IR 05000416/2022001
| ML22115A056 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 05/09/2022 |
| From: | Jeffrey Josey NRC/RGN-IV/DORS/PBC |
| To: | Franssen R Entergy Operations |
| References | |
| IR 2022001 | |
| Download: ML22115A056 (29) | |
Text
May 09, 2022
SUBJECT:
GRAND GULF NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000416/2022001
Dear Mr. Franssen:
On March 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Grand Gulf Nuclear Station. On April 7, 2022, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
Four findings of very low safety significance (Green) are documented in this report. Four of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance of the violations documented in this inspection report, 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; 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Grand Gulf Nuclear Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Jeffrey E. Josey, Chief Projects Branch C Division of Operating Reactor Safety Docket No. 05000416 License No. NPF-29
Enclosure:
As stated
Inspection Report
Docket Number:
05000416
License Number:
Report Number:
Enterprise Identifier:
I-2022-001-0018
Licensee:
Entergy Operations, Inc.
Facility:
Grand Gulf Nuclear Station
Location:
Port Gibson, MS
Inspection Dates:
January 1, 2022, to March 31, 2022
Inspectors:
B. Baca, Health Physicist
J. O'Donnell, Senior Health Physicist
E. Simpson, Health Physicist
T. Steadham, Senior Resident Inspector
M. Thomas, Resident Inspector
Approved By:
Jeffrey E. Josey, Chief
Projects Branch C
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Grand Gulf Nuclear Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Maintain Configuration Control of the Diesel Generator Control Panel Door Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000416/2022001-01 Open/Closed
[H.12] - Avoid Complacency 71111.15 The inspectors identified a Green finding and associated non-cited violation of Technical Specification 5.4.1, Procedures, when the licensee failed to follow Station Procedure EN-OP-115-07, Configuration Control, Revision 4. Specifically, the licensee failed to either establish or restore the Division 1 diesel generator control panel door configuration when two of the three latches on the control panel door were left unlatched.
Failure to Maintain Constant Awareness of Plant Status Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000416/2022001-02 Open/Closed
[H.1] -
Resources 71111.22 The inspectors identified a Green finding and associated non-cited violation of Technical Specification 5.4.1, Procedures, when the licensee failed to follow Procedure EN-OP-115,
Conduct of Operations, Revision 31, step 4.1.C. Specifically, the licensee failed to maintain a constant awareness of plant status and aggressively pursue the satisfactory resolution of abnormal conditions when the drywell equipment drain sump controller failed on the morning of December 9, 2021. This failure caused an increase in unidentified leakage of greater than gallons per minute within the previous 24-hour period, and unknowingly put the licensee in a short duration (4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) technical specification limiting condition for operation action statement 3.4.5.d.
Failure to Identify a Condition Adverse to Quality Associated with the Division 3 Diesel Generator Ring Gear Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000416/2022001-03 Open/Closed
[P.5] -
Operating Experience 71152A The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, when the licensee failed to identify a condition adverse to quality. Specifically, the licensee failed to identify that the Division 3 diesel generator ring gear degradation was a condition adverse to quality.
Failure to Correct a Condition Adverse to Quality Associated with Transient Combustible Control Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000416/2022001-04 Open/Closed
[P.2] -
Evaluation 71152A The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, when the licensee failed to take prompt corrective actions to correct the improper control of transient combustibles.
Specifically, after the inspectors identified that transient combustibles staged in the 119-foot elevation of the auxiliary building for the temporary suppression pool clean-up skid were not in conformance with the associated transient combustible permit, the licensee failed to take adequate corrective actions to bring the plant back into compliance with the fire protection program.
Additional Tracking Items
None.
PLANT STATUS
Grand Gulf Nuclear Station, Unit 1, began the inspection period at rated thermal power (RTP).
On January 28, 2022, operators reduced power to 82 percent RTP for a rod pattern adjustment.
The unit was returned to RTP on January 29, 2022. On February 11, 2022, operators reduced power to 80 percent RTP for a rod pattern adjustment. The unit was returned to RTP on February 12, 2022. On February 26, 2022, the unit was shut down for Refueling Outage 23 and remained shut down for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk-significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather due to thunderstorms and predicted high winds on March 22, 2022.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Standby service water basin siphon system on January 31, 2022
- (2) Reactor core isolation cooling system while high pressure core spray was out of service for maintenance on February 4, 2022
- (3) Low pressure core spray while high pressure core spray was out of service for maintenance on February 4, 2022
- (4) Residual heat removal A on February 10, 2022
- (5) Division 3 standby diesel generator on March 31, 2022
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Division 3 standby diesel generator room on January 14, 2022
- (2) Upper control room on February 2, 2022
- (3) Low pressure core spray pump room on February 3, 2022
- (4) Reactor core isolation cooling pump room on February 3, 2022
- (5) Residual heat removal A pump room on February 10, 2022
- (6) Residual heat removal A piping and penetration room, 139-foot elevation, on February 10, 2022
- (7) Auxiliary building general area, 119-foot elevation, on February 27, 2022
- (8) Auxiliary building steam tunnel on March 31, 2022
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Low pressure core spray pump room on March 31, 2022
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during emergent plant service water issues on January 28, 2022.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Emergent risk during and after the partial loss of plant service water when the C radial well pump tripped the week of January 24, 2022
- (2) Protected system verification with high pressure core spray out of service for maintenance on February 4, 2022
- (3) Observation of work management for work on protected equipment on February 14, 2022
- (4) Shutdown system verification walkdowns on March 31, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Condition Report CR-GGN-2021-09280, Division 1 emergency diesel generator fuel injectors found to be locked in fully outward position on January 14, 2022
- (2) Condition Report CR-GGN-2022-00449, standby service water basin siphon line vent found clogged on February 1, 2022
- (3) Condition Report CR-GGN-2022-00813, Division 3 emergency diesel generator speed sensor found with wear marks on February 3, 2022
- (4) Condition Report CR-GGN-2021-08933, Division 1 emergency diesel generator control cabinet doors found not fully latched on February 23, 2022
- (5) Condition Report CR-GGN-2022-01161, potentially misaligned reactor core isolation cooling pipe hanger on February 25, 2022
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Engineering Change EC-91613, temporary supplemental suppression pool clean-up on February 22, 2022
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) Work Order 552075, replacement of high pressure core spray instrumentation power supply on January 28, 2022
- (2) Division 3 emergency diesel generator following maintenance on February 11, 2022
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)
(1)
(Partial)
The inspectors evaluated Refueling Outage 23 activities from February 26, 2022, through March 31, 2022. The inspectors completed inspection procedure Sections 03.01a, 03.01b, and 03.01c.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (4 Samples)
- (1) Work Order 52935626, Procedure 06-IC-1B21-R-0035-03, Channel C main steam line low pressure containment isolation time response surveillance on January 19, 2022
- (2) Work Order 52993254, Procedure 06-OP-1N32-M-0002, turbine bypass stop and control valve test on January 25, 2022
- (3) Work Order 52988559, Procedure 06-OP-1P81-M-0002, Division 3 emergency diesel generator functional test on January 30, 2022
- (4) Work Order 52991865, Procedure 06-EL-1R21-M-0001B, Division 2 4.16 kV degraded voltage functional test on February 3, 2022
RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)
- (1) Condition Report CR-GGN-2021-09206, high unidentified leakage following drywell equipment drain level control failure on March 14, 2022
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
- (1) Work Order 52926484-01, main steam isolation valve full stroke test on March 25, 2022
FLEX Testing (IP Section 03.02) (1 Sample)
- (1) Work Order 52925473, 3-year load test on the diesel-driven FLEX pump on January 19,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identified the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assessed radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructed workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Observed the licensee conduct surveys of potentially contaminated packages/equipment from the radiologically controlled area for release offsite and workers exiting contaminated areas such as the drywell
- (2) Walked down the storage locations for several nonexempt radioactive sources listed in the licensee's nonexempt source inventory for the following sources:
GGNS No.17-002, GGNS No.93-112, GGNS No.98-003
- (3) Evaluated the licensee's physical and programmatic controls for highly activated and contaminated non-fuel materials stored within the spent fuel pool
Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) Locked high radiation area work and job coverage for reactor low power range monitor replacement, including movement, cutting, surveying, and placement of highly activated components into a shielded container (RWP 2022-1508, Tasks 1 and 2)
- (2) Transfer of the low power range monitor waste to the spent fuel pool from the high radiation, high contamination staging area (RWP 2022-1508, Task 5)
- (3) Locked high radiation area for insulation removal activities and radiation protection support for in-service inspection and non-destructive examination of welds inside the annulus area outside of the reactor vessel (RWP 2022-1516)
- (4) Status of satellite radiologically controlled areas to assess storage and security of outage related radioactive materials areas and contaminated items High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (4 Samples)
The inspectors evaluated licensee controls of the following high radiation areas and very high radiation areas:
- (1) Grand Gulf Nuclear Station condenser bay, 133-foot elevation, Room 1T319, Door 1T320
- (2) Grand Gulf Nuclear Station fuel pool cooling and cleanup backwash tank room, 166-foot elevation, Room 1A436, Door 1A414
- (3) Grand Gulf Nuclear Station reactor water cleanup phase separator decay tank A, Room OR211, Door OR208
- (4) Grand Gulf Nuclear Station radwaste truck bay, 136-foot elevation Radiation Worker Performance and Radiation Protection Technician Proficiency (IP
Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertained to radiation protection requirements.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (2 Samples)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
- (1) Control room fresh air system
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated the configuration of the following temporary ventilation systems:
- (1) High efficiency particulate air filtration (HEPA 71-28) utilized for 133-foot elevation condenser bay work
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices such as breather boxes, powered air-purifying respirators/hoods, and self-contained breathing apparatuses.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Shipment Preparation (IP Section 03.04)
- (1) The inspectors observed the preparation of LSAII radioactive shipment GGN-2022-0212 on March 7,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===
- (1) January 1, 2021, through December 31, 2021 BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)
- (1) January 1, 2021, through December 31, 2021
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
- (1) January 1, 2021, through December 31, 2021
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) January 1, 2021, through December 31, 2021 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) January 1, 2021, through December 31, 2021
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Condition Report CR-GGN-2022-01378, corrective actions associated with NRC identified transient combustible permit deficiencies on March 31, 2022
- (2) Condition Report CR-GGN-2022-00813, corrective actions for the Division 3 diesel generator speed probe degradation on March 31,
INSPECTION RESULTS
Failure to Maintain Configuration Control of the Diesel Generator Control Panel Door Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000416/2022001-01 Open/Closed
[H.12] - Avoid Complacency 71111.15 The inspectors identified a Green finding and associated non-cited violation of Technical Specification 5.4.1, Procedures, when the licensee failed to follow Station Procedure EN-OP-115-07, Configuration Control, Revision 4. Specifically, the licensee failed to either establish or restore the Division 1 diesel generator control panel door configuration when two of the three latches on the control panel door were left unlatched.
Description:
On November 30, 2021, during a routine walkdown of the Division 1 diesel generator, the inspectors identified that two of the three latches on the west door of the diesel generator control panel 1H22-P400 were unlatched. The diesel generator was in its standby configuration at the time (i.e., no maintenance or testing was in progress). The last time the control panel door was unlatched and open was during the 24-hour surveillance test that concluded on October 21, 2021.
According to Surveillance Procedure 06-OP-1P75-R-0003, Standby Diesel Generator 11:
Functional Test, Revision 139, step 2.1.26, if the diesel generator control cabinet doors are left open or unlatched, then they must not be left unattended; otherwise, the diesel generator is to be declared inoperable.
Referencing the surveillance procedure step, the residents notified the control room of the apparent misconfiguration of panel door 1H22-P400. Operations personnel were sent to the Division 1 diesel generator room where they verified that the two control panel door latches were unlatched. They subsequently took immediate action to restore the latches to a latched configuration, ultimately returning the control panel door to its seismically qualified, standby configuration. They also walked down the other diesel control panels to ensure proper door latch configuration. The licensee initiated a past operability evaluation to assess operability of the diesel generator given the as-found, nonconforming condition of the partially unlatched control panel door.
Station Procedure EN-OP-115-07, Configuration Control, Revision 4, Section 5.2, Maintaining Plant/System Configuration, step 1, required that system line ups, complete or partial, are to be performed to either establish or restore system configuration during startup as directed by plant procedures; after completion of testing, post work, surveillances, or major system outages as determined by operations; and/or as directed by the shift manager.
Corrective Actions: The licensee entered this issue into their corrective action program and took immediate action to restore the control panel door to its seismically qualified, standby configuration. The licensee also walked down the other diesel control panels to ensure their proper door latch configuration as well. Additionally, the licensee conducted a past operability evaluation on the partially unlatched diesel control panel door and showed that it remained operable in its as-found condition.
Corrective Action References: Condition Report CR-GGN-2021-08933
Performance Assessment:
Performance Deficiency: The failure to follow Procedure EN-OP-115-07, Configuration Control, Revision 4, Section 5.2, step 1 was a performance deficiency. Specifically, the licensees failure to either establish or restore the Division 1 diesel generator control panel door latch configuration following system maintenance put the diesel generator in a nonconforming, nonseismically qualified state which impacted the reliability of the system to respond to a seismic event.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Configuration Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, with the control panel door latches misconfigured, the diesel generator was in a nonconforming, nonseismically qualified state which adversely affected the reliability of the diesel generator.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Utilizing Exhibit 2, the inspectors screened the finding as Green because the mitigating system maintained its operability according to the licensees past operability evaluation.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Following the last system maintenance and testing, during system restoration, the licensee did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk. In other words, the licensee lacked rigorous behaviors to verify proper restoration of even the most unsuspecting components (e.g., a door latch). Instead, the licensee expected a successful outcome and thus failed to properly establish and restore system configuration.
Enforcement:
Violation: Technical Specification 5.4.1, Procedures, requires, in part, written procedures shall be implemented covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Regulatory Guide 1.33, Revision 2, Appendix A, Section 1.c, recommends procedures for equipment control. The licensee established Procedure EN-OP-115-07, Configuration Control, Revision 4, to meet the Technical Specification 5.4.1 requirement associated with the procedure specified by Regulatory Guide 1.33, Section 1.c.
Contrary to the above, from October 21, 2021, to November 30, 2021, the licensee failed to implement Procedure EN-OP-115-07, Configuration Control, Revision 4. Specifically, the licensee failed to either establish or restore the Division 1 diesel generator control panel door latch configuration following testing.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Maintain Constant Awareness of Plant Status Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000416/2022001-02 Open/Closed
[H.1] -
Resources 71111.22 The inspectors identified a Green finding and associated non-cited violation of Technical Specification 5.4.1, Procedures, when the licensee failed to follow Procedure EN-OP-115, Conduct of Operations, Revision 31, step 4.1.C. Specifically, the licensee failed to maintain a constant awareness of plant status and aggressively pursue the satisfactory resolution of abnormal conditions when the drywell equipment drain sump controller failed on the morning of December 9, 2021. This failure caused an increase in unidentified leakage of greater than 2 gallons per minute within the previous 24-hour period, and unknowingly put the licensee in a short duration (4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) technical specification limiting condition for operation action statement 3.4.5.d.
Description:
On December 9, 2021, at approximately 7:07 p.m. operators in the main control room identified drywell floor drain sump in-leakage rate to be 2.18 gallons per minute (gpm),which also served as a measure of technical specification unidentified leakage. Prior to this observed increase, operators logged unidentified leakage at 0.13 gpm the morning of December 9, 2021. As a result, the licensee entered TS limiting condition for operation (LCO) 3.4.5.d for greater than a 2 gpm increase in unidentified leakage within the previous 24-hour period. Shortly thereafter, operators confirmed that the increase in unidentified leakage was due to the failure of the drywell equipment drain sump pumps to pump down the drywell equipment drain once its level had reached the high setpoint. Because the drywell equipment drain sump pumps failed to pump the equipment drain sump down, which was later found to be due to a failed level controller, the drywell equipment drain sump overflowed into the drywell floor drain sump. This overflow was later confirmed to be the cause of the unidentified leakage rate increasing to 2.18 gpm.
The licensee took immediate corrective action to pump down the drywell equipment drain sump manually, which stopped the overflow into the drywell floor drain sump and caused unidentified leakage to return to its pre-event rate of 0.13 gpm. The licensee maintained manual control over the drywell equipment drain sump until they were able to diagnose and repair the failed sump level controller. Following the drywell sump level controller repair, the licensee restored the normal automatic configuration of the drywell equipment drain sump system.
While reviewing plant computer trends, the inspectors identified an approximate 3.75-hour window earlier in the day on December 9, 2021, where the drywell equipment drain sump was overflowing into the drywell floor drain sump. This earlier overflow started at approximately 10:00 a.m. and lasted until approximately 1:45 p.m. When the inspectors brought this to the attention of the licensee, it became evident that the licensee was unaware of this earlier overflow event where unidentified leakage had also exceeded the TS LCO 3.4.5.d limit. As a result, the residents identified a 3.75-hour window where the licensee was unknowingly in TS LCO 3.4.5, Condition B, (which requires actions to be completed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> upon entry) due to a greater than 2 gpm increase in unidentified leakage within the previous 24-hour period.
The inspectors noted that the earlier overflow event was unintentionally corrected due to a calibration surveillance on the drywell floor drain system that took place around 1:45 p.m.
later that day. The system consists of two drywell sump level controllers and each controller has the capability to control both the drywell equipment and floor drain sumps. Prior to the surveillance, the equipment drain sump was selected to the failed controller (hence the equipment drain overflow that was occurring at that time). During the surveillance, at approximately 1:45 p.m., the equipment drain sump was momentarily swapped over to the good controller which caused an equipment drain sump pump down, stopped the overflow, and restored the unidentified leakage rate in the floor drain sump to its normal, pre-event rate.
Following the surveillance, the equipment drain sump was changed back over to the failed controller, which led to the second overflow event that happened that day (i.e., the one that operators identified that evening at 7:07 p.m.).
The inspectors also noted that TS Surveillance Requirement (SR) 3.4.5.1 was only conducted once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; therefore, because the morning surveillance was done before 10:00 a.m. on December 9, 2021, operators would not have seen the first overflow event during the conduct of the morning surveillance. However, operators could have become aware about the first overflow event (10:00 a.m. - 1:45 p.m.) had they been maintaining a constant awareness of plant status throughout the day. Additionally, operators had the opportunity to identify the first overflow event when they conducted the evening SR 3.4.5.1 surveillance had they reviewed the leakage trends as opposed to only reviewing the beginning and end points of the leakage data.
Additionally in their response to Generic Letter (GL) 88-01, the licensee stated that the Grand Gulf Nuclear Station technical specifications are in compliance with the NRC staff positions on leakage detection. The NRC staff position on leakage detection, as outlined in GL 88-01, states that plant shutdown should be initiated for inspection and corrective action when, within any period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less, any leakage detection system indicates an increase in rate of unidentified leakage in excess of 2 gpm or its equivalent, or when the total unidentified leakage attains a rate of 5 gpm or equivalent, whichever occurs first. On the morning of December 9, 2021, at approximately 10:00 a.m., the operators had indication showing an unidentified leakage increase greater than 2 gpm; however, because of the operators failure to maintain a constant awareness of plant status, they unknowingly entered a 4-hour LCO action statement. Had it not been for the unintentional pump down of the equipment drain sump as a result of the planned surveillance at 1:45 p.m., the operators would have unknowingly exceeded TS LCO 3.4.5, Action B Completion Time limit, at which point they would have unknowingly entered a 12-hour shutdown action statement.
Procedure EN-OP-115, Conduct of Operations, Revision 31, step 4.1.c, stated that all operators are to maintain a constant awareness of plant status and aggressively pursue the satisfactory resolution of abnormal conditions. The inspectors concluded that on December 9, 2021, operators did not maintain a constant awareness of plant status because they did not identify the conditions for entry into TS LCO 3.4.5, Action B, until several days later when prompted by the inspectors.
Corrective Actions: The licensee implemented Standing Order 21-022, Revision 0, to increase unidentified leakage monitoring to once every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to increase awareness of plant conditions.
Corrective Action References: Condition Report CR-GGN-2021-09325
Performance Assessment:
Performance Deficiency: The failure to follow Procedure EN-OP-115, Conduct of Operations, Revision 31, step 4.1.c was a performance deficiency. Specifically, on December 9, 2021, the operators did not maintain a constant awareness of plant status when the drywell unidentified leakage increased greater than 2 gpm without the operators identifying the increase.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, failing to maintain a constant awareness of plant status, in this case, monitoring drywell unidentified leakage increases, resulted in a situation where the licensee was unknowingly in a short duration TS LCO action statement and did not quickly assess and correct a degraded condition that could have been a precursor to an initiating event (i.e., loss-of-coolant accident).
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Utilizing Exhibit 1, the inspectors screened the finding as Green because the finding was not associated with actual reactor coolant system boundary degradation that could have resulted in exceeding the reactor coolant system leak rate for a small loss-of-coolant accident (LOCA), and the finding could not have affected other systems used to mitigate a LOCA.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. In this case, leaders did not ensure that procedures or equipment were available or adequate to support nuclear safety in the area of monitoring for unidentified leakage increases.
Enforcement:
Violation: Technical Specification 5.4.1, Procedures, requires, in part, written procedures shall be implemented covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Regulatory Guide 1.33, Revision 2, Appendix A, Section 1.b, recommends procedures for the responsibilities for safe operation. The licensee established Procedure EN-OP-115, Conduct of Operations, Revision 31, to meet the Technical Specification 5.4.1 requirement associated with the procedure specified by Regulatory Guide 1.33, Section 1.b. Procedure EN-OP-115, step 4.1.c, required that all operators are to maintain a constant awareness of plant status and aggressively pursue the satisfactory resolution of abnormal conditions.
Contrary to the above, on December 9, 2021, the licensee failed to implement written procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Specifically, the licensee failed to follow Procedure EN-OP-115, Conduct of Operations, Revision 31, step 4.1.c in that operators failed to maintain a constant awareness of unidentified leakage and aggressively pursue resolution of the abnormal condition.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Identify a Condition Adverse to Quality Associated with the Division 3 Diesel Generator Ring Gear Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000416/2022001-03 Open/Closed
[P.5] -
Operating Experience 71152A The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, when the licensee failed to identify a condition adverse to quality. Specifically, the licensee failed to identify that the Division 3 diesel generator ring gear degradation was a condition adverse to quality.
Description:
On January 31, 2022, while performing work to clean the Division 3 diesel generator speed probe magnetic pickup, technicians discovered wear marks on the tip of the sensor nearest to the ring gear teeth. The licensee placed this issue into their corrective action program as Condition Report CR-GGN-2022-00813. Upon closer inspection, the licensee noticed that part of the flywheel ring gear teeth were deformed which was the wear of the speed probe. During discussions with the inspectors, the licensee noted that the ring gear teeth deformation was due to repeated impacts caused by the air start motor pinion gear during each startup over the diesels operational lifetime. The ring gear teeth deformation prompted the licensee to implement Engineering Change EC-92070 to re-position the speed probe adjacent to the portion of the ring gear teeth that was unaffected by the deformation.
The inspectors noted that Condition Report CR-GGN-2022-00813 only discussed the speed probe wear and did not discuss the ring gear deformation.
After a challenge by the inspectors regarding Condition Report CR-GGN-2022-00813 lacking information about the ring gear deformation and the condition reports overall disposition as non-adverse, the licensee agreed that the ring gear teeth deformation was a condition that needed to be documented in the corrective action program and on February 22, 2022, wrote Condition Report CR-GGN-2022-01586.
On February 25, 2022, the inspectors also provided operating experience from the Dresden Nuclear Plant which showed how deformation and degradation of the flywheel ring gear could cause failures to start of the diesel (ADAMS Accession No. ML17252B442). Additionally, the inspectors reviewed recent operating experience from the Arkansas Nuclear One plant where an air start motor partially failed as a result of degradation to the air start motor pinion gear teeth (Condition Reports CR-ANO-1-2020-01681 and CR-ANO-1-2021-01895). On March 16, 2022, the licensee provided a vendor service advisory that was issued in 2009 to provide inspection guidance and qualification criteria for ring gear degradation. The service advisory provided specific guidance on inspecting the ring gear for wear patterns, burrs, chips, and other worn areas of the ring gear. It also provided guidance for repair and replacement activities; however, as of March 9, 2022, the licensee had not yet implemented this service advisory guidance. As part of the actions from Condition Report CR-GGN-2022-01586, on March 10, 2022, the licensee scheduled a one-time service advisory inspection for the next system maintenance outage to occur in June 2023.
However, Condition Report CR-GGN-2022-01586 was screened as non-adverse and thus the corrective action for scheduling the service advisory inspection of the ring gear in 2023 was tied to a nonquality related document which procedurally could have been canceled.
Procedure EN-LI-102, Corrective Action Program, Revision 47, required that conditions adverse to quality were to be identified and corrected.
The inspectors determined that the condition experienced by the ring gear was adverse to quality because:
- (1) operating experience shows that degradation to the ring gear teeth can cause failures of the diesel to start; and
- (2) the vendor service advisory provides recommendations for repair/replacement activities when conditions warrant so as to ensure the diesel is capable of performing its function, and not having preventive maintenance measures in place to periodically monitor and trend the ring gear degradation leads to a situation where ring gear failures can occur unexpectedly.
Corrective Actions: The licensee entered this issue into their corrective action program to re-screen the issue as adverse and to ensure the inspections are performed in a quality manner within the corrective action process.
Corrective Action References: Condition Reports CR-GGN-2022-00813, CR-GGN-2022-01586, and CR-GGN-2022-01723
Performance Assessment:
Performance Deficiency: The failure to identify a condition adverse to quality, in accordance with Procedure EN-LI-102, Corrective Action Program, Revision 47, was a performance deficiency. Specifically, the licensee failed to identify the Division 3 diesel generator flywheel ring gear degradation was a condition adverse to quality.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failing to identify the condition adverse to quality results in a quality assurance noncompliance for the system (i.e., 10 CFR Part 50, Appendix B, Criterion XVI). Failing to identify conditions adverse to quality could continue to degrade the system without proper monitoring and correction. Lastly, if the performance deficiency is left uncorrected, the condition adverse to quality could reasonably persist and continue to degrade to the point of system failure.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Utilizing Exhibit 2, the inspectors screened the finding as Green because the mitigating system maintained its operability.
Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and effectively collects, evaluates, and implements relevant internal and external operating experience in a timely manner. The licensee failed to identify the Division 3 ring gear degradation as a condition adverse to quality because it did not systematically collect, evaluate, nor implement the operating experience associated with ring gear degradation in a timely manner.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
Contrary to the above, since January 31, 2022, the licensee failed to identify the Division 3 diesel generator flywheel ring gear degradation as a condition adverse to quality.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Correct a Condition Adverse to Quality Associated with Transient Combustible Control Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000416/2022001-04 Open/Closed
[P.2] -
Evaluation 71152A The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, when the licensee failed to take prompt corrective actions to correct the improper control of transient combustibles.
Specifically, after the inspectors identified that transient combustibles staged in the 119-foot elevation of the auxiliary building for the temporary suppression pool clean-up skid were not in conformance with the associated transient combustible permit, the licensee failed to take adequate corrective actions to bring the plant back into compliance with the fire protection program.
Description:
On February 16, 2022, during a walkdown of the temporary suppression pool clean-up skid located in the 119-foot elevation of the auxiliary building, the inspector observed transient combustibles staged in the area with an associated transient combustible permit. Upon closer inspection of both the transient combustibles and the permit, the inspectors noted that the permits finish date was annotated as January 23, 2022, and that the permits description of materials was limited to 250 pounds of rubber hoses. The inspectors noted that in addition to the rubber hoses staged near the skid, there were also plastic bags, bundles of zip ties, and a small amount of other miscellaneous combustibles.
The inspectors brought this concern to the licensee who documented the concern as Condition Report CR-GGN-2022-01378.
Procedure EN-DC-161, Control of Combustibles, Revision 24, contained the following requirements:
Section 5.7, step 1.b, required that the combustible material description, quantity required, and total weight be documented on the transient combustible permit (TCP)
Section 3.0, step 15, allowed for TCPs to be placed in the plant for a maximum of 90 days, with one 90-day extension being allowed 9.14, provided the template for a transient combustible permit which required annotation of a start and finish date
Section 5.9, step 1, required that upon job completion, the worker shall remove the combustibles from the plant and notify the fire marshal As documented in Condition Report CR-GGN-2022-01378, on February 22, 2022, the inspectors debriefed to the licensee a minor violation of Facility Operating License NPF-29, License Condition 2.C(41), for the failure to properly control transient combustibles in accordance with Procedure EN-DC-161, Control of Combustibles, Revision 24. Specifically, the licensee failed to document the correct material description, quantity, and weight of the transient combustibles staged at the temporary suppression pool clean-up skid. This violation was determined to be minor because the additional materials staged had little to no safety impact on the fire protection program for the area.
During subsequent review of Condition Report CR-GGN-2022-01378, the inspectors identified that the condition report was screened as non-adverse and closed out with no actions taken to correct the procedural noncompliance. On February 24, 2022, the inspectors raised another concern to licensee management regarding the apparent inadequate corrective actions taken for Condition Report CR-GGN-2022-01378. As a result, the licensee wrote another condition report, Condition Report CR-GGN-2022-01688, documenting the minor violation as well as the inspectors concerns about closing the first condition report as non-adverse with no actions taken.
On February 27, 2022, the inspectors noted that the same transient combustibles remained staged in the area with the same transient combustible permit.
Procedure EN-LI-102, Corrective Action Program, Revision 47, requires that conditions adverse to quality are to be corrected. As discussed in Table 9.5-11 of the Updated Final Safety Analysis, the licensee invoked the requirements of Title 10 CFR Part 50, Appendix B, Criterion XVI to the fire protection program. Further, Procedure EN-LI-102 defined conditions adverse to the fire protection program as conditions adverse to quality.
Corrective Actions: The licensee removed the transient combustibles on April 7, 2022.
Corrective Action References: Condition Reports CR-GGN-2022-01378 and CR-GGN-2022-01688
Performance Assessment:
Performance Deficiency: The failure to correct a condition adverse to quality in accordance with Procedure EN-LI-102, Corrective Action Program, Revision 47, was a performance deficiency. Specifically, the licensees failure to correct the improper control of transient combustibles staged in the 119-foot elevation of the auxiliary building for the temporary suppression pool clean-up skid led to continued noncompliance with License Condition 2.C(41) of Facility Operating License NPF-29.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, failing to correct the improper control of transient combustibles would have the potential to lead to scenarios where transient combustibles exceed the combustible control zone threshold limits unbeknownst to the licensee.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Utilizing Exhibit 1, the inspectors screened the finding as Green because the finding did not cause a reactor trip nor a loss of mitigation equipment. The mitigating system maintained its operability according to the licensees past operability evaluation.
Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. After entering the original issue into their corrective action program, the licensee failed to thoroughly evaluate the issue to ensure that its resolution would address the causes and any extent of conditions commensurate with their safety significance. The licensee lacked rigor in evaluating this issue, which led them to not taking the appropriate corrective actions.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
Contrary to the above, from February 16, 2022, to April 7, 2022, the licensee failed to correct a condition adverse to quality. Specifically, the licensee failed to correct the nonconforming transient combustible control associated with the temporary suppression pool clean-up skid.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On March 23, 2022, the inspectors presented the occupational radiation safety inspection results to Mr. R. Franssen, Site Vice President, and other members of the licensee staff.
On April 7, 2022, the inspectors presented the integrated inspection results to Mr. R. Franssen, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-GGN-
20-11591, 2021-07799, 2021-09457, 2022-00449, 2022-
00640, 2022-01154
M-1061A
P & I Diagram Standby Service Water System
Drawings
M-1358P
System Piping Isometric Transfer Siphon for Standby
Service Water Basins A&B
04-1-01-E12-1
Residual Heat Removal System
160
Procedures
04-1-01-P41-1
Standby Service Water System
153
Work Orders
WO 554353, 556449
Corrective Action
Documents
CR-GGN-
22-01154
Miscellaneous
FPP, Volume 1
Grand Gulf Nuclear Station Unit 1 Fire Preplans
Corrective Action
Documents
CR-GGN-
22-00970
M-1575
Internal Flood Areas and Boundaries Resulting from Pipe
Failures
Drawings
M195.0-48
Internal Flooding in the Auxiliary Building
Miscellaneous
GGNS-91-0045
Engineering Report for IPE Internal Flooding Analysis
Notebook
Corrective Action
Documents
CR-GGN-
22-01286, 2022-01307
Protected Equipment Postings
Procedures
On Line Risk Assessment
Corrective Action
Documents
CR-GGN-
2000-01025, 2003-00919, 2021-08933, 2021-09280, 2022-
00096, 2022-00449, 2022-00640, 2022-00813, 2022-00833,
22-01161
3636-116
Schematic Diagram Engine Control
M-1061A
P & I Diagram Standby Service Water System
Drawings
M-1358P
System Piping Isometric Transfer Siphon for Standby
Service Water Basins A&B
460000154
Instruction Manual for Diesel Generator Morrison Knudsen
301
460000155
Instructions-Part Manual for Diesel Generator Unit
300
Miscellaneous
460000451
Transamerica Delaval Vendor Manual
303
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
MS16
Hanger Installation Criteria
04-1-01-P41-1
Standby Service Water System
153
04-1-01-P81-1
High Pressure Core Spray Diesel Generator
06-OP-1P75-R-
0003
Standby Diesel Generator 11: Functional Test
139
E-1188-006
HPCS Power Supply System Engine Control
EN-OP-115-07
Configuration Control
Procedures
MC-Q1P41-11001
GGNS Standby Service Water Ultimate Heat Sink Thirty Day
Performance at EPU
Work Orders
WO 2928, 573150, 51084808, 52227318, 52352745, 52976356
Corrective Action
Documents
CR-GGN-
22-01378
M-1065
Condensate and Refueling Water Storage Transfer System
Drawings
M-1099
Suppression Pool Cleanup
Engineering
Changes
Evaluation of the Installation of the Supplemental
Suppression Pool Cleanup Demineralizer Skid
Procedures
Control of Combustibles
Work Orders
Paragon Report
No.
EERR1802652-
01-01
Equivalency Evaluation and Repair Report
Miscellaneous
Receipt
Inspection Report
No. 47916
Power Supply Cat ID 1599914066
03/05/2020
06-OP-1P81-M-
0002
I
2/06/2022
Procedures
06-OP-1P81-M-
0002
II
2/06/2022
Work Orders
Corrective Action
Documents
CR-GGN-
21-09206, 2022-00760
04-1-01-P45-1
Equipment Drain Sump System
Procedures
04-1-01-P45-2
Floor Drain Sump System
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
04-1-02-1H13-
P601
Alarm Response Instruction Panel No: 1H13-P601
173
04-1-02-1H13-
P680
Alarm Response Instruction Panel No: 1H13-P680
263
06-EL-1R21-M-
0001B
Division II 4.16kV Degraded Voltage Functional Test and
Calibration
2
06-IC-1B21-R-
0035-03
Main Steam Line Low Pressure (PCIS) Electronics Time
Response Test Channel C
104
06-IC-1P45-M-
0001
Drywell Floor Drain Sump Level Switch Functional Test
110
06-OP-1000-D-
0001
Daily Operating Logs
173
06-OP-1N32-M-
0002
Turbine Bypass Stop and Control Valve Test
103
06-OP-1P81-M-
0002
HPCS Diesel Generator 13 Functional Test
140
17-S-06-5
Technical Specification Instrumentation Loop Logic
Work Orders
WO 2925473, 52935626, 52988559, 52989633, 52991865,
2993254
RWP-2022-1508
Under Vessel Maintenance
ALARA Plans
RWP-2022-1952
Radiography and ARM Calibration
Corrective Action
Documents
CR-GGN-
21-05103, 2021-05838, 2021-05986, 2021-06898, 2021-
06978, 2021-07014, 2021-07184, 2021-07440, 2021-08405,
21-08538, 2021-09149, 2021-09235, 2021-09344, 2021-
09723, 2022-00110, 2022-00246, 2022-00304, 2022-00305,
22-00343, 2022-00353, 2022-00716, 2022-01853
Miscellaneous
ALARA Managers Committee Meeting: RWP 2022-1531
Suppression Pool Diving and Vacuum with Diaknot Robotic
Equipment
03/08/2021
Procedures
Personnel Contamination Events
2/29/2020
03/07/2022
Undervessel Equipment Tags
03/02/2022
Radiation
Surveys
03/04/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
LPRM Removal
03/09/2022
LPRM Cask
03/09/2022
LPRM Removal and Cut Up
03/09/2022
Survey Area - Surveyed the CA after the LPRM cask came
out of the CA (WO# 537206-25)
03/10/2022
LPRM Removal and Cut Up
03/10/2022
LPRM Removal
03/11/2022
LPRM Cask
03/11/2022
GGN-AS-030922-
0394
Beta/Gamma Air Sample - RWP/Task: 20221508/2 Under
Vessel Maintenance. TASK 2, 3, 4-High Radiological Risk
Activities
03/08/2022
GGN-AS-031022-
0417
Beta/Gamma Air Sample - RWP/Task: 20221508/2 Under
Vessel Maintenance. TASK 2, 3, 4-High Radiological Risk
Activities
03/10/2022
GGN-AS-031122-
0439
Beta/Gamma Air Sample: RWP/Task: 20221508/2 Under
Vessel Maintenance. TASK 2, 3, 4-High Radiological Risk
Activities
03/11/2022
RWP 2022-1508
Undervessel Activities
Radiation Work
Permits (RWPs)
RWP 2022-1952
Radiography and ARM Calibration
Self-Assessments QA-14-15-2021-
GGNS-1
Quality Assurance Audit Report
10/26/2021
Work Orders
WO-GGN-
2972141-01
06HPS000-SA-0001 Leak Test of Sealed Sources
01/12/2021
ALARA Plans
RWP 2022-1508
Under Vessel Maintenance
Corrective Action
Documents
CR-GGN-
21-03984, 2021-06743, 2021-07242, 2021-07725, 2021-
08027, 2021-08907, 2021-08930, 2021-08972, 2021-08980,
21-09001, 2021-09193, 2022-01644
Corrective Action
Documents
Resulting from
Inspection
CR-GGN-
22-02467
Monthly SCBA and Face Piece Inspection Log: June 2021
07/20/2021
Monthly SCBA and Face Piece Inspection Log: July 2021
08/02/2021
Miscellaneous
Monthly SCBA and Face Piece Inspection Log: August 2021
10/08/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Monthly SCBA and Face Piece Inspection Log: September
21
10/08/2021
Monthly SCBA and Face Piece Inspection Log: October
21
11/03/2021
MSA Air Hawk Qualification Matrix Report for: Chemistry,
Electrical, Instrument and Control, Mechanical, and
Radiation Protection Departments
2/21/2022
MSA Air Hawk and Fire Hawk Qualification Matrix Report:
Operations Department
2/21/2022
21-B5.31-
RESP-
Posi3 USB Test Results (Complete SCBA Test): 002, 004,
009, 026, 029, 032, 036, 044
23112-0
Compressed Air/Gas Quality Testing: Eagle Air (SN:
BHB1053G2U)
07/08/2021
28057-0
Compressed Air/Gas Quality Testing: Baron II (SN:
30T689509)
09/14/2021
2271-0
Compressed Air/Gas Quality Testing: Eagle Air
(SN: BHB1053G2U)
11/03/2021
435040-0
Compressed Air/Gas Quality Testing: Baron II
2/10/2021
437287-0
Compressed Air/Gas Quality Testing: Eagle Air Black Hawk
(SN: 95570401)
01/12/2022
06-ME-1T48-R-
0005
In-Place Testing of Standby Gas Treatment Filtration System
107
08-5-07-101
Operation and Maintenance of SCBA Fill Systems
DOP Challenge Testing of HEPA Vacuums and Portable
Ventilation Units
Operation and Maintenance of HEPA Vacuum Cleaners and
HEPA Ventilation Units
Respiratory Protection Program
Inspection and Maintenance of Respiratory Protection
Equipment
EN-RP-502-03
AirHawk II SCBA
Procedures
Breathing Air
Undervessel Equipment Tags
03/02/2022
Radiation
Surveys
LPRM Removal
03/09/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
LPRM Cask
03/09/2022
LPRM Removal
03/11/2022
LPRM Cask
03/11/2022
GGN-AS-030922-
0394
Beta/Gamma Air Sample: RWP/Task: 20221508/2 Under
Vessel Maintenance. TASK 2, 3, 4-High Radiological Risk
Activities
03/08/2022
GGN-AS-031022-
0417
Beta/Gamma Air Sample: RWP/Task: 20221508/2 Under
Vessel Maintenance. TASK 2, 3, 4-High Radiological Risk
Activities
03/10/2022
GGN-AS-031122-
0439
Beta/Gamma Air Sample: RWP/Task: 20221508/2 Under
Vessel Maintenance. TASK 2, 3, 4-High Radiological Risk
Activities
03/11/2022
Radiation Work
Permits (RWPs)
RWP 2022-1508
Under Vessel Maintenance
Self-Assessments LO-GLO-2019-
00192
In Plant Airborne Radioactivity Control and Mitigation
Inspection Assessment (IP 71124.03)
2/04/2020
Charcoal Adsorber Chemical Analysis: 06ME1000-R-0007-
01, 1T48D001A; T48 SGT Train "A" Division 1
04/15/2019
In-Place Testing of the Control Room Emergency Filtration
System: 06ME1Z51-R-0006-02 SZ51D002B; Train "B" DOP
Test Division 2
07/12/2019
Charcoal Adsorber Chemical Analysis: 06ME1000-R-0007-
2, 1T48D001B; SGT Train "B" Remove Test Canister
Division 2
09/26/2019
In-Place Testing of Standby Gas Treatment Filtration
System: 06ME1Z51-R-0006-01 SZ51D002A; Train "A" DOP
Test Division 1
2/24/2020
Charcoal Adsorber Chemical Analysis: 06ME1000-R-0007-
1T48D001A; T48 SGT Train "A" Remove Canisters
Division 1
05/21/2021
In-Place Testing of the Control Room Emergency Filtration
System: 06ME1Z51-R-0006-02 SZ51D002B; Train "B" DOP
Test Division 2
2/16/2020
Work Orders
Charcoal Adsorber Chemical Analysis: 06ME1000-R-0007-
01/05/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2, 1T48D001 B; SGT Train "B" Remove Test Canisters
Division 2
In-Place Testing of Standby Gas Treatment Filtration
System: 06ME1T48-R-0005-02, 1T48D001B; Train "B" DOP
Test, Division 2
2/02/2021
In-Place Testing of Standby Gas Treatment Filtration
System: 06ME1T48-R-0005-01, 1T48D001A; Train "A" DOP
Test, Division 1
05/30/2021
In-Place Testing of the Control Room Emergency Filtration
System: 06ME1Z51-R-0006-01 SZ51D002A; Train "A" DOP
Test Division 1
05/26/2021
In-Place Testing of Standby Gas Treatment Filtration
System: 1T48D001B - Train "B" Change Charcoal and
Perform DOP Test Division 2
10/15/2019
In-Place Testing of Standby Gas Treatment Filtration
System: 06ME1T48-R-0005-01, 1T48D001A; Train "A" DOP
Test, Division 1
10/24/2019
NRC Performance Indicator Technique/Data Sheet
07/01/2021
NRC Performance Indicator Technique/Data Sheet
10/05/2021
Calculations
NRC Performance Indicator Technique/Data Sheet
01/07/2022
71151
Miscellaneous
GGNS Annual Effluent Dose Report 2021
03/10/2022
Corrective Action
Documents
CR-GGN-
22-00813, 2022-00833, 2022-01378, 2022-01586, 2022-
01675, 2022-01688, 2022-01723
Evaluate Replacement for HPCS DG Speed Probe and
Modify Mounting Bracket
71152A
Procedures
Corrective Action Program
47