IR 05000416/2022002
| ML22214A164 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 08/11/2022 |
| From: | Harry Freeman NRC/RGN-IV/DORS/PBC |
| To: | Kapellas B Entergy Operations |
| Josey J | |
| References | |
| IR 2022002 | |
| Download: ML22214A164 (34) | |
Text
August 9, 2022
SUBJECT:
GRAND GULF NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000416/2022002
Dear Mr. Kapellas:
On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Grand Gulf Nuclear Station. On July 14, 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.
Six findings of very low safety significance (Green) are documented in this report. Six 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 or severity 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-2022-002-0012
Licensee:
Entergy Operations, Inc.
Facility:
Grand Gulf Nuclear Station
Location:
Port Gibson, MS
Inspection Dates:
April 1 to June 30, 2022
Inspectors:
J. Drake, Senior Reactor Inspector
S. Hedger, Senior Emergency Preparedness Inspector
S. Roberts, Resident Inspector
A. Smallwood, Resident Inspector
T. Steadham, Senior Resident Inspector
H. Strittmatter, Emergency Preparedness 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 Secure Loose Items Prior to Impending Severe Weather Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000416/2022002-01 Open/Closed
[P.2] -
Evaluation 71111.01 An NRC-identified Green finding and associated non-cited violation of Technical Specification 5.4.1, Procedures, was identified when the licensee failed to prepare for impending severe weather in accordance with licensee procedures. As a result, a stanchion in the immediate vicinity of transformer ESF-12 remained unsecured prior to, during, and after periods when high winds were projected onsite.
Failure to Establish Testing Program as Required by Appendix B, Criterion XI, Test Control with Two Examples.
Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000416/2022002-02 Open/Closed
[P.5] -
Operating Experience 71111.08G An NRC-identified Green finding and associated non-cited violation of 10 CFR Part 50, appendix B, criterion XI, Test Control, with two examples was identified when the licensee failed to establish testing requirements and acceptance limits to detect degradation of the fuel transfer tube, or the closure hatch as required by 10 CFR Part 50, appendix B, criterion XI.
The failure to detect degradation of the fuel transfer tube or closure hatch could result in the components being rendered inoperable and unable to meet their safety-related functions.
Failure to Ensure Functionality of Drywell Unidentified Leakage Monitoring System Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000416/2022002-03 Open/Closed
[P.3] -
Resolution 71111.19 An NRC-identified Green finding and associated non-cited violation of Technical Specification 3.4.7.C.1 was identified when the licensee failed to ensure that the drywell air cooler condensate flow rate monitoring system was capable of performing its intended function. Specifically, on February 18, 2022, flow obstructions prevented the system from being capable of performing its intended function. As a consequence, the licensee failed to perform a channel check of the required drywell atmospheric monitoring system required once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> while the drywell air cooler condensate flow rate monitoring system was inoperable.
Failure to Maintain Arrangements for Assistance with an Offsite Organization Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000416/2022002-04 Open/Closed None (NPP)71114.05 An NRC-identified Green finding and associated non-cited violation of 10 CFR 50.54(q)(2)was identified when the licensee failed to follow their emergency plan. Specifically, the licensee failed to follow Grand Gulf Nuclear Station Emergency Plan, revisions 74 to 81, section 8.5, which states that letters of agreement with offsite organizations are reviewed during annual plan reviews and updated as necessary. Specifically, the licensee failed to annually confirm the arrangements with the Claiborne County Sheriffs Office described in the emergency plan. The majority of the services described in the emergency plan as needed from the sheriffs office were not captured in a letter of agreement from 2016 to present.
Discussion between the licensee and the sheriffs office revealed that, despite not maintaining the agreement, the sheriff would be willing to support implementation of the emergency plan.
Failure to Disseminate Public Information to Portions of the Emergency Planning Zone Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000416/2022002-05 Open/Closed
[H.3] - Change Management 71114.05 An NRC-identified Green finding and associated non-cited violation of 10 CFR 50.54(q)(2)was identified when the licensee failed to follow their emergency plan. Specifically, the licensee failed to follow Grand Gulf Nuclear Station Emergency Plan, revisions 79 to 81, section 8.7, which requires an annual dissemination of emergency preparedness information to residents of the 10-mile emergency planning zone. In 2020 and 2021, the licensee failed to provide this annual information to residents in certain portions of the emergency planning zone.
Failure to Perform Appropriate Preventive Maintenance Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000416/2022002-06 Open/Closed
[P.5] -
Operating Experience 71153 A self-revealed Green finding and associated non-cited violation of Technical Specification 5.4.1, Procedures, was identified when the licensee failed to perform appropriate preventive maintenance on the loss of power relay associated with the high pressure core spray minimum flow valve. As a result, the relay failed on September 9, 2021, causing high pressure core spray to become inoperable which was reported as Licensee Event Report 05000416/2021-003-00.
Additional Tracking Items
Type Issue Number Title Report Section Status
LER 05000416/2021-003-00 High Pressure Core Spray Declared Inoperable 71153 Closed
PLANT STATUS
Grand Gulf Nuclear Station, Unit 1, began the inspection period shutdown for refueling outage 23 (RF23). On April 30, 2022, operators began a plant startup following completion of RF23 and achieved rated thermal power (RTP) on May 9, 2022. On May 23, 2022, operators reduced power to 60 percent RTP for power suppression testing to locate a suspected fuel leak.
Following the testing, operators returned the unit to RTP on May 28, 2022. On May 29, 2022, operators reduced power to 76 percent RTP for a rod pattern adjustment. The unit was returned to RTP on May 30, 2022. On June 30, 2022, operators manually shut the unit down as a result of a loss of plant service water 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, 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 severe thunderstorms with projected high winds that were predicted on March 30, 2022.
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on April 20, 2022.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)residual heat removal B while in standby alignment for decay heat removal on April 22, 2022 (2)standby liquid control B following surveillance testing on May 13, 2022 (3)high-pressure core spray vessel nozzle inspections on June 21, 2022
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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)residual heat removal B pump room on April 20, 2022 (2)drywell, all elevations, on April 22, 2022 (3)high-pressure core spray pump room on April 27, 2022 (4)residual heat removal A pump room on May 25, 2022 (5)containment general areas, all elevations, on June 23, 2022
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on June 2, 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) residual heat removal B pump room on May 25, 2022
71111.08G - Inservice Inspection Activities (BWR)
BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding
Activities (IP Section 03.01)
- (1) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined, and accepted by reviewing the following activities from February 28 to March 10, 2022:
03.01.a - Nondestructive Examination and Welding Activities.
The inspectors observed and/or reviewed the following nondestructive examinations:
VT-1 Decon flange, 1B33C001B, nuts and studs
VT-3 site service water, Q2P41G01A01, pipe support and attachment welds
VT-3 site service water, Q1P41G009R06, pipe support and attachment welds
ultrasonic examination high-pressure core spray, 1E22G003W10, pipe to valve ultrasonic examination feedwater nozzle, 1B21G026W12, pipe to nozzle
ultrasonic examination feedwater nozzle, 1B21G026W43, nozzle to pipe
ultrasonic examination nuclear boiler system, 1B21G3-A1-A, pipe to elbow
magnetic particle examination reactor pressure vessel, AG, circular head-to-flange weld The following nondestructive examination records with relevant indications accepted for continued service were reviewed:
ISI-VT-20-011, nuclear boiler system, Q1B21G026C01, support B3
ISI-VT-20-032, nuclear boiler system, Q1B21G026C01, support B3
ISI-VT-21-007, reactor core isolation cooling, P-1083-01, valve The following weld packages were reviewed:
===00549912, gas tungsten arc welding, 1-1/4 HBC-407 piping on 1P41C003A standby service water cooling tower SP41B001A FAN gear box, W900, W901, W902, W903, W904, W905, W906, W907, W908, and W909
00557050, gas tungsten arc welding, 1T51B002, low pressure core spray cooler inlet/outlet piping, W901 and W902 The inspectors evaluated a sample of 12 condition reports associated with inservice inspection activities. The inspector did not identify any findings or violations of more than minor significance.
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) The inspectors observed and evaluated licensed operator performance in the control room during plant startup from refueling outage 23 on April 30, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator requalification simulator training on June 23, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)condition report CR-GGN-2022-04667, containment spray breaker failure during testing on May 13, 2022 (2)condition report CR-GGN-2022-01290, high-pressure core spray needs to be evaluated for (a)(1) status on June 21, 2022
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
(1)commercial grade dedication for emergency diesel generator temperature control valve O-rings on June 15, 2022
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 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)protected system verification while in Yellow shutdown safety risk on April 21, 2022 (2)standby diesel generator 12 operability verification with standby diesel generator 11 inoperable on May 17, 2022 (3)protected system lineup with standby diesel generator 11 out of service on June 17, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)condition report CR-GGN-2022-03258, missing fasteners on safety-relief valve tailpipes on May 13, 2022 (2)condition report CR-GGN-2022-01496, potential clog in drywell cooler condensate drain line on June 30, 2022
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
(1)temporary and long-term scaffolding installation on May 27, 2022 (2)engineering change 91526, equivalency evaluation for replacement Limitorque valve actuator motor on May 27, 2022
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
(1)work order 52941763, clean and flush drywell cooler drain pans and drain lines on April 27, 2022 (2)work order 578263, repair motor control center 16B31 feeder breaker on May 13, 2022 (3)work order 52941071, replace safety-relief valves on May 20, 2022 (4)work order 572160, replace motor for B21F065B valve actuator on May 27, 2022 (5)work order 580099, rebuild thermostatic control valve for division 1 emergency diesel generator on May 27, 2022 (6)work order 577869, drywell cooler drain line piping replacement on June 22, 2022 (7)work order 562977, clean and flush drywell cooler drain pans and drain lines on June 24, 2022
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated refueling outage 23 activities from April 1 to May 2, 2022.
The inspectors completed inspection procedure sections 03.01.d. and 03.01.e. on May 2, 2022. This completes the sample that was partially completed and documented in Inspection Report 05000416/2022001 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22115A056).
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)procedure 06-OP-1P75-R-003, division 1 simulated loss of power with loss of coolant accident test on April 22, 2022 (2)work order 52926479, containment integrated leak rate test on May 6, 2022 (3)work order 252120, drywell bypass leak rate test on May 25, 2022 (4)reactor coolant system hydrostatic test on May 13, 2022
Inservice Testing (IP Section 03.01) (3 Samples)
(1)work order 52993245, reactor core isolation cooling quarterly pump test on May 6, 2022 (2)work order 52997934, procedure 06-OP11C41-Q-0001-02, standby liquid control pump B quarterly performance test on May 20, 2022 (3)work order 52999920, main steam isolation valve as-left stroke time testing on June 22, 2022
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the maintenance and testing of the alert and notification system between November 14, 2020, and June 17, 2022.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the Emergency Preparedness Organization between November 14, 2020, and June 17, 2022. Inspectors also evaluated the licensee's ability to staff their emergency response facilities in accordance with emergency plan commitments.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated the 10 CFR 50.54(q) emergency plan change process and practices between November 14, 2020, and June 17, 2022. The evaluation reviewed screenings and evaluations documenting implementation of the process. In addition, the inspectors evaluated the following emergency plan revisions:
Emergency Action Level Technical Bases Document, revision 1 (notification submitted April 15, 2021)
Alert and Notification System (ANS) Evaluation Report, revision 0 (notification submitted January 11, 2022)
The reviews of the change process documentation or the emergency plan changes do not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program between November 14, 2020, and June 17, 2022. The evaluation reviewed evidence of completing various emergency plan commitments, the conduct of drills and exercises, licensee audits and assessments, and the maintenance of equipment important to emergency preparedness.
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
(1)classification and notification evaluation during licensed operator requalification simulator training on June 23,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)===
- (1) April 1, 2021, through March 31, 2022
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)
- (1) April 1, 2021, through March 31, 2022
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)
- (1) April 1, 2021, through March 31, 2022
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) April 1, 2021, through March 31, 2022 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) April 1, 2021, through March 31, 2022 EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) April 1, 2021, through March 31, 2022
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in foreign material exclusion control that might be indicative of a more significant safety issue.
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Follow up (IP Section 03.01)
- (1) The inspectors evaluated the manual scram due to loss of plant service water and the licensees response on June 30, 2022.
Event Report (IP Section 03.02) (1 Sample)
The inspectors evaluated the following licensee event report (LER):
- (1) LER 05000416/2021-003-00, High Pressure Core Spray Declared lnoperable (ML21308A491). The inspection conclusions associated with this LER and a Green, non-cited violation is documented in the Inspection Results section of this report.
INSPECTION RESULTS
Failure to Secure Loose Items Prior to Impending Severe Weather Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000416/2022002-01 Open/Closed
[P.2] -
Evaluation 71111.01 An NRC-identified Green finding and associated non-cited violation of Technical Specification 5.4.1, Procedures, was identified when the licensee failed to prepare for impending severe weather in accordance with licensee procedures. As a result, a stanchion in the immediate vicinity of transformer ESF-12 remained unsecured prior to, during, and after periods when high winds were projected onsite.
Description:
On March 22, 2022, severe thunderstorms with predicted high winds were forecasted onsite. At the time, Grand Gulf was shut down for a refueling outage and transformer ESF-12 was protected for normal offsite power supply to the safety buses.
Operations entered off-normal event procedure (ONEP) 05-1-02-VI-2, Hurricanes, Tornados, and Severe Weather, revision 143, to prepare for the incoming severe weather.
The ONEP required the station to perform outside walkdowns in accordance with procedure EN-FAP-EP-010, Severe Weather Response, revision 8, to secure loose objects which could become missile hazards and damage plant equipment. Step 24 of attachment 5 of this procedure required, in part, the licensee to, secure all loose equipment such as ladders, fire extinguishers, and hose reels, waste containers, life rings, etc. To the extent practical, have loose materials...that could become missiles removed, stored, or securely tied down (i.e., pipes, boards, tools, and other materials that could be picked up by the wind and hurled through the air...and cause damage to the plant.).
After the licensee completed their walkdowns, the inspectors performed an independent walkdown and identified numerous objects around the yard which were required to be secured per procedure but were not secured. One such item was a stanchion inside the fenced area of transformer ESF-12. The inspectors provided their observations to the licensee with photographs of the unsecured items, including the stanchion. The licensee entered the inspectors concerns as condition report CR-GGN-2022-03274 as a non-adverse condition and closed the condition report documenting that all items were either secured or removed. The storm passed with lower than projected wind speeds and no damage was noted to the plant.
On March 30, 2022, severe thunderstorms with projected high winds were again forecasted for the area. The severe weather ONEP was again entered and yard walkdowns again completed using procedure EN-FAP-EP-010. The inspectors performed walkdowns and found many of the same items as they identified 8 days prior in the same condition and location. The licensee accompanied the inspectors on another tour of the yard where all unsecured items not complying with procedure EN-FAP-EP-010 were identified to the licensee including the stanchion in the transformer ESF-12 fenced area. Transformer ESF-12 remained protected on March 30, 2022. The storm passed with lower than projected wind speeds and no damage was noted to the plant.
On March 31, 2022, after all severe weather had passed, the inspectors again performed a yard walkdown and identified the stanchion remained in the transformer ESF-12 fenced area.
The inspectors questioned whether the stanchion had been removed the day prior and placed back or if the stanchion was secure in a manner that was not readily apparent. The licensee concluded that the stanchion was not removed, stored, or securely tied down while the severe weather was present onsite. The stanchion was later removed after the inspectors discussed this issue with licensee management.
The licensee entered the inspectors observations into the corrective action program as condition report CR-GGN-2022-03776 as a B level condition report with a causal evaluation.
Corrective Actions: Licensee corrective actions included removing the stanchion from the transformer ESF-12 fenced area and performing a causal evaluation.
Corrective Action References: This issue was entered into the licensees corrective action program as condition report CR-GGN-2022-03776.
Performance Assessment:
Performance Deficiency: The failure to secure loose objects in the immediate vicinity of transformer ESF-12 was contrary to procedure EN-FAP-EP-010 and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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, the stanchion was a credible missile hazard which could have damaged ESF-12 which would have affected shutdown equipment that was operating at the time.
Significance: The inspectors assessed the significance of the finding using IMC 0609, appendix G, Shutdown Safety SDP. Because the inspectors answered no to all screening questions in attachment 1, exhibit 5 of appendix G, the finding screened to a Green significance.
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. Specifically, the licensee failed to properly evaluate the potential impacts of the stanchion on the ESF-12 transformer, and therefore, failed to take appropriate action to resolve the issue (i.e., remove or secure the items).
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 6, recommends, in part, procedures for combating acts of nature. Licensee procedure 05-1-02-VI-2, revision 143, was developed to combat acts of nature such as severe weather. Procedure 05-1-02-VI-2, step 3.6, required performing procedure EN-FAP-EP-010, revision 8. Step 24 of attachment 5 of procedure EN-FAP-EP-010 required, in part, the licensee to, secure all loose equipment...To the extent practical, have loose materials...that could become missiles removed, stored, or securely tied down (i.e., materials that could be picked up by the wind and hurled through the air...and cause damage to the plant.).
Contrary to the above, on March 22 and March 30, 2022, the licensee failed to secure all loose equipment...To the extent practical, have loose materials...that could become missiles removed, stored, or securely tied down (i.e., materials that could be picked up by the wind and hurled through the air...and cause damage to the plant.) Specifically, a metal stanchion which could have become a missile during high winds and damaged transformer ESF-12 remained in place during periods of severe weather on both days when procedure 05-1-02-VI-2 was being implemented.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Failure to Establish Testing Program as Required by Appendix B, Criterion XI, Test Control with Two Examples.
Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000416/2022002-02 Open/Closed
[P.5] -
Operating Experience 71111.08G An NRC-identified Green finding and associated non-cited violation of 10 CFR Part 50, appendix B, criterion XI, Test Control, with two examples was identified when the licensee did not establish testing requirements and acceptance limits to detect degradation of the fuel transfer tube, or the closure hatch as required by 10 CFR Part 50, appendix B, criterion XI.
Failure to detect degradation of the fuel transfer tube or closure hatch could result in the components being rendered inoperable and unable to meet their safety-related functions.
Description:
During a review of Grand Gulf Nuclear Station's (GGNSs) inspection self-assessment report, (LO-GLO-2019-00167 CA-2, ISI Pre-NRC Inspection Self-Assessment, dated 11/10/2021), the inspectors identified several concerns with the assessments of two items. The self-assessment was performed in accordance with Nuclear Management Manual procedure EN-LI-104, Self-Assessment and Benchmark Process. The inspectors questioned the evaluation of operating experience pertaining to the fuel transfer tube and the closure hatch.
Example 1: The inspectors noted that the inservice inspection program classified the fuel transfer tube as ASME code class MC, while the Final Safety Analysis Report (FSAR) and original purchase documents listed the fuel transfer tube as seismic category 1, class 2. The inspectors noted that the inspections being performed on the fuel transfer tube did not fully comply with ASME code requirements for class MC components and did not ensure the fuel transfer tube would remain capable of performing its safety functions. When the licensee was made aware of this inconsistency, they determined that the correct classification of the fuel transfer tube was seismic category 1, quality class 2. The licensee had no program established as required by 10 CFR Part 50, appendix B, criterion XI, "Test Control," to ensure that the fuel transfer tube remained capable of performing its safety functions. The licensees initial position was that the fuel transfer tube was essentially an open-ended pipe, and therefore, no pressure testing was required per ASME code. The inspectors noted that the vendor documents specifically stated that the horizontal fuel transfer system was required to be pressure tested in accordance with ASME code requirements. Further inspection revealed that MNCR87-00448, "Revised Drawbridge Connections on HFTS," (horizontal fuel transfer system) performed in 1987 resulted in the knife valve having to be left in the open position.
Prior to this modification, the knife valve was required to be shut during reactor operations and would serve several functions, back up to the closure hatch and isolate the spent fuel pool from the fuel transfer tube and allow pressure testing of the fuel transfer tube. The knife valve was designed with a leak limit of 1 gpm. As a result of this modification, failure of the fuel transfer tube has the potential to cause a partial drain down of the spent fuel pool even during reactor operations, so the fuel transfer tube was evaluated using Inspection Manual Chapter 0609, appendix A, The Significance Determination Process (SDP) for Findings At-Power rather than Appendix G for shutdown conditions. The licensee completed a visual inspection of the accessible portions of the exterior of the fuel transfer tube and no indications of degradation were observed.
Example 2: The inspectors noted that the licensee's assessment was that their procedure for 10 CFR PART 50, appendix J leak rate testing did not require collection of "as found" leak rate data. The inspectors questioned this position since Grand Gulf was committed to Nuclear Energy Institute (NEI) 94-01, revision 0, dated July 26, 1995, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J." Regulatory Guide 1.163, Performance-Based Containment Leak-Test Program," section C, indicates that the NRC has endorsed Nuclear Energy Institute (NEI) 94-01, revision 0, dated July 26, 1995. NEI 94-01, section 8.0, Testing Methodologies For Type A, B and C Tests, states, in part, that the as-found and the as-left leakage rate for all pathways that are not drained and vented must be determined by type B and type C testing. The fuel transfer tube is not drained. Licensee procedure EN-WM-110, Surveillance Program, revision 2, section 7.3, Performance of Surveillance Tests, requires that surveillance testing be performed such that test results are not pre-conditioned by test procedure or maintenance prior to performance and as found leak rate data be obtained if possible. The licensee has not performed as found condition testing of the closure hatch and there has been no evaluation of the impact of the preconditioning. The licensee completed satisfactory as left leak rate checks on the closure hatch following refueling operations.
Corrective Actions: The licensee placed the issue into their corrective action program to change the classification of the fuel transfer tube in the inservice inspection (ISI) program to the correct designation of ASME code class 2 and develop a test program to ensure the fuel transfer tube and closure hatch remained capable of performing their safety functions.
Corrective Action References: Condition Reports CR-GGN-2022-01934, CR-GGN-2022-02433, CR-GGN-2022-02023, and CR-GGN-2022-02077
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to develop a testing program for the fuel transfer tube and the closure hatch to ensure they remained capable of performing their functions under design conditions was a performance deficiency.
Specifically, the failure to establish a testing program for the fuel transfer tube and the closure hatch was contrary to the requirements of 10 CFR Part 50, appendix B, criterion XI, Test Control.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the SSC and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.
Significance: The inspectors assessed the significance of the finding using IMC 0609.
Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using attachment A, exhibit 3 (barrier integrity), the finding screened as Green because the finding did not represent an actual open pathway in the physical integrity of reactor containment.
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. During the latest inservice inspection program self-assessment, completed in November 2021, the organization failed to systematically and effectively evaluate and implement corrective actions for external operating experience in a timely manner, they failed to recognize that the classification of the fuel transfer tube in the inservice inspection program was in conflict with the FSAR, and they failed to question why their classification of the fuel transfer tube differed from other licensees. The licensee failed to identify that their procedures for testing of the closure hatch did require "as found" leak rate data and did not evaluate why their assessment of testing requirements differed from requirements of other licensees. Since this was a recent opportunity for the licensee to review and assess these issues, the inspectors considered this indicative of present performance.
Enforcement:
Violation: As required by 10 CFR Part 50, appendix B, Criterion XI, Test Control, a test program shall be established to assure that all testing required to demonstrate that systems, structures, and components will perform satisfactorily in service is identified and performed in accordance with written procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Contrary to the above, from initial commercial operations until present, the licensee failed to establish testing programs to assure that all testing required to demonstrate that the fuel transfer tube and the closure hatch will perform satisfactorily in service was identified and performed in accordance with written procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Specifically, the licensee did not establish adequate testing required by 10 CFR Part 50, appendix B, criterion XI, Test Control," to detect degradation of the fuel transfer tube or the closure hatch. Since the violation is of very low safety significance and is documented in the licensees corrective action program as Condition Reports CR-GGN-2022-01934, CR-GGN-2022-02433, CR-GGN-2022-02023, and CR-GGN-2022-02077, it is being treated as a non-cited violation, consistent with section 2.3.2.a of the Enforcement Policy.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Observation: Commercial Grade Dedication for Emergency Diesel Generator Temperature Control Valve O-rings 71111.12 During inspection of this sample, a special inspection team was formed to review the events and circumstances surrounding the failure of the thermostatic control valve for the division 1 standby diesel generator. Any findings or observations associated with this valve failure will be documented in Special Inspection Reactive Report 05000416/2022050. No ADAMS accession number was available at the time this integrated report was issued because the special inspection report has not yet been issued.
Failure to Ensure Functionality of Drywell Unidentified Leakage Monitoring System Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000416/2022002-03 Open/Closed
[P.3] -
Resolution 71111.19 An NRC-identified Green finding and associated non-cited violation of Technical Specification 3.4.7.C.1 was identified when the licensee failed to ensure that the drywell air cooler condensate flow rate monitoring system was capable of performing its intended function. Specifically, on February 18, 2022, flow obstructions prevented the system from being capable of performing its intended function. As a consequence, the licensee failed to perform a channel check of the required drywell atmospheric monitoring system required once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> while the drywell air cooler condensate flow rate monitoring system was inoperable.
Description:
On February 18, 2022, operators received annunciator 1H13-P601-22A-E2 for the drywell air cooler drain flow high alarm in the control room. Investigation determined that unidentified leakage increased to approximately 4.5 gpm and then returned to the pre-event leakage rate of 0.13 gpm after several seconds. The licensee concluded, and the inspectors independently confirmed, that there were no other indications of a steam leak in the drywell.
Operators initiated condition report CR-GGN-2022-01496 to document that the drain line had likely temporarily stopped up and cleared causing a slug of water to cause the alarm.
Operators determined that the drain line remained operable to perform its intended function for drywell unidentified leakage monitoring.
On February 22, 2022, the inspectors questioned the operability of the drywell cooler condensate drain line for similar reasons following a previous obstruction that occurred on January 7, 2021, as discussed in NRC Inspection Report 05000416/2021001 (ML21123A300). After discussions with the licensee, operators declared the drywell cooler condensate drain line flow monitoring system inoperable on February 22, 2022, and entered technical specification action statement 3.4.7.C.1.
On April 20, 2021, during a planned shutdown to address a condenser tube leak, the licensee also cleaned and flushed the drywell cooler drain lines. During that outage, the licensee identified an obstruction that required several attempts at clearing with various methods such as a mechanical drain snake. Subsequent flow testing of the lines indicated that the drain lines were capable of performing their function at the time; however, as described in condition report CR-GGN-2022-06494, the inspectors identified an anomaly in the data which could have provided evidence that not all obstructions had been removed from the line. Had the licensee identified these anomalies, they would have had the opportunity to question the ability of the system to perform its intended function for the remainder of the operating cycle.
The inspectors determined that these anomalies were within the licensees ability to identify, evaluate, and disposition during the planned outage. Therefore, the inspectors considered the formation of the obstruction to be within the licensees ability to foresee and correct.
During the most recent refuel outage in April 2022, while flushing these drain lines, the licensee identified obstructions that they were not able to clear via snaking. The licensee cut out and removed approximately 20 feet of drain piping refuel outage under work order 577869. Other obstructions were found elsewhere in the piping which were removed as they were identified. Additional inspections and flushing identified no additional obstructions.
The inspectors determined that the existence of these obstructions in the drain lines were likely the cause of the drywell air cooler drain flow high alarm on February 22, 2022.
Corrective Actions: Licensee corrective actions included replacing obstructed pipe, flushing the system, and developing corrective actions for long-term modifications of the system to increase equipment reliability and availability.
Corrective Action References: This issue was entered into the licensees corrective action program as condition report CR-GGN-2021-01496.
Performance Assessment:
Performance Deficiency: The failure to ensure that the drywell air cooler condensate flow rate monitoring system was capable of performing its intended function is a performance deficiency. Specifically, the performance deficiency contributed to the inoperability of the system.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment 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, the performance deficiency contributed to the inoperability of the system.
Significance: The inspectors assessed the significance of the finding using IMC 0609, appendix A, The Significance Determination Process (SDP) for Findings At-Power. Because the inspectors answered no to all screening questions in exhibit 1 of appendix A, the finding screens to a Green significance. Specifically, the drywell air cooler condensate flow rate monitoring system is not a probabilistic risk assessment function.
Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Because the licensee failed to adequately resolve the cause for continued obstructions forming in the system, this directly led to the failure to correct the underlying issues causing the clogging/obstructions.
Enforcement:
Violation: As required by Technical Specification 3.4.7.C.1, with the drywell air cooler condensate flow rate monitoring system inoperable, a channel check of the required drywell atmospheric monitoring system is required once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Contrary to the above, from February 18-22, 2022, the licensee failed to perform a channel check of the required drywell atmospheric monitoring system required once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> while the drywell air cooler condensate flow rate monitoring system was inoperable.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Observation: Rebuild Thermostatic Control Valve for Division 1 Standby Diesel Generator 71111.19 During inspection of this sample, a special inspection team was formed to review the events and circumstances surrounding the failure of the thermostatic control valve for the division 1 standby diesel generator. Any findings or observations associated with this valve failure will be documented in Special Inspection Reactive Report 05000416/2022050. No ADAMS accession number was available at the time this integrated report was issued because the special inspection report has not yet been issued.
Failure to Maintain Arrangements for Assistance with an Offsite Organization Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000416/2022002-04 Open/Closed None (NPP)71114.05 An NRC-identified Green finding and associated non-cited violation of 10 CFR 50.54(q)(2)was identified when the licensee failed to follow their emergency plan. Specifically, the licensee failed to follow Grand Gulf Nuclear Station Emergency Plan, revisions 74 to 81, section 8.5, which states that letters of agreement with offsite organizations are reviewed during annual plan reviews and updated as necessary. Specifically, the licensee failed to annually confirm the arrangements with the Claiborne County Sheriffs Office described in the emergency plan. The majority of the services described in the emergency plan as needed from the sheriffs office were not captured in a letter of agreement from 2016 to present.
Discussion between the licensee and the sheriffs office revealed that, despite not maintaining the agreement, the sheriff would be willing to support implementation of the emergency plan.
Description:
The inspectors reviewed the results of annual emergency preparedness reviews of letters of agreement (LOA). Letters of agreement that are annually confirmed with the organization are described in appendix D of the sites emergency plan. One of the LOA listed is with Claiborne County Sheriffs Office. Documentation showing evidence of recent reviews of this LOA with the county sheriff's office was not provided. The inspectors asked for evidence of this annual review by the emergency preparedness organization, and none could be provided.
The licensee researched the history on LOA maintenance with the Claiborne County Sheriffs Office. Part of this review was to confirm if there was an agreement with the sheriff's office to provide emergency response services as described in section 5.6.3 of the emergency plan.
Communications between the licensees emergency preparedness and security groups were conducted with the Claiborne County Sheriffs Office during the period of June 24-28, 2022.
This review revealed the following:
In December 2015, the emergency plan was revised (revision 74) to provide for maintaining the scope of emergency preparedness services within a memorandum of understanding (MOU) that was to be maintained between the sheriff's office and the site security organization. The commitment within the emergency plan to annually confirm the agreement providing credited services in the event of a radiological emergency did not change. However, in practice, the decision was made to assume that emergency preparedness services would be maintained current through site securitys MOU maintenance process.
From November 2015 to present, there is no evidence that the emergency preparedness department completed annual reviews of their portion of the security organization MOU with the county sheriff's office.
Review of the most recent renewed MOU between the security organization and the county sheriff's office (2021) revealed that the scope of services described within section 5.6.3 of the emergency plan was not included in the agreement.
Despite the failure to maintain the agreement on emergency preparedness support services during this time, Claiborne County Sheriffs Office indicated that they would be willing to support the full scope of services needed by the licensee in the event of a radiological emergency.
The inspectors concluded that Grand Gulf Nuclear Station did not maintain arrangements for use of offsite assistance because they failed to ensure there was an agreement with a scope of services provided by the Claiborne County Sherriffs Office consistent with those described in the site emergency plan.
Corrective Actions: The licensee entered this issue into the corrective action program. In addition, the licensee is taking action to develop a LOA with the sheriffs office that addresses the scope of services described in the emergency plan.
Corrective Action References: Condition Report CR-GGN-2022-06763
Performance Assessment:
Performance Deficiency: The failure to perform annual confirmations of the arrangements for offsite assistance for emergency preparedness purposes was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Offsite EP attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the ability to implement adequate measures to protect the health and safety of the public could be affected if agreements on what support offsite agencies provide to a licensee are not developed and maintained.
Significance: The inspectors assessed the significance of the finding using IMC 0609, appendix B, Emergency Preparedness SDP. The performance deficiency was determined to have very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded risk-significant planning standard function.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. The change in practices to maintain the affected agreement took place in 2015 and is not indicative of present performance.
Enforcement:
Violation: As required by 10 CFR 50.54(q)(2), a power reactor licensee is to follow an emergency plan which meets the requirements of appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b). Planning standard 10 CFR 50.47(b)(3) requires, in part, that arrangements for requesting and effectively using assistance resources have been made.
Grand Gulf Nuclear Station Emergency Plan, revisions 74 to 81, section 8.5, states that LOA with offsite organizations are reviewed during annual plan reviews and updated as necessary.
Contrary to the above, between January 1, 2017, to present, Grand Gulf Nuclear Station failed to follow an emergency plan which met the requirements of appendix E and the standards of 10 CFR 50.47(b). Specifically, regarding services described in the site emergency plan, the licensee failed to annually review the LOA with Claiborne County Sheriffs Office during plan reviews.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Failure to Disseminate Public Information to Portions of the Emergency Planning Zone Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000416/2022002-05 Open/Closed
[H.3] - Change Management 71114.05 An NRC-identified Green finding and associated non-cited violation of 10 CFR 50.54(q)(2)was identified when the licensee failed to follow their emergency plan. Specifically, the licensee failed to follow Grand Gulf Nuclear Station Emergency Plan, revisions 79 to 81, section 8.7, which requires an annual dissemination of emergency preparedness information to residents of the 10-mile emergency planning zone. In 2020 and 2021, the licensee failed to provide this annual information to residents in certain portions of the emergency planning zone.
Description:
The inspectors reviewed documentation associated with the licensees annual residential emergency preparedness information mailings over the review period. The mailing list used for 2021 was reviewed versus the 10-mile emergency planning zone (EPZ) map, as defined in figure 2-4 of the emergency plan. Based on observation, while the major residential centers appeared to be addressed, there were several towns with residents in the EPZ that didnt appear to be covered on the mailing list. The observations were shared with the licensee for further investigation.
This review revealed the following:
In 2019, changes were made to the mailing process. At the time, annual mailings were being sent to residents in the 10-mile EPZ plus additional areas. Changes were made with the intent to provide the annual dissemination to the 10-mile EPZ residents only.
Revised mailing lists were used for sending out residential information in 2020 and 2021.
There were some towns with residents living in the 10-mile EPZ that were not covered in the 2020 and 2021 mailing lists. The affected areas were identified during the investigation.
The inspectors inquired as to whether the change control process used in 2019 provided for evaluation of the changes to ensure the revised mailing lists still reached the intended audience. Although the mailing list was generated by a service contractor, the licensee had the ability to review it and provide feedback. The licensee determined that there was no evidence of a follow-up review of the mailing list in the subsequent years to make adjustments. Therefore, the omissions of the affected areas was allowed to stay this way for the subsequent years.
The inspectors determined that the licensee did not mail emergency preparedness information post cards to some residents of the 10-mile EPZ in 2020 and 2021. Therefore, the inspectors concluded that the licensee did not follow the requirements of the site emergency plan.
Corrective Actions: The licensee entered these issues into the corrective action program. In addition, the licensee took action to revise the mailing list, and to send out the post cards to the affected population.
Corrective Action References: Condition Report CR-GGN-2022-06842
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to complete annual postcard distribution to all residents in the 10-mile EPZ is a performance deficiency within the licensees ability to foresee and correct.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Offsite EP attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the ability to implement adequate measures to protect the health and safety of the public could be affected if the public does not have current information informing them of how they will receive notifications and what their actions should be in an emergency.
Significance: The inspectors assessed the significance of the finding using IMC 0609, appendix B, Emergency Preparedness SDP. The performance deficiency was determined to have very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded risk-significant planning standard function. The planning standard function was not lost because the licensee had provided annual mailings to the affected population in the past, and public emergency information was available through a public website.
Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.
Specifically, the mailing list revision process did not include reviews of the list used in the following years to ensure that the implemented change still provided the annual public information to residents in the 10-mile EPZ.
Enforcement:
Violation: As required, in part, by 10 CFR 50.54(q)(2), a power reactor licensee will follow an emergency plan which meets the requirements of appendix E to 10CFR Part 50 and the standards of 10CFR 50.47(b). Planning standard 10CFR 50.47(b)(7) requires, in part, that information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency. Grand Gulf Nuclear Station Emergency Plan, revisions 79 to 81, section 8.7, states, in part, that public information is disseminated via postcards mailed annually to residents of the 10-mile EPZ.
Contrary to the above, between January 1, 2021, to present, Grand Gulf Nuclear Station failed to follow an emergency plan which met the requirements of appendix E and the standards of 10CFR 50.47(b). Specifically, the licensee failed to disseminate public information via postcards to a portion of the residents in the 10-mile EPZ.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Observation: Semiannual Trend in Foreign Material Exclusion Control 71152S The inspectors performed a review of potential adverse trends in foreign material exclusion (FME) that might be indicative of a more significant safety issue. The inspectors performed interviews and plant walkdowns and sampled a population of condition reports during the period of January 1 through June 30, 2022.
Based upon the samples reviewed, the inspectors found that there was an apparent increasing trend in adverse FME and housekeeping events. For example, during multiple walkdowns inside containment and the drywell, in both FME zone 1 areas which required the highest level of FME controls, the inspectors identified miscellaneous loose trash and debris, clear plastic, and items which were not authorized in the area per the licensees FME control plan. Additionally, multiple condition reports were written during the outage which were related to potential FME events such as dropped objects inside containment and the drywell, wire pieces found inside the spent fuel pool, and jewelry being worn in areas which prohibited the wearing of jewelry. However, station management properly identified the need for trend review upon reaching condition and performance monitoring thresholds generating corrective actions consistent with their programs to address the decline in performance related to FME controls and worker behavior. The inspectors did not identify any findings as a result of this inspection.
Failure to Perform Appropriate Preventive Maintenance Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000416/2022002-06 Open/Closed
[P.5] -
Operating Experience 71153 A self-revealed Green finding and associated non-cited violation of Technical Specification 5.4.1, Procedures, was identified when the licensee failed to perform appropriate preventive maintenance on the loss of power relay associated with the high pressure core spray minimum flow valve. As a result, the relay failed on September 9, 2021, causing high pressure core spray to become inoperable which was reported as Licensee Event Report 05000416/2021-003-00.
Description:
On September 9, 2021, operators received the high-pressure core spray (HPCS)out of service annunciator along with a HPCS motor-operated valve (MOV) power loss status light. Investigation showed a loss of power to the HPCS minimum flow valve. Operators declared HPCS inoperable. Troubleshooting identified the loss of power relay in the breaker failed with visible charring to the relay. The relay, a GE type CR120B, was a normally energized relay and had been in service for approximately 36 years. The relay was replaced on September 10, 2021, and the system was declared operable approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the initial failure.
The licensee performed a causal evaluation and determined that the relay failed due to normal and expected service life degradation. The relay was allowed to remain installed for that length of time because they failed to utilize operating experience, including GE Service Information Letter 229, which described limiting the service life of these normally energized relays. Based on an operating experience search, the licensee concluded that the relays should have been replaced when the breakers were overhauled every 10 years, but the breaker preventive maintenance instructions contained no steps to either perform these inspections or to pre-emptively change the relay.
The licensee identified 24 previous instances, 5 of which were in safety-related applications, of similar types of relays failing. In each case, the relays were replaced with no documented attempt to understand why they failed.
The licensee reported this event as Licensee Event Report 05000416/2021-003-00 on November 4, 2021.
Corrective Actions: Licensee corrective actions included replacing other susceptible relays and initiated actions to update the preventive maintenance basis template to include the replacement of these relays when the associated breaker is either refurbished or replaced.
Corrective Action References: This issue was entered into the licensees corrective action program as condition report CR-GGN-2022-06911.
Performance Assessment:
Performance Deficiency: The failure to perform appropriate preventive maintenance on the loss of power relay associated with the HPCS minimum flow valve was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment 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, the performance deficiency contributed to the inoperability of the system.
Significance: The inspectors assessed the significance of the finding using IMC 0609, appendix A, The Significance Determination Process (SDP) for Findings At-Power. Because the inspectors answered no to all screening questions in exhibit 2 of appendix A, the finding screens to a Green significance.
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 adequately utilize operating experience to ensure that the loss of power relays had an appropriate preventive maintenance strategy.
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 9, recommends, in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures appropriate to the circumstances and that preventive maintenance schedules should be developed to specify inspections of equipment and inspection or replacement of parts that have a specific lifetime.
Contrary to the above, until September 9, 2021, the licensee failed to properly pre-plan and perform maintenance that could affect the performance of safety-related equipment in accordance with written procedures appropriate to the circumstances and failed to develop preventive maintenance schedules to specify inspections of equipment and inspection or replacement of parts that have a specific lifetime. Specifically, no maintenance was performed on the HPCS minimum flow valve breaker loss of power relay, a safety-related component, and no preventive maintenance schedules for either inspection or replacement was developed until the relays failed in service. This failure caused the HPCS system to be inoperable until the relay was replaced on September 10, 2021.
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 July 14, 2022, the inspectors presented the inservice inspection, emergency preparedness program, and integrated inspection results to Mr. B. Kapellas, 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-
21-09464, 2021-09598, 2022-01436
Corrective Action
Documents
Resulting from
Inspection
CR-GGN-
22-01685, 2022-01826, 2022-01877, 2022-01912,
22-01913, 2022-01923, 2022-01934, 2022-01941,
22-01961, 2022-01989, 2022-02007, 2022-02023,
22-02077, 2022-02126, 2022-02127, 2022-02141,
22-02433, 2022-03329. 2022-11851, 2022-11893
CEP-APJ-001
Primary Containment Leakage Rate Testing
(10CFR50 Appendix J) Program Plan
CEP-COS-0100
Control And Use of IDDEAL Concepts Software
CEP-NDE-0100
Administration and Control of NDE
CEP-NDE-0110
Certification of NDE Personnel
CEP-NDE-0400
Ultrasonic Examination
CEP-NDE-0404
Manual UT Ferritic Piping
CEP-NDE-0407
Straight Beam Ultrasonic Examination of Bolts and
Studs (ASME XI)
CEP-NDE-0423
Manual UT Austenitic Piping
CEP-NDE-0641
Liquid Penetrant Examination for ASME Section XI
CEP-NDE-0901
VT-1 Examination
CEP-NDE-0902
VT-2 Examination
CEP-NDE-0903
VT-3 Examination
CEP-WP-WIIR-1
Weld In process Inspection Requirements
DR-ECH-
WPS_CS_1_1_A000
CEP-WP-002
Welding Procedure Specification
DR-ECH-
WPS_CS_1_1_B000
CEP-WP-002
Welding Procedure Specification
DR-ECH-
WPS_CS_1_1_C000
CEP-WP-002
Welding Procedure Specification
Procedures
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Generic Foreign Material Exclusion
Quality Assurance Program Manual
SEP-CISI-102
Program Section for ASME Section XI, Division 1
GGNS Containment Inservice Inspection Program
SEP-ISI-GGN-001
Program Section for ASME Section Xi, Division 1
GGNS Inservice Inspection Program
WDI-STD-006
Manual Ultrasonic Procedure for Examination of
Nozzle Inner Corner Radius Areas in Accordance With
ASME Section XI, Including Appendix VIII
WDI-STD-1107
Generic Procedure for the Manual Ultrasonic
Examination of Reactor Pressure Vessel Welds in
Accordance with PDI-UT-6
WDI-STD-1151
Generic Procedure for the Manual Ultrasonic
Examination of Weld Overlaid Similar and Dissimilar
Metal Welds Using EPRI-WOL-PA-01
WDI-STD-1158
Procedure for Manual Phased Array Ultrasonic
Examination of Dissimilar Metal Welds in Accordance
with EPRI-DMW-PA-1
Self-
Assessments
ISI Pre-NRC Inspection Self-Assessment
11/10/2021
Miscellaneous
Scenario GSMS-LOR-WEX02.23
Corrective Action
Documents
CR-GGN-
22-01290, 2022-04778
10351537
Purchase Order
03/04/2019
58428
Receipt Inspection Report
04/04/2019
Miscellaneous
Commercial Grade Dedication Report
03/27/2019
Work Orders
Procedures
06-OP-1P75-V-0013
Standby Diesel Generator 12 Operability Verification
05/17/2022
Corrective Action
Documents
CR-GGN-
22-01496, 2022-01620, 2022-03258, 2022-04779
Work Orders
WO 2977, 577869, 52941763
Corrective Action
Documents
CR-GGN-
22-04779
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Engineering
Changes
Receiving Inspection Report 70304
Miscellaneous
Material Issue Report for Catalog ID 83264073-1
05/27/2022
Work Orders
Corrective Action
Documents
CR-GGN-
22-01496, 2022-04303, 2022-04803, 2022-05003,
22-05865, 2022-06494
Engineering
Changes
Procedures
06-OP-1P75-M-0001
Standby Diesel Generator 11 Functional Test
150
Work Orders
WO 2977, 572160, 577869, 578263, 580099,
2941071, 52941763
Corrective Action
Documents
CR-GGN-
22-03219, 2022-03221, 2022-03251, 2022-03360,
22-03362, 2022-03364, 2022-03428, 2022-05125,
22-05138, 2022-05139
06-OP-1B21-V-0001
Main Steam Isolation Valve Operability Test
25
Procedures
06-OP-1P75-R-003
Standby Diesel Generator 11 Functional Test
139
Work Orders
WO 2120, 52926479, 52939834, 52939955, 52993245,
2997934, 52999920
Corrective Action
Documents
CR-GGN-
20-12191, 2022-01614, 2022-05870,
Corrective Action
Documents
Resulting from
Inspection
CR-GGN-
22-06612
Email from ANS Siren Vendor Regarding Battery
Capacity
06/22/2022
FEMA Approval Letter for Siren Test Time Change
04/05/2022
FEMA Approval Letter for New ANS Design Report
08/10/2021
GGNS Siren Failure Population Calculator
06/23/2022
GIN: 2017/00031
FEMA Approved ANS REP-10 Report
May 2013
Miscellaneous
GIN: 2020/0176
Grand Gulf Nuclear Station Emergency Plan
01-S-10-3
Emergency Planning Department Responsibilities
Procedures
ENTANSERGGN201217
FEMA Approved ANS Design Report
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-GGN-
20-12039, 2021-02446, 2021-04195, 2021-05794,
21-05799, 2021-07811
Corrective Action
Documents
WT-GGN-2021-00422
Corrective Actions
GGNS On-Shift Staffing Analysis Final Report
EN-OP-133-02
Grand Gulf Nuclear Station Operations Notifications
Emergency Response Organization Training
GIN: 2020/00219
Quarterly Off-Hours Unannounced Everbridge Test
4th Quarter 2020
2/08/2020
GIN: 2020/0176
Grand Gulf Nuclear Station Emergency Plan
GIN: 2021/00066
Quarterly Off-Hours Unannounced Everbridge Test
1st Quarter 2021
03/29/2021
GIN: 2021/00101
Quarterly Off-Hours Unannounced Everbridge Test
2nd Quarter 2021
06/14/2021
GIN: 2021/00158
Green Team Off-Hours 07/28/2021 Unannounced
"Touch the Wall" Drill Report
10/07/2021
GIN: 2021/00175
Quarterly Off-Hours Unannounced Everbridge Test
4th Quarter 2021
11/04/2021
Miscellaneous
GIN: 2022/00023
Quarterly Off-Hours Unannounced Everbridge Test
1st Quarter 2022
2/02/2022
10-S-01-26
Emergency Plan Procedure Offsite Emergency
Response
10-S-01-6
Emergency Plan Procedure Notification of Offsite
Agencies and Plant On-Call Emergency Personnel
Drills and Exercises
Procedures
Emergency Response Organization Notification
System
CFR 50.54(q)(3)
Evaluation,
Procedure/Document
Number: EAL Technical
Bases, Revision: 1
EAL Technical Bases
03/21/2021
Miscellaneous
CFR 50.54(q)(3)
Evaluation,
Procedure/Document
ANS Evaluation Report Grand Gulf Nuclear
2/16/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Number:
ENTANSERGGN201217,
Revision: 0
CFR 50.54(q)(3)
Screening,
Procedure/Document
Number: CCFD LOA,
Revision: 0
Letter of Agreement Between Entergy Operations,
Inc., and the Claiborne County Fire Department
05/27/2021
CFR 50.54(q)(3)
Screening,
Procedure/Document
Number: EAL Technical
Bases, Revision: 1
EAL Technical Bases
03/21/2021
CFR 50.54(q)(3)
Screening,
Procedure/Document
Number: EN-EP-801,
Revision: 18
Emergency Response Organization
11/30/2021
CFR 50.54(q)(3)
Screening,
Procedure/Document
Number: MEMA LOA,
Revision: 61
Letter of Agreement Between Entergy Operations, Inc.
and the Mississippi Emergency Management Agency
05/27/2021
GNRO2021/00010
Grand Gulf Nuclear Station EAL Technical Bases
Document Revision 1, Grand Gulf Nuclear Station,
Unit 1; NRC Docket No. 50-416; Renewed Facility
Operating License No. NPF-29
04/15/2021
GNRO2022/00001
Grand Gulf Nuclear Station Unit 1, ANS Evaluation
Report; Grand Gulf Nuclear Station, Unit 1; NRC
Docket No. 50-416; Renewed Facility Operating
License NPF-29
01/11/2022
Procedures
Emergency Planning 10CFR50.54(q) Review Program
Corrective Action
Documents
CR-GGN-
20-11564, 2020-11586, 2020-12432, 2021-00218,
21-00219, 2021-00221, 2021-00884, 2021-02179,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
21-03962, 2021-05369, 2021-09002, 2022-00069,
22-01287, 2022-02996, 2022-03337, 2022-04161,
22-05230, 2022-05870, 2022-06118
Corrective Action
Documents
Resulting from
Inspection
CR-GGN-
22-06558, 2022-06609, 2022-06612, 2022-06763,
22-06842
Annual Fire Drill Report, Shift Team: A; October 16,
20
10/16/2020
GIN: 2020/00121
GGNS First Half Semi-Annual Health Physics Drill
Report
07/14/2020
GIN: 2020/00206
GGNS October 28, 2020, Blue Team 4th Quarter Drill
Report
11/27/2020
GIN: 2020/00220
GGNS Medical Drill Report
2/09/2020
GIN: 2021/00015
21 EOF Five Year Isolation Capability Test
01/13/2021
GIN: 2021/00038
Event Report - January 7, 2021, Unusual Event
01/28/2021
GIN: 2021/00075
GGNS March 16, 2021 - Green Team Graded
Exercise Drill Report
04/14/2021
GIN: 2021/00076
GGNS First Half Semi-Annual Health Physics Drill
Report 2021
04/14/2021
GIN: 2021/00077
GGNS HH2 Exercise - March 17, 2021
04/14/2021
GIN: 2021/00082
GGNS February 23, 2021 - Green Team Dress
Rehearsal Report
04/28/2021
GIN: 2021/00103
GGNS Medical Drill Report
06/16/2021
GIN: 2021/00155
GGNS Blue/Green Team Tabletop Report
GIN: 2021/00158
GGNS 2021-7-28 Green Team Off-Hours
Unannounced Drill Report
10/7/2021
GIN: 2021/00168
21_09_21_Practice Drill Red ERO Team
10/21/2021
GIN: 2021/00169
Quarterly Emergency Response Facilities Inventory
Report - 2nd Quarter 2021
2/07/2021
GIN: 2021/00173
21_09_28_INPO-WANO Evaluated Drill - Red
Team
10/27/2021
GIN: 2021/00188
GGNS Medical Drill Report
11/23/2021
Miscellaneous
GIN: 2021/00199
Annual Review of Census Growth Rates and
2/07/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Methodology for the Grand Gulf Nuclear Station is Not
Required in 2021
GIN: 2021/00204
GGNS Second Half Semi-Annual Health Physics Drill
Report
2/15/2021
GIN: 2021/00210
21 Annual Media Training
2/29/2021
GIN: 2022/00004
21 Annual Fire Brigade Drill with Offsite Support
01/06/2022
GIN: 2022/00012
GGNS 2021 DEC 15 Blue Team Drill
01/13/2022
GIN: 2022/00019
Emergency Preparedness Letter of Agreement (LOA)
Annual Review - 2021
01/26/2022
GIN: 2022/00091
Quarterly Emergency Response Facilities Inventory
Report - 1st Quarter 2022
04/20/2022
QA-7-2021-GGNS-01
Audited Area Title: Emergency Preparedness
Program
05/10/2021
01-S-10-3
Emergency Planning Department Responsibilities
10-S-01-11
Evacuation of Onsite Personnel
10-S-02-1
ERF Inspection, Inventories, Operability Checks, and
Maintenance
Drills and Exercises
Procedures
EN-OP-115-03
Shift Turnover and Relief
Work Orders
WO 548876, 564668
Miscellaneous
Scenario GSMS-LOR-WEX02.23
Miscellaneous
EOF Mini-Drill 2022-01
01/11/2022
01-S-10-3
Emergency Planning Department Responsibilities
71151
Procedures
EN-FAP-EP-005
Emergency Preparedness Performance Indicators
Corrective Action
Documents
CR-GGN-
21-06911
Miscellaneous
21-003-00
LER