, Acting (Brian.Parks@nrc.gov)

Grand Gulf Administrative Assistant (Alley.Farrell@nrc.gov)

Acting Branch Chief, DRP/C (Gerond.George@nrc.gov)

Senior Project Engineer (Ray.Azua@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Alan.Wang@nrc.gov)

Branch Chiefs, DRP (R4DRP-BC@nrc.gov)

Branch Chiefs, DRS (R4DRS-BC@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RI Congressional Affairs Officer (Angel.Moreno@nrc.gov)

RIV/ETA: OEDO (John.Jandovitz@nrc.gov)

Regional State Liaison Officer (Bill.Maier@nrc.gov)

NSIR/DPR/EP (Eric.Schrader@nrc.gov)

ROPreports

- 1 -

Enclosure U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket:

05000416 License:

NPF-29 Report:

05000416/2014004 Licensee:

Entergy Operations, Inc.

Facility:

Grand Gulf Nuclear Station, Unit 1 Location:

7003 Baldhill Road Port Gibson, MS 39150 Dates:

July 1 through September 30, 2014 Inspectors: B. Rice, Senior Resident Inspector B. Baca, Project Engineer P. Nizov, Acting Resident Inspector B. Parks, Acting Resident Inspector M. Williams, Acting Senior Resident Inspector Approved By:

Gerond George Acting Chief, Project Branch C Division of Reactor Projects

- 2 -

SUMMARY

IR 05000416/2014004; 07/01/2014 - 09/30/2014; Grand Gulf Nuclear Station; Equipment

Alignment and Follow-up of Events and Notices of Enforcement Discretion

The inspection activities described in this report were performed between July 1 and September 30, 2014, by the resident inspectors and inspectors from the NRCs Region IV office.

Two findings of very low safety significance (Green) are documented in this report. One of these findings involved a violation of NRC requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects Within the Cross-Cutting Areas.

Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Cornerstone: Initiating Events

Green.

The inspectors reviewed a self-revealing finding for the licensee's failure to follow procedure EN-LI-102, "Corrective Action Process, Revision 12, which requires the licensee to appropriately complete assigned corrective actions within the prescribed time frame. On March 29, 2014, with Grand Gulf Nuclear Station operating at 87 percent power, a capacitor in a multiplier module of the main turbine overspeed protection circuit failed, causing the load reject relay to actuate. The main turbine control valves closed and an automatic actuation of the reactor protection system occurred, resulting in a plant scram. The root cause analysis noted that a corrective action initially assigned in 2007 in association with a single point vulnerability review was not completed in the prescribed time frame. The corrective action required that the module in question, which contained a single point vulnerability, either be rebuilt so as to reduce the probability that an age-related failure capable of triggering the vulnerability would occur, or replaced with a new design that eliminated the vulnerability altogether. The licensee entered this issue into the corrective action program under Condition Report CR-GGN-2014-03131. Immediate corrective actions following the scram included replacing the failed module with a spare module that had been visually inspected and functionally checked. Long term corrective actions include replacing the module with a component that does not exhibit single point vulnerability.

The licensee's failure to follow procedure by failing to appropriately complete assigned corrective actions was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective, in that it increased the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Using NRC Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of Findings," dated June 19, 2012, the inspectors determined that the issue affected the Initiating Events Cornerstone. Using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process for Findings At-Power," dated June 19th, 2012, the finding was determined to be of very low safety significance (Green) because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigating equipment would not be available. The finding was a latent issue and is not reflective of present licensee performance; therefore, no cross-cutting aspect was assigned (Section 4OA3).

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of License Condition 2.C(41), Fire Protection Program, for the failure to control transient combustibles in accordance with a fire protection program procedure. On August 13, 2014, the inspectors identified unattended transient combustible material stored within a combustible exclusion zone in Fire Zone 1A222 of the auxiliary building 119 elevation. The inspectors reported the occurrence to the operations shift manager and determined licensee personnel had not performed a transient combustible evaluation of the contents of the carts. The licensee documented this issue in Condition Report CR-GGN-2014-05842. As an immediate corrective action, the licensee moved the material to an appropriate designated area.

The failure to control transient combustible material in accordance with the approved fire protection program is a performance deficiency. The performance deficiency was more than minor and therefore a finding because it was associated with the protection against external factors attribute of the Mitigating System Cornerstone and adversely affected the cornerstone objective in that the transient combustible materials decreased the external event mitigation for fire prevention. Using NRC Inspection Manual Chapter 0609,

Attachment 4, Initial Characterization of Findings, June 19, 2012, the inspectors determined that the issue affected the Mitigation Systems Cornerstone and that the finding pertained to a failure to adequately implement fire prevention and administrative controls for transient combustible materials. As a result, the inspectors were directed to Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process,

September 20, 2013. The inspectors evaluated the finding through Appendix F,

Attachment 1, Fire Protection Significance Determination Process Worksheet,

September 20, 2013, and determined that the finding was of very low safety consequence (Green) because the Fire Prevention and Administrative Controls finding would not prevent the reactor from reaching and maintaining a safe shutdown condition. The apparent cause of this finding was incorrect assumptions and mental shortcuts or biases. This finding had a cross-cutting aspect in the human performance area associated with conservative bias, in that licensee staff failed to use decision making-practices that emphasize prudent choices over those that are simply allowable [H.14]. (Section 1R04)

PLANT STATUS

The operators began the inspection period at 92 percent reactor thermal power and continued performing power ascension activities until 100 percent reactor thermal power was reached on July 2, 2014.

On July 4, 2014, the operators reduced power to 84 percent reactor thermal power to remove heater drain pump A from service due to a steam leak. The operators returned the plant to 100 percent reactor thermal power that same day.

On July 15, 2014, the operators reduced power to 88 percent reactor thermal power due to heater drain pump B operating in a run-out condition and having elevated vibration readings.

The operators maintained power at 88 percent until heater drain pump A was returned to service. On August 15, 2014, heater drain pump A was returned to service, and the operators increased power to 100 percent reactor thermal power.

On August 18, 2014, the operators reduced power to 80 percent reactor thermal power for monthly control rod exercises. The operators returned the plant to 100 percent reactor thermal power on August 22, 2014.

On September 5, 2014, the operators reduced power to 55 percent reactor thermal power for a sequence exchange and control rod scram time testing. The operators returned the plant to 100 percent reactor thermal power on September 12, 2014, and remained at full power through the end of the inspection period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

Main article: IP 71111.04

.1 Partial Walkdown

a. Inspection Scope

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

  • August 13, 2014, division three diesel generator following a monthly surveillance The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration.

These activities constituted three partial system walk-down samples as defined in Inspection Procedure 71111.04.

b. Findings

Introduction.

The inspectors identified a Green non-cited violation of License Condition 2.C(41), Fire Protection Program, for the failure to control transient combustibles in accordance with a fire protection program procedure.

Description.

On August 13, 2014, the inspectors identified unattended transient combustible material stored within a combustible exclusion zone in Fire Zone 1A222 of the auxiliary building 119 foot elevation. The combustible materials included 100 feet of plastic hose, a 50-foot extension cord, approximately 100 feet of Permalon tape, two 25-gallon plastic barrels, and several other miscellaneous plastic items. The items were located in wheeled carts within the designated combustible exclusion zone and were not attended by plant personnel. The estimated weight for the transient combustible material was less than 50 pounds. Procedure EN-DC-161, Control of Combustibles, Revision 10, Section 5.6[3], requires a transient combustible evaluation before the introduction of material to a Level 1 Combustible Control Zone (Transient Combustible Exclusion Area). Attachment 9.2, GGNS - Combustible Control Zones, of EN-DC-161 allows for transient combustible material in a Level 1 Zone without a transient combustible evaluation if the material is less than 50 pounds of Class A combustibles and is constantly attended. The inspectors reported the occurrence to the operations shift manager and determined licensee personnel had not performed a transient combustible evaluation of the contents of the carts. The licensee documented this issue in Condition Report CR-GGN-2014-05842. As an immediate corrective action, the licensee moved the material to an appropriate designated area.

Analysis.

The failure to control transient combustible material in accordance with the approved fire protection program is a performance deficiency. The performance deficiency was more than minor and therefore a finding because it was associated with the protection against external factors attribute of the Mitigating System Cornerstone and adversely affected the cornerstone objective in that the transient combustible materials decreased the external event mitigation for fire prevention. Using NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, dated June 19, 2012, the inspectors determined that the issue affected the Mitigating Systems Cornerstone and that the finding pertained to a failure to implement fire prevention and administrative controls adequately for transient combustible materials. As a result, the inspectors were directed to Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, dated September 20, 2013. The inspectors evaluated the finding through Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated September 20, 2013, and determined that the finding was of very low safety consequence (Green) because the impact of the Fire Prevention and Administrative Controls finding would not prevent the reactor from reaching and maintaining a safe shutdown condition. The apparent cause of this finding was incorrect assumptions and mental shortcuts or biases. This finding had a cross-cutting aspect in the human performance area associated with conservative bias, in that licensee staff failed to use decision making-practices that emphasize prudent choices over those that are simply allowable [H.14].

Enforcement.

Grand Gulf Nuclear Station Unit 1 Facility Operating License Condition 2.C(41), Fire Protection Program, requires the licensee to implement and maintain in effect all provisions of the approved Fire Protection Program as described in Revision 5 to the Updated Final Safety Analysis Report (UFSAR). UFSAR Table 9.5-11, Fire Protection Program Comparison with NRC Requirements, provides Grand Gulf Station Position on meeting NRCs Appendix A to Branch Technical Position APCSB 9.5-1, dated August 23, 1976. Position C.2 states, in part, the scope of the Fire Protection Quality Assurance Program for Grand Gulf Nuclear Station was limited to selected aspects of 10 CFR 50, Appendix B. Specifically, Criteria III - V, VII, X, XI, and XIV - XVIII of Appendix B were invoked. 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-DC-161, Control of Combustibles, Revision 10, Section 5.6[3] requires a transient combustible evaluation before the introduction of material to a Level 1 Combustible Control Zone (Transient Combustible Exclusion Area). Contrary to the above, on August 13, 2014, the licensee did not perform a transient combustible evaluation before introducing material to a Level 1 Combustible Control Zone (Transient Combustible Exclusion Area). Specifically, the licensee stored and left combustible material unattended in a combustible exclusion zone. This violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy. The violation was entered into the licensees corrective action program as CR-GGN-2014-005842. (NCV 05000416/2014004-01, Failure to Control Transient Combustible Material in Accordance with a Fire Protection Procedure).

1R05 Fire Protection

Main article: IP 71111.05

.1 Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on five plant areas important to safety:

  • July 1, 2014, low pressure core spray pump room (1A119)
  • July 10, 2014, auxiliary building refuel floor (1A603 and 1A604)
  • August 11, 2014, division three diesel generator room

For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constituted five quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

Main article: IP 71111.06

a. Inspection Scope

On September 17, 2014, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose the floor drain system installed in three plant areas containing risk-significant structures, systems, and components that were susceptible to flooding:

The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.

In addition, on July 11, 2014, the inspectors completed an inspection of underground bunkers susceptible to flooding. The inspectors selected two underground bunkers that contained risk-significant or multiple-train cables whose failure could disable risk-significant equipment:

  • July 11, 2014, manholes MH20 and MH21

The inspectors observed the material condition of the cables and splices contained in the bunkers and looked for evidence of cable degradation due to water intrusion. The inspectors verified that the cables and vaults met design requirements.

These activities constitute completion of one flood protection measures sample and one bunker/manhole sample, as defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

Main article: IP 71111.11

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On July 16, 2014, the inspectors observed an evaluated simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance.

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 Review of Licensed Operator Performance

a. Inspection Scope

On September 5, 2014, 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 a scheduled down power to 55 percent reactor thermal power to perform a control rod sequence exchange, control rod scram time testing, and turbine testing. The inspectors observed the operators performance of the following activities:

  • Power reduction by reducing core flow
  • Minimization of control room distractions

In addition, the inspectors assessed the operators adherence to plant procedures, including conduct of operations procedure 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

Main article: IP 71111.12

a. Inspection Scope

The inspectors reviewed two instances of degraded performance or condition of safety-related structures, systems, and components (SSCs):

  • August 28, 2014, Maintenance Rule a(3) self-assessment review

The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of two maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

a. Inspection Scope

The inspectors reviewed three risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:

  • August 8, 2014, change in risk due to severe weather in the area
  • August 10, 2014, change in risk due to severe weather in the area

The inspectors verified that these risk assessment were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessment and verified that the licensee implemented appropriate risk management actions based on the result of the assessment.

The inspectors also observed portions of two emergent work activities that had the potential to affect the functional capability of mitigating systems:

  • July 1, 2014, division two diesel generator causing the completion of scheduled maintenance to be delayed
  • August 29, 2014, division one diesel generator oil leak repair

The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected SSCs.

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

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

Main article: IP 71111.15

a. Inspection Scope

The inspectors reviewed six operability determinations and functionality assessments that the licensee performed for degraded or nonconforming SSCs:

The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable or functional, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded SSC.

These activities constitute completion of six operability and functionality review samples, as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1R18 Plant Modifications

Main article: IP 71111.18

a. Inspection Scope

The inspectors reviewed a temporary plant modification that affected risk-significant SSCs:

  • September 10, 2014, temporary bypass of recirculation pump A thermal shock interlocks and the disabling of the associated control room annunciator

The inspectors verified that the licensee had installed and this temporary modification in accordance with technically adequate design documents. The inspectors verified that this modification did not adversely impact the operability or availability of affected SSCs.

The inspectors reviewed design documentation and plant procedures affected by the modification to verify the licensee maintained configuration control.

These activities constitute completion of one sample of temporary modifications, as defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

a. Inspection Scope

The inspectors reviewed six post-maintenance testing activities that affected risk-significant SSCs:

  • July 21, 2014, residual heat removal system B motor operator valve functional test following scheduled maintenance
  • July 21, 2014, power range neutron monitoring system functional test following permanent plant modification
  • August 19, 2014, 119 foot elevation containment airlock test following scheduled maintenance
  • August 29, 2014, division one diesel generator following oil leak repair

The inspectors reviewed licensing-and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.

These activities constitute completion of six post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

a. Inspection Scope

The inspectors observed five risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components (SSCs) were capable of performing their safety functions:

In-service tests:

Other surveillance tests:

  • July 23, 2014, containment pressure trip unit channel B functional test
  • July 25, 2014, division two load shedding sequencer functional test
  • July 28, 2014, division two diesel generator monthly functional test
  • August 13, 2014, reactor core isolation coolant pump low pressure functional test

The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.

These activities constitute completion of five surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

Main article: IP 71114.06

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors observed an emergency preparedness drill on August 13, 2014, to verify the adequacy and capability of the licensees assessment of drill performance. The inspectors reviewed the drill scenario, observed the drill from the emergency operating facility (EOF), and attended the post-drill critique. The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.

These activities constitute completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06.

b. Findings

No findings were identified.

OTHER ACTIVITIES

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

4OA2 Problem Identification and Resolution

Main article: IP 71152

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors selected two issues for an in-depth follow-up:

  • On August 4, 2014, the inspectors reviewed the licensees back log of long standing technical requirements manual limiting condition of operation (LCO).

The inspectors reviewed the required actions associated with each LCO and determined the licensee had maintained compliance with the technical requirements manual by performing the required actions within the prescribed time limits. The inspectors also reviewed the condition reports and work orders associated with the deficient equipment and found the long standing LCOs shared a common theme in that the required LCO action was to write an appropriate deficiency document (i.e. a condition report) if the equipment had not been restored within the LCO time limit. Since all required LCO actions were complete, and compensatory actions were established, the licensee prioritized the work orders in accordance with the normal work management process. As a result, the equipment often remained deficient for long periods of time.

For example, the inspectors analyzed data from October 2011, through August 2014, relating to Technical Requirements Manual Sections TRM 6.2.1 Fire Detection Instrumentation, TRM 6.3.1 Radiation Monitoring Instrumentation, and TRM 6.3.2 Seismic Monitoring Instrumentation. The LCO times for these sections are either 14 or 30 days, and the associated action for each is to initiate a deficiency document. The inspectors found that the time for resolving the deficient equipment ranged from 17 to 464 days, with an average of 161 days.

The inspectors shared these insights with the licensee who agreed the resolution of long standing equipment issues was untimely and that they had already identified the need for improvement. The licensee provided the inspectors with system health reports and work order completion data and demonstrated they were making a reasonable effort to resolve their long standing equipment issues.

The inspectors assessed the licensees problem identification threshold and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition. However, the inspectors determined that, although no violations of regulatory requirements were identified, the frequent occurrence of long standing LCO represents a weakness in the work management process in that technical requirements manual related equipment deficiencies are allowed to exist for long periods.

  • On August 22, 2014, the inspectors completed a review of Condition Report CR-GGN-2014-02598, which addressed the discovery of contaminated soil outside of the radiologically controlled area boundary. The inspectors observed the licensees response to the discovery of the contamination and the subsequent clean-up and disposal. The source of the contamination was determined to be a buried pipe that was not properly sealed during plant construction. The licensee excavated the contaminated soil and sent it for disposal in accordance with their radioactive waste disposal process. They also used a robot to inspect the integrity of the buried pipe and verified no other leaks were present. Finally, the pipe was sealed with a permanent cap. Additionally, the licensee installed monitoring wells for continued monitoring of the soil. The inspectors reviewed the licensees evaluation of the event and determined their conclusions were reasonable and their corrective actions were appropriate.

The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews, and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.

These activities constitute completion of two annual follow-up samples as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

Main article: IP 71153

.1 (Closed) Licensee Event Report 05000416/2014-003-00: Automatic Actuation of the

Reactor Protection System (RPS) due to Main Turbine Overspeed Protection Load Reject Relay Fault

a. Inspection Scope

On March 29, 2014, at approximately 10:08 AM, Grand Gulf Nuclear Station experienced an automatic actuation of the reactor protection system and plant scram due to a main turbine overspeed protection load reject relay fault. All control rods fully inserted and safety systems operated as designed. No safety relief valves lifted and no isolation signals were received.

The cause of the event was a failed capacitor in a multiplier module of the main turbine overspeed protection circuit. Corrective actions included replacement of the multiplier module, the load reject relay power supply, the power measurement input module, and the voltage measurement input module. A design change is planned to replace the load reject relay with an upgrade that is not vulnerable to single component failure. The inspectors reviewed the root causes as well as the associated corrective actions and determined that the actions taken and planned by the licensee were reasonable. The enforcement aspects of the event are discussed below. Documents reviewed as part of this inspection are listed in the attachment.

These activities constitute completion of one event follow-up sample, as defined in Inspection Procedure 71153.

b. Findings

Introduction.

The inspectors reviewed a self-revealing Green finding for the licensee's failure to follow Procedure EN-LI-102, "Corrective Action Process, Revision 12, which requires the licensee to appropriately complete assigned corrective actions within the prescribed time frame.

Description.

On March 29, 2014, with Grand Gulf Nuclear Station operating at 87 percent power, a capacitor in a multiplier module of the main turbine overspeed protection circuit failed, causing the load reject relay to actuate. The main turbine control valves closed and an automatic actuation of the reactor protection system occurred, resulting in a plant scram.

Following the scram, the licensee performed a root cause analysis. The root cause analysis observed that a corrective action initially assigned in 2007 in association with a single point vulnerability review was not completed in the prescribed time frame. The corrective action required that the module in question, which contained a single point vulnerability, either be rebuilt so as to reduce the probability that an age-related failure capable of triggering the vulnerability would occur, or replaced with a new design that eliminated the vulnerability altogether.

The inspectors discussed the finding with the licensee and reviewed the licensee's root cause analysis. The inspectors also reviewed Procedure EN-LI-102, "Corrective Action Process, Revision 12. The inspectors concluded that the licensee failed to follow Step 4.a.2 of the procedure, which required that the licensee ensure the assigned corrective actions are appropriately completed within the prescribed time frame. The assigned corrective action had an initial due date of August 30th, 2009, and was closed, without being appropriately completed on August 13th, 2009.

The licensee entered this issue into the corrective action program under Condition Report CR-GGN-2014-03131. Immediate corrective actions following the scram included replacing the failed module with a spare module that had been visually inspected and functionally checked. Long term corrective actions include replacing the module with a component that does not exhibit single point vulnerability.

Analysis.

The licensee's failure to follow procedure by failing to appropriately complete assigned corrective actions was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective, in that it increased the likelihood of those events that upset plant stability and challenge critical safety functions during power operations.

Using NRC Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of Findings," dated June 19, 2012, the inspectors determined that the issue affected the Initiating Events Cornerstone. Using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process for Findings At-Power," dated June 19th, 2012, the finding was determined to be of very low safety significance (Green) because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigating equipment would not be available. The finding was a latent issue and is not reflective of present licensee performance; therefore no cross-cutting aspect was assigned.

Enforcement.

This finding does not involve enforcement action because no regulatory requirements were violated. The licensee documented the issue in the corrective action program as Condition Report CR-GGN-2014-03131. (FIN 05000416/2014004-02, "Failure to Implement Corrective Actions Leads to Automatic Plant Scram").

4OA6 Meetings, Including Exit

Exit Meeting Summary

On October 2, 2014, the inspectors presented the inspection results to K. Mulligan, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

C. Boschetti, Manager, Nuclear Oversight
K. Boudreaux, Manager, Systems and Components
T. Coutu, Director, Regulatory Assurance and Performance Improvement
J. Dorsey, Security Manager
V. Fallacara, General Manager, Plant Operations
H. Farris, Assistant Operations Manager
J. Gerard, Senior Manager, Operations
M. Goodwin, Assistant Operations Manager
G. Hawkins, Senior Manager, Site Projects
C. Lewis, Manager, Emergency Preparedness
E. Meaders, Manager, Training
R. Miller, Manager, Radiation Protection
M. Milly, Senior Manager, Maintenance
K. Mulligan, Site Vice President
J. Nadeau, Manager, Regulatory Assurance
C. Robinson, Site Vice President
P. Salgado, Manager, Performance Improvement
R. Scarbrough, Senior Regulatory Engineer, Licensing
R. Sumrall, Manager, Chemistry
T. Thornton, Manager, Design and Program
D. Wiles, Director, Engineering

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000416/2014004-01 NCV Failure to Control Transient Combustible Material in Accordance with a Fire Protection Procedure (Section 1R04)
05000416/2014004-02 FIN Failure to Implement Corrective Actions Leads to Automatic Plant Scram (Section 40A3)

Closed

05000416/2014-003-00 LER Automatic Actuation of the Reactor Protection System (RPS) due to Main Turbine Overspeed Protection Load Reject Relay Fault (Section 40A3)

LIST OF DOCUMENTS REVIEWED

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