IR 05000416/2023001

Notice of Violation; Integrated Inspection Report 05000416/2023001 and NRC Investigation Report 4-2022-004

ML23110A800
Person / Time
Site:	Grand Gulf
Issue date:	05/10/2023
From:	Jeffrey Josey NRC/RGN-IV/DORS/PBC
To:	Kapellas B Entergy Operations
Rollins J
References
EA-22-104, EA-22-115, 4-2022-004 4-2022-004
Download: ML23110A800 (40)

Text

May 10, 2023

SUBJECT:

GRAND GULF NUCLEAR STATION - NOTICE OF VIOLATION; INTEGRATED INSPECTION REPORT 05000416/2023001 AND NRC INVESTIGATION REPORT 4-2022-004

Dear Brad Kapellas:

This letter refers to an investigation completed on November 8, 2022, and an inspection completed on March 31, 2023, by the U.S. Nuclear Regulatory Commission (NRC) at the Grand Gulf Nuclear Station. The purpose of the investigation was to determine whether a willful violation of NRC requirements occurred for the failure to write a condition report after it was discovered that a required fire watch had not been established. On April 6, 2023, the NRC inspectors discussed the results of the investigation and the inspection with you and other members of your staff. A factual summary of the investigation is documented in Enclosure 2 and the results of the inspection are documented in Enclosure 3.

The enclosed report documents a Severity Level IV violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, appendix B, criterion V, for the failure to initiate a condition report after it was discovered that a required fire watch had not been established. The NRC evaluated this violation in accordance with section 2.3.2 of the NRC Enforcement Policy, which can be found at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in Enclosure 1, Notice of Violation (Notice), and the circumstances surrounding it are described in detail in the enclosed report. The violation did not meet the criteria to be treated as a non-cited violation (NCV) because it involved willfulness.

The enclosed report also documents a Severity Level IV violation of 10 CFR 21.21(d) for the failure to notify the Commission after the discovery of a defect associated with a substantial safety hazard evaluation. The NRC evaluated this violation in accordance with section 2.3.2 of the NRC Enforcement Policy. The violation is cited in Enclosure 1 and the circumstances surrounding it are described in detail in the enclosed report. This violation did not meet the criteria to be treated as an NCV because we determined that your staff failed to restore compliance within a reasonable period after the violation was identified. You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRCs review of your response will also determine whether further enforcement action is necessary to ensure your compliance with regulatory requirements.

Based on the results of this inspection, the NRC has also determined that a violation of 10 CFR 21.21(a)(1) occurred. The violation involved the failure to evaluate deviations and failures to identify defects associated with substantial safety hazards as soon as practicable and in all cases within 60 days of discovery, in order to identify a reportable defect that could create a substantial safety hazard. This violation was considered for escalated enforcement at Severity Level III per the NRC Enforcement Policy..However, in reviewing the specific circumstances of this violation (i.e., the NRC resident staff was aware of the issue, and there was little to no impact to the inspection process/regulatory process; the impact to overall containment leakage is mitigated by the size of the valves; your staff entered the issue into the corrective action program and issued a licensee event report after they concluded it was reportable under 10 CFR 50.73; and the valves were only supplied to the Grand Gulf Nuclear Station and no other licensees) the NRC determined that it is more appropriately categorized as a Severity Level IV violation. In addition, because the violation was entered into the corrective action program, corrected by your staff, not repetitive, and not willful, it is being treated as an NCV, consistent with section 2.3.2 of the NRC Enforcement Policy.

Additionally, two findings of very low safety significance (Green) are documented in this report.

One of these findings involved a violation of NRC requirements. Two Severity Level IV violations without an associated finding are also documented in this report. We are treating these violations as NCVs consistent with section 2.3.2 of the NRC Enforcement Policy.

Licensee-identified violations which were determined to be of very low safety significance are documented in this report. We are treating these violations as NCVs consistent with section 2.3.2 of the NRC Enforcement Policy.

In the preceding 12 months, the NRC issued five Severity Level IV traditional enforcement violations as described in NRC Inspection Report 05000416/2022002, dated August 9, 2022, and in this report. One violation was associated with willfulness and the other four violations were associated with impeding the regulatory process. The NRC noted that the four violations associated with impeding the regulatory process appear to show a gap in your process for making required reports to the NRC. The NRC determined that one of the examples was not representative of current plant performance. However, the NRC has determined that the other three violations were indicative of current performance, and the NRC is evaluating whether performance of Inspection Procedure 92723, Follow up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period, is warranted. This decision will be documented in future correspondence.

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 or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the 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.

In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter, its enclosures, and your response, will be made available electronically for public inspection in the NRC Public Document Room and from the NRCs ADAMS, accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction.

Sincerely, Jeffrey E. Josey, Chief Projects Branch C Division of Operating Reactor Safety Docket No. 05000416 License No. NPF-29 Enclosures:

1.

Notice of Violation 2.

Factual Summary 3.

Inspection Report 05000416/2023001 cc w/ encl: Distribution via LISTSERV Signed by Josey, Jeffrey on 05/10/23

ML23110A800 x

SUNSI Review x

Non-Sensitive

Sensitive x

Publicly Available

Non-Publicly Available OFFICE SES:ACES SRI:DORS/C ATL:ACES RC ASPE:DORS/C NAME JKramer TSteadham RKumano DCylkowski JRollins SIGNATURE

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/RA/ E DATE 04/25/23 04/21/23 05/04/23 05/01/23 05/10/23 OFFICE BC:DORS/C NAME JJosey SIGNATURE

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Enclosure 1 NOTICE OF VIOLATION Entergy Operations, Inc.

Docket No. 05000416 Grand Gulf Nuclear Station License No. NPF-29 EA-22-104 EA-22-115 During an NRC investigation completed on November 8, 2022, and an NRC inspection completed on March 31, 2023, two violations of NRC requirements were identified. In accordance with the NRC Enforcement Policy, the violations are listed below:

A. 10 CFR 21.21(a)(3) requires, in part, that entities subject to the regulations in 10 CFR Part 21 shall ensure that a director or responsible officer is informed as soon as practicable, and, in all cases, within the 5 working days after completion of the evaluation described in 10 CFR 21.21(a)(1).

10 CFR 21.21(d) requires, in part, that a director or responsible officer must notify the Commission when he or she obtains information reasonably indicating a failure to comply or a defect within 2 days following receipt of the information.

Contrary to the above, from August 13 to October 31, 2022, the licensee failed to notify the Commission after the discovery of a defect associated with a substantial safety hazard evaluation described in 10 CFR 21.21(a)(1). Specifically, the licensee identified that the lack of lubrication on the containment personnel airlock equalizing valves caused the excessive leakage and evaluated the condition as a substantial safety hazard on August 3, 2022, but failed to make the timeliness requirements to notify the Commission.

This is a Severity Level IV violation (NRC Enforcement Policy, section 6.9(d)(13). (EA-22-104)

B. 10 CFR Part 50, appendix B, criterion V requires, in part, that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings, of a type appropriate to the circumstances.

Procedure EN-LI-102, Corrective Action Program, revision 45, a quality-related procedure, attachment 1, step 21 states, in part, that any condition which materially impacts the ability to implement the fire protection program including degraded fire barriers and their subcomponents (penetration seals, fire doors and dampers), and fire detection and suppression systems, be screened as an adverse condition in the corrective action program.

Procedure EN-LI-102, step 5.2.4 requires, in part, that employees and contractors are required to initiate condition reports for adverse conditions.

Contrary to the above, from September 15, 2021, to April 20, 2022, licensed personnel failed to initiate a condition report for adverse conditions. Specifically, a licensed operator deliberately failed to write a condition report for a condition which materially impacted the ability to implement the fire protection program when a continuous fire watch was not established.

This is a Severity Level IV violation (NRC Enforcement Policy, section 2.2.1.d). (EA-22-115)

Pursuant to 10 CFR 2.201, Entergy Operations, Inc. is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 1600 East Lamar Blvd., Arlington, Texas 76011-4511, and the NRC Resident Inspector at the Grand Gulf Nuclear Station, and email it to R4Enforcement@nrc.gov within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a Reply to a Notice of Violation, EA-22-104 and EA-22-115, and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken; and (4) the date when full compliance will be achieved.

Your response may reference or include previous docketed correspondence if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, the NRC may issue an order or a demand for information requiring you to explain why your license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

Your response will be made available electronically for public inspection in the NRC Public Document Room and from the NRCs ADAMS, accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. Therefore, to the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction.

If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request that such material is withheld from public disclosure, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information).

Dated this 10th day of May 2023

Enclosure 2 FACTUAL

SUMMARY

OFFICE OF INVESTIGATIONS REPORT 4-2022-004

On December 8, 2021, the U.S. Nuclear Regulatory Commission (NRC) Office of Investigations Region IV initiated an investigation to determine if a licensed operator, employed by Entergy Operations Inc. (licensee) at the Grand Gulf Nuclear Station (GGNS), deliberately failed to write a condition report after licensee personnel discovered that a required fire watch had not been established. The investigation was completed on November 8, 2022.

Licensee document 1-FTR-0406 required a continuous fire watch be established for the division 1 and division 2 switchgear rooms beginning on September 14, 2021. On September 15, 2021, a licensed operator identified that the required fire watch had not been established. Following the discovery, the control room staff dispatched two non-licensed operators to perform the fire watch duties until they were relieved by mechanical maintenance personnel.

Procedure EN-LI-102, Corrective Action Program, revision 45, a quality-related procedure, attachment 1, step 21, states, in part, that any condition which materially impacts the ability to implement the fire protection program including degraded fire barriers and their subcomponents (penetration seals, fire doors and dampers), and fire detection and suppression systems, be screened as an adverse condition in the corrective action program.

Procedure EN-LI-102, step 5.2.4 requires, in part, that employees and contractors are required to initiate condition reports for adverse conditions.

Based on the evidence obtained during the investigation, there was sufficient information to demonstrate that a licensed operator deliberately failed to write a condition report for not establishing a required fire watch. The licensed operator knew that no condition report had been written by any other licensee employee, and the licensed operator knew that the failure to write a condition report was contrary to licensee policy and NRC regulations.

U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:

05000416 License Number:

NPF-29 Report Number:

05000416/2023001 Enterprise Identifier:

I-2023-001-0011 Licensee:

Entergy Operations, Inc.

Facility:

Grand Gulf Nuclear Station Location:

Port Gibson, MS Inspection Dates:

January 1 to March 31, 2023 Inspectors:

N. Greene, Senior Health Physicist S. Hedger, Senior Emergency Preparedness Inspector W. Schaup, Senior Project Engineer E. Simpson, Health Physicist A. Smallwood, Resident Inspector T. Steadham, Senior 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. Licensee-identified non-cited violations are documented in report sections: 71111.24 and 7115

List of Findings and Violations

Failure to Initiate a Condition Report for a Condition Adverse to Quality Cornerstone Significance/Severity Cross-Cutting Aspect Report Section Mitigating Systems Severity Level IV NOV 05000416/2023001-01 Open EA-22-115 None 71111.05 The inspectors identified a Severity Level IV violation of 10 CFR Part 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings, for the failure to follow station Procedure EN-LI-102, Corrective Action Program, that requires all employees and contractors to initiate condition reports for adverse conditions. Specifically, after determining a required fire watch was not posted, an adverse condition, a licensed operator failed to promptly document the condition in a condition report.

Failure to Control Transient Combustibles in the Auxiliary Building Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000416/2023001-02 Open/Closed

[H.1] -

Resources 71111.18 The inspectors identified four examples of a Green finding and non-cited violation of License Condition 2.C(41), Fire Protection Program, for the licensees failure to implement all provisions of the approved fire protection program described in the NRC Safety Evaluation dated September 29, 2006, related to License Amendment 170 to operating license NPF-29.

Specifically, the licensee failed to store transient combustible materials in the auxiliary building as required by the safety evaluation.

Failure to Adequately Verify Design Change Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000416/2023001-03 Open/Closed None 71153 A self-revealed Green finding was identified for the licensees failure to perform appropriate design verifications of an engineering change associated with the feedwater heater level control valves. As a result, the system response of a condensate booster pump trip was not adequately analyzed which contributed to a loss of feedwater event and plant scram when a condensate booster pump tripped on December 19, 2022. This event was reported as Licensee Event Report 05000416/2022-003-00.

Failure to Submit a Licensee Event Report Within 60 Days Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000416/2023001-04 Open/Closed Not Applicable 71153 The inspectors identified two examples of a Severity Level IV non-cited violation of 10 CFR 50.73(a), Licensee Event Report System, for the licensees failure to submit two licensee event reports within 60 days after discovery of the event. Specifically, the licensee determined on November 4, 2021, that an issue associated with jet pump summer miscalibration resulted in multiple cases of operation in a condition prohibited by technical specification 3.2.2 and the licensee event report was submitted 76 days later, on January 19, 2022. Additionally, the licensee determined on December 2, 2021, that an issue associated with oscillation power range monitors was a reportable event and the licensee event report was submitted 62 days later on February 2, 2022.

Failure to Evaluate a Deviation for 10 CFR Part 21 Applicability Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000416/2023001-05 Open/Closed EA-22-104 Not Applicable 71153 The inspectors identified a Severity Level IV non-cited violation of 10 CFR 21.21(a)(1) for the licensees failure to evaluate a deviation in a basic component within 60 days of discovery. As a result, the licensee failed to evaluate a deviation identified on April 21, 2021, that was associated with a reportable defect that could have created a substantial safety hazard were it to have remained uncorrected within 60 days of discovery. The licensee completed the evaluation on August 10, 2022, and determined that the deviation was associated with a substantial safety hazard and was required to be reported under 10 CFR Part 21.

Failure to Make a Timely 10 CFR Part 21 Report Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NOV 05000416/2023001-06 Open EA-22-104 Not Applicable 71153 The inspectors identified a Severity Level IV violation of 10 CFR 21.21(a)(3) and 10 CFR 21.21(d) for the licensees failure to make a 10 CFR Part 21 report within the required time limits specified in 10 CFR Part 21. Specifically, the licensee notified the responsible officer 55 working days after making the determination that a substantial safety hazard existed (50 working days late) and the report was made three calendar days after the responsible officer was notified (one day late).

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000416/2021-001-01 Primary Containment Outer Airlock Door Inoperable Due to Unacceptable Leak Rate 71153 Closed LER 05000416/2021-004-00 Procedure Inadequacy Resulted in Core Monitoring System Miscalibration and Violation of Technical Specification 71153 Closed LER 05000416/2021-005-00 Oscillation Power Range Monitors (OPRMs) Setpoint Error Causes Technical Specification Noncompliance 71153 Closed LER 05000416/2022-001-00 Manual Reactor Trip Due to the Loss of Balance of Plant Transformer 23 71153 Closed LER 05000416/2022-003-00 Manual Reactor SCRAM due to a Loss of the Condensate and Feed Water System 71153 Closed

PLANT STATUS

Grand Gulf Nuclear Station, Unit 1, began the inspection period at 100 percent rated thermal power (RTP). On March 31, 2023, operators reduced power to 67 percent RTP for a control rod sequence exchange where it remained at or near 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.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1)residual heat removal train B on January 12, 2023 (2)low pressure core spray while residual heat removal B was out of service on January 18, 2023 (3)division 1 standby service water on March 1, 2023 (4)residual heat removal train A on March 17, 2023

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the division 2 standby diesel generator system on March 29, 2023.

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)low pressure core spray pump room on January 10, 2023 (2)auxiliary building, 139-foot elevation, fire area 1A316, on January 12, 2023 (3)containment, all elevations, on January 19, 2023 (4)division 1 control room ventilation room on February 2, 2023 (5)switchgear rooms 1A208 and 1A207 auxiliary building, 119-foot elevation, on February 9, 2023 (6)auxiliary building hallways, 93-foot, 103-foot, 139-foot, and 166-foot elevations, on February 10, 2023 (7)residual heat removal A pump room on March 9, 2023 (8)division 2 standby diesel generator on March 16, 2023

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire brigade drill response to a simulated fire in the control building, 189-foot elevation, on January 25, 2023.

71111.06 - Flood Protection Measures

Flooding Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated internal flooding mitigation protections in the auxiliary building, 93-foot elevation, high pressure core spray, low pressure core spray, and residual heat removal C pump rooms on January 10, 2023.

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 a downpower for rod sequence exchange on March 31, 2023.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a licensed operator training evolution in the simulator on February 6, 2023.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1)work order 593088, engineered safety feature transformer 11 relay replacement on March 27, 2023

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)work order 590923, replace two cards for the division 2 load shedder and sequencing panel on February 9, 2023

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 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 lineup while residual heat removal B was out of service on January 10, 2023 (2)protected system lineup while residual heat removal A was out of service on January 20, 2023 (3)emergent work control due to reactor core isolation cooling system unavailability on January 27, 2023 (4)maintenance risk assessment during division 2 work week on February 2, 2023 (5)risk management actions for transformer 23 underground power cable connections on March 27, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1)condition report CR-GGN-2022-00296, potential moisture intrusion in reactor core isolation cooling oil system on January 26, 2023 (2)condition report CR-GGN-2023-00633, reactor core isolation cooling trip throttle valve failure to open on February 3, 2023 (3)condition report CR-GGN-2023-00721, material nonconformance for control rod drive mechanism cap screws on February 7, 2023 (4)condition report CR-GGN-2023-00478, division 2 load shedding and sequencer failure on February 9, 2023 (5)condition report CR-GGN-2023-00562, non-conservative moment of inertia for recirculation pump on March 13, 2023 (6)condition report CR-GGN-2023-01532, snubber misaligned on March 14, 2023

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)revision to Procedure EN-DC-161, "Control of Combustibles," on March 14, 2023

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (5 Samples)

(1)work order 590923, division 2 load shedding and sequencer panel functional test on January 25, 2023 (2)work order 591227, failed light socket for reactor core isolation cooling trip/throttle valve position indicating lamp on February 10, 2023 (3)work order 559947-01, disassemble and inspect actuator on March 8, 2023 (4)work order 591510, control room air-conditioner train B power supply replacement on March 24, 2023 (5)work order 52916166, clean, inspect, and lubricate air handling equipment on March 31, 2023

Surveillance Testing (IP Section 03.01) (3 Samples)

(1)work order 53022722, anticipated transient without scram reactor vessel high pressure channel A on February 15, 2023 (2)work order 53022735, reactor vessel water level 3 and level 8 functional test on March 8, 2023 (3)work order 423277, remove and inspect snubber 1E12G013R11 on March 13, 2023

Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1)work order 52931269, motor operated valve periodic diagnostic test of valve 1E51F010 on February 10, 2023

Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)

(1)work order 52995885 and 5295886, FLEX building 2 equipment testing on February 8, 2023

71114.01 - Exercise Evaluation

Inspection Review (IP Section 02.01-02.11) (1 Partial)

(1) The inspectors evaluated the biennial emergency plan exercise conducted on March 22, 2023. However, as of the end of the 1st Quarter 2023, the licensee had not completed its critique process for the exercise. As such, the inspectors had not completed the full evaluation of the exercise and the critique process. The inspectors will complete the inspection in the 2nd Quarter, and the results of the inspection will be documented in NRC Inspection Report 05000416/2023002.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated changes to the Emergency Action Level (EAL) Technical Bases Document, revisions 2 and 3 (effective August 2022, and January 2023, respectively). This involved review of a selection of additional licensee screening and evaluation documentation. These evaluations and reviews do not constitute NRC approval.

71114.08 - Exercise Evaluation - Scenario Review

Inspection Review (IP Section 02.01 - 02.04) (1 Sample)

(1) The inspectors reviewed the licensees preliminary exercise scenario that was submitted to the NRC on January 19, 2023 (ML23019A183), for the exercise scheduled to occur on March 22, 2023. The inspectors discussed the preliminary scenario with Mike Lewis, Manager, Emergency Preparedness, and other members of the emergency preparedness staff on February 15, 2023. The inspectors' review does not constitute NRC approval of the scenario.

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials, and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs 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) (2 Samples)

The inspectors observed and evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1)observed the licensee conduct surveys of potentially contaminated packages and equipment from the radiologically controlled area for release offsite and workers exiting potential contaminated areas (2)evaluated the licensee's physical and programmatic controls for the unconditional release of non-contaminated and non-radioactive equipment from inside the radiologically controlled area

Radiological Hazards Control and Work Coverage (IP Section 03.04) (2 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1)high risk radiological work and job coverage for floor drain centrifugal disc filter maintenance (RWP 2023-1070, Task 2 for work order 590804)

(2)high risk radiological work and job coverage to support the spent fuel pool cleanout project (RWP 2022-1313, Task 1 for work order 583982)

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 turbine building, 113-foot elevation, door 1T204

(2) Grand Gulf Nuclear Station turbine building, 110-foot elevation, door 1T207

(3) Grand Gulf Nuclear Station radwaste building, 118-foot elevation, door OR208

(4) Grand Gulf Nuclear Station radwaste building, 136-foot elevation, door OR317 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 pertains to radiation protection requirements.

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.

Internal Dosimetry (IP Section 03.03) (3 Samples)

The inspectors evaluated the following internal dose assessments:

(1)a potential intake that occurred on March 8, 2022, while cutting out piping (2)a potential intake that occurred on March 19, 2022, while removing insulation from auxiliary room steam tunnel piping (3)a potential intake that occurred on March 24, 2022, while performing nondestructive examination testing

Special Dosimetric Situations (IP Section 03.04) (3 Samples)

The inspectors evaluated the following special dosimetric situations:

(1)three examples of declared pregnant worker's dose assessment (2)effective dose equivalent for external exposure (EDEx) assessments for three workers working as divers in non-uniformed radiation fields in 2022 under RWP 2022-1531 (3)neutron dose tracking for work near the independent spent fuel storage installation pad

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, 2022, through December 31, 2022 BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)

(1) January 1, 2022, through December 31, 2022

BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)

(1) January 1, 2022, through December 31, 2022

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) January 1, 2022, through December 31, 2022 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, 2022, through December 31, 2022

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)

(1) April 1, 2022, through December 31, 2022 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)

(1) April 1, 2022, through December 31, 2022 EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)

(1) April 1, 2022, through December 31, 2022

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000416/2021-001-00, Primary Containment Outer Airlock Door Inoperable Due to Unacceptable Leak Rate (ML21137A090). The circumstances surrounding this LER and a Severity Level IV non-cited violation is documented in the Inspection Results section of this report. This LER is closed.

(2) LER 05000416/2021-004-00, Procedure Inadequacy Resulted in Core Monitoring System Miscalibration and Violation of Technical Specification (ML22019A270). The circumstances surrounding this LER and a Severity Level IV non-cited violation is documented in the Inspection Results section of this report. This LER is closed.

(3) LER 05000416/2021-005-00, Oscillation Power Range Monitors (OPRMs) Setpoint Error Causes Technical Specification Noncompliance (ML22033A065). The circumstances surrounding this LER,a Severity Level IV non-cited violation, and a licensee identified violation are documented in the Inspection Results section of this report. This LER is closed.

(4) LER 05000416/2022-001-00, Manual Reactor Trip Due to the Loss of Balance of Plant Transformer 23 (ML22241A113). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER, therefore, no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements. This LER is Closed.

(5) LER 05000416/2022-003-00, Manual Reactor SCRAM due to a Loss of the Condensate and Feed Water System (ML23047A547). The circumstances surrounding this LER and a Green finding is documented in the Inspection Results section of this report. This LER is Closed.

INSPECTION RESULTS

Failure to Initiate a Condition Report for a Condition Adverse to Quality Cornerstone Significance/Severity Cross-Cutting Aspect Report Section Mitigating Systems Severity Level IV NOV 05000416/2023001-01 Open EA-22-115 None 71111.05 The inspectors identified a Severity Level IV violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to follow station Procedure EN-LI-102, Corrective Action Program, that requires all employees and contractors to initiate condition reports for adverse conditions. Specifically, after determining a required fire watch was not posted, an adverse condition, a licensed operator failed to promptly document the condition in a condition report.

Description:

On September 15, 2021, a licensed operator serving as the work control supervisor, was asked to go to the maintenance department and locate a fire watch for the division 1 and division 2 switchgear rooms because it had been determined that a required continuous fire watch had not been posted. The control room sent two non-licensed operators (NLOs) to perform fire watch duties until personnel from the maintenance department could get to the division 1 and division 2 switchgear rooms to perform the continuous fire watch duties and relieve the NLOs.

Licensee document limiting condition for operation (LCO) 1 FTR-21-0406 indicated on the tagout instructions that a continuous fire watch was required because, once the tagout was hung, it disabled portions of the fire protection system. When those portions of the fire protection system are disabled, station procedures require establishing a continuous fire watch in that area.

Along with the work control supervisor, several control room personnel including the shift manager, control room supervisor, and the shift technical supervisor were aware that the continuous fire watch had not be established.

On December 8, 2021, the NRCs Office of Investigations (OI) initiated an investigation to determine whether the licensees actions involved a willful violation of a regulatory requirement. A factual summary of the investigation is contained in Enclosure 2.

As a result of the investigation, the NRC determined that a condition report had not been initiated to document that the licensee had failed to establish a required fire watch in accordance with station procedures until April 20, 2022, when the NRC informed the licensee that the action had not been performed. This is based upon the following:

Procedure EN-LI-102, Corrective Action Program, revision 45, a quality-related procedure, attachment 1, step 21 states, in part, that any condition which materially impacts the ability to implement the fire protection program including degraded fire barriers and their subcomponents (penetration seals, fire doors and dampers), and fire detection and suppression systems, be screened as an adverse condition in the corrective action program.

Procedure EN-LI-102, step 5.2.4 requires, in part, that employees and contractors are required to initiate condition reports for adverse conditions.

On April 20, 2022, the licensee documented the condition adverse to quality in the corrective action program as condition report CR-GGN-2022-04646.

Additionally, based on the evidence obtained during the investigation, there was sufficient information to demonstrate that a licensed operator deliberately failed to write a condition report for not establishing a required fire watch. The licensed operator knew that no condition report had been written by any other licensee employee, and the licensed operator knew that the failure to write a condition report was contrary to licensee policy and NRC regulations.

Corrective Actions: Immediate corrective actions were to establish the required fire watch. No additional corrective actions were generated after documenting the adverse condition in condition report CR-GGN-2022-04646.

Corrective Action References: This issue was entered into the licensees corrective action program as condition report CR-GGN-2022-04646

Performance Assessment:

Performance Deficiency: The NRC determined that this violation was associated with a minor performance deficiency. Licensee Procedure EN-LI-102, step 5.2.4c. requires, in part, that employees and contractors are required to initiate condition reports for adverse conditions.

Specifically, after determining a required fire watch was not posted, an adverse condition, a licensed operator failed to promptly document the condition in a condition report.

Cross-Cutting Aspect: None

Enforcement:

The ROPs significance determination process does not specifically consider willfulness in its assessment of licensee performance. Therefore, it is necessary to address this violation which involves willfulness using traditional enforcement.-.

Severity: The NRC evaluated this violation in accordance with section 2.2.1.d. and section 2.2.2 of the NRC Enforcement Policy. Because the issue involved willfulness, this violation was determined to be Severity Level IV.

Violation: 10 CFR Part 50, appendix B, criterion V requires, in part, that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings, of a type appropriate to the circumstances.

Procedure EN-LI-102, Corrective Action Program, revision 45, a quality-related procedure, attachment 1, step 21 states, in part, that any condition which materially impacts the ability to implement the fire protection program including degraded fire barriers and their subcomponents (penetration seals, fire doors and dampers), and fire detection and suppression systems, be screened as an adverse condition in the corrective action program.

Procedure EN-LI-102, step 5.2.4 requires, in part, that employees and contractors are required to initiate condition reports for adverse conditions.

Contrary to the above, from September 15, 2021, to April 20, 2022, licensed personnel failed to initiate a condition report for adverse conditions. Specifically, a licensed operator deliberately failed to write a condition report for a condition which materially impacted the ability to implement the fire protection program when a continuous fire watch was not established.

Enforcement Action: This violation is being cited because the violation was willful.

Failure to Control Transient Combustibles in the Auxiliary Building Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000416/2023001-02 Open/Closed

[H.1] -

Resources 71111.18 The inspectors identified four examples of a Green finding and non-cited violation of License Condition 2.C(41), Fire Protection Program, for the licensees failure to implement all provisions of the approved fire protection program described in the NRC Safety Evaluation dated September 29, 2006, related to License Amendment 170 to operating license NPF-29.

Specifically, the licensee failed to store transient combustible materials in the auxiliary building as required by the Safety Evaluation (SE).

Description:

On February 9th, 2023, the inspectors toured the auxiliary building 93-foot, 103-foot, 119-foot, 139-foot, and 166-foot elevations including several risk significant fire areas and combustible material exclusion zones as described in the SE dated September 29, 2006. Section 4.2.2.1.8 of the SE states, in part, that combustible storage areas are designated locations where transient combustible materials may be stored or staged, and that outside these designated storage areas transient combustibles may only be stored in sealed metal drums. Section 3.1.5 of the SE prohibits storing combustible materials on the 93-foot elevation. The inspectors observed the following examples of combustible materials that were not stored in accordance with these sections of the SE:

(Example 1) A combustible material storage permit issued on the 93-foot elevation per procedure EN-DC-161 for rubber hose contrary to section 3.1.5. The combustible material was also not stored in a sealed metal drum contrary to section 4.2.2.1.8. In addition, the combustible material storage permit had expired 9 days prior to the observation on January 31, 2023.

(Example 2) Also stored on the 93-foot elevation not in a sealed metal container were several fiberglass ladders, rubber hoses, and rolls of plastic pearl weave used for netting in a scaffolding storage area contrary to both sections 3.1.5 and 4.2.2.1.8.

(Example 3) On the 139-foot elevation, miscellaneous transient combustibles such as a cart with a wooden deck, a rubber hose, a dust mop, and plastic wet floor signs were found near door 1A310 in a safe storage area contrary to section 4.2.2.1.8. Safe storage areas are not designated combustible material storage areas per plant maintenance standard MS53. These items were not in a transient combustible material storage area, and they were not stored in sealed metal drums.

(Example 4) Additionally, sections 3.1 through 3.4 of the SE include restrictions to limit the size and location of combustible storage areas in the auxiliary building; however, the licensees transient combustible permit program did not track or otherwise restrict the size of combustible storage areas in the auxiliary building to remain in conformance with the SE.

The inspectors reported the transient combustible material to the licensee who determined that the transient combustibles were not controlled as described in the SE. The inspectors determined that the procedure used to control transient combustibles, Procedure EN-DC-161, Control of Combustibles, revision 25, did not capture the specific requirements as detailed in the SE. Specifically, none of the examples identified above were inconsistent with procedure EN-DC-161, but all four were inconsistent with the SE.

Because the licensee was unable to produce any evaluations which approved these deviations, the inspectors concluded that procedure EN-DC-161 was not appropriately controlling transient combustibles in accordance with the applicable license condition.

Corrective Actions: The licensee entered this issue into their corrective action program to review the discrepancies and revise the procedure as appropriate.

Corrective Action References: This issue was entered into the licensees corrective action program as condition reports CR-GGN-2023-00933 and CR-GGN-2023-01003

Performance Assessment:

Performance Deficiency: The licensees failure to implement procedures for the control of combustible materials in the auxiliary building in accordance with the SE dated September 29, 2006, 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 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, the performance deficiency resulted in uncontrolled combustible materials in multiple locations in the auxiliary building containing safe shutdown components for both division 1 and division 2.

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 finding involved the ability to confine a fire, the inspectors applied IMC 0609, Appendix F, Fire Protection SDP, to determine the findings significance. The inspectors determined that there were adequate fire suppression and detection systems in the auxiliary building, and therefore, they concluded that the performance deficiency was of very low safety significance (Green).

Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.

Enforcement:

Violation: License Condition 2.C(41), Fire Protection Program, states, in part, that the plant shall implement and maintain in effect all provisions of the Fire Protection Program as described in the Updated Final Safety Analysis Report (UFSAR), and as approved in the Safety Evaluation dated September 29, 2006. The safety evaluation dated September 29, 2006, states, in part, that transient combustibles may only be stored in sealed metal containers outside designated combustible storage areas. Section 3.1.5 of the safety evaluation dated September 29, 2006, prohibits combustible material storage areas on the 93-foot elevation of the auxiliary building. Section 4.2.2.1.8 of the safety evaluation dated September 29, 2006, states, in part, that processes and procedures are in place at Grand Gulf Nuclear Station to address the control of combustible loading throughout the plant.

Contrary to the above, on February 9, 2023, the licensee failed to implement and maintain in effect all provisions of the Fire Protection Program as described in the Updated Final Safety Analysis Report, and as approved in the Safety Evaluation dated September 29, 2006, as evidenced by the following four examples:

(Example 1): A combustible material storage permit was issued on the 93-foot elevation per procedure EN-DC-161 for rubber hose contrary to section 3.1.5. The combustible material was also not stored in a sealed metal drum contrary to section 4.2.2.1.8. In addition, the combustible material storage permit had expired 9 days prior to the observation on January 31, 2023.

(Example 2): Several fiberglass ladders, rubber hoses, and rolls of plastic pearl weave used for netting in a scaffolding storage area were stored on the 93-foot elevation and not in a sealed metal drum contrary to both sections 3.1.5 and 4.2.2.1.8.

(Example 3): On the 139-foot elevation, miscellaneous transient combustibles such as a cart with a wooden deck, a rubber hose, a dust mop, and plastic wet floor signs were found near door 1A310 in a safe storage area contrary to section 4.2.2.1.8. Safe storage areas are not designated combustible material storage areas per plant maintenance standard MS53. These items were not in a transient combustible material storage area, and they were not stored in sealed metal drums.

(Example 4) Sections 3.1 through 3.4 of the SE include restrictions to limit the size and location of combustible storage areas in the auxiliary building; however, the licensees transient combustible permit program did not track or otherwise restrict the size of combustible storage areas in the auxiliary building to remain in conformance with the SE.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Licensee-Identified Non-Cited Violation 71111.24 This violation of very low safety significance was identified by the licensee, has been entered into the licensee corrective action program, and is being treated as a non-cited violation consistent with Section 2.3.2 of the Enforcement Policy.

Violation: License Condition 2.C(41), Fire Protection Program, states, in part, that the plant shall implement and maintain in effect all provisions of the fire protection program as described in the UFSAR. UFSAR, section 9B.6, requires, in part, that the licensee govern the operability requirements, required actions, and surveillance requirements specified in Technical Requirements Manual, section 6.2. Technical Requirements Manual, section 6.2.4.1, required that a continuous fire watch be established within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the carbon dioxide system protecting the division 1, 2, or 3 switchgear rooms being declared non-functional.

Contrary to the above, from 11:17 a.m. on September 14, 2021, until September 15, 2021, the licensee failed to establish a continuous fire watch when the carbon dioxide system protecting the division 1, 2, or 3 switchgear rooms was declared non-functional.

Significance/Severity: The inspectors assessed the significance of the finding using Appendix F, Fire Protection Significance Determination Process. The finding represented a high degradation of a fixed fire protection system. A regional senior reactor analyst performed a Phase 2 screening using a bounding risk quantification which determined an increase in core damage frequency of 4.4E-7/year, representing very low safety significance (Green).

The finding has very low safety significance (Green) because of the short time there was not a fire watch and the low probability of a fire during that time.

Corrective Action References: This issue was entered into the licensees corrective action program as condition report CR-GGN-2022-04646 Failure to Adequately Verify Design Change Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000416/2023001-03 Open/Closed None 71153 A self-revealed Green finding was identified for the licensees failure to perform appropriate design verifications of an engineering change associated with the feedwater heater level control valves. As a result, the system response of a condensate booster pump trip was not adequately analyzed which contributed to a loss of feedwater event and plant scram when a condensate booster pump tripped on December 19, 2022. This event was reported as Licensee Event Report 05000416/2022-003-00.

Description:

On December 19, 2022, with the plant operating at 100 percent power, an electrical fault with the A condensate booster pump occurred which caused the pump to trip.

This trip caused an initial reduction in reactor water level because of an approximate 22 percent loss in total flow to the reactor feedwater pumps. In accordance with the reactor feedwater malfunction offnormal event procedure 05-1-02-V-7, operators reduced reactor recirculation flow to 70 Mlbm/hr using the fast detent option. This rapid reduction in recirculation flow exacerbated the perturbation on the feedwater system and ultimately led to the feedwater heater drain tank (HDT) level control valves closing to maintain level in the HDT. However, the combination of a load reduction and the HDT level control valves closing caused level in HDT to increase which created level oscillations that the HDT level control valves were not able to recover from.

The response of the HDT level control valves caused a reduction in the flow from the HDT to the reactor feedwater pumps because the valves were not sized appropriately to respond to a loss of condensate booster pump. The valves responded too slowly to the transient to maintain adequate suction pressure to the feedwater pumps which ultimately resulted in a trip of the A reactor feedwater pump. Further complications in the feedwater system resulted in continued lowering of feedwater flow to the reactor and a continuing lowering of reactor water level. Prior to reaching the setpoint for an automatic scram, operators manually inserted a scram and recovered from the transient without incident.

The licensee performed a root cause analysis of the cause of the feedwater transient and determined that an inadequate engineering change performed in the 2011/2012 timeframe was the root cause. Engineering change (EC) 23022 modified the HDT level control valves by replacing the existing 8-inch valves with 12-inch valves. The inspectors reviewed the design verification for this modification and determined that the licensee failed to identify that this modification could affect the design, performance, or operation of the main feedwater pumps and failed to identify valve stroke time as a critical parameter to the HDT level control valve performance. Additionally, the licensee determined that the use of the fast detent reduction in reactor recirculation flow in procedure 05-1-02-V-7 was not evaluated in design calculations that evaluated HDT response to condensate booster pump transients. Performing such an evaluation in conjunction with more thorough design verifications in EC 23022 likely would have identified the design deficiency with the replacement HDT level control valves. The inspectors concluded that this was not a procedure deficiency with procedure 05-1-02-V-7, but rather another example of the inadequate modification to the HDT level control valves.

Licensee Procedure EN-DC-115, Engineering Change Process, revision 10, step 4.2, required the design verifier to perform a thorough review of all information contained in the engineering change to ensure that the document is technically adequate, procedurally compliant, accurate, and of a quality to warrant approval and issuance. The mechanical design engineering input for EC 23022 contained various screening criteria, one of which was Affect the design, performance, or operation of pumps. Another screening criteria was Affect hydraulic requirements such as pump net positive suction head, allowable pressure drops, system curves, etc. Neither of these criteria were marked as being impacted. The inspectors determined that, based on the demonstrable effects of the valve operation from the condensate booster pump trip, the HDP level control valve modification affected both criteria and was required to be evaluated by procedure EN-DC-115, but was not evaluated.

The licensee reported this event as Licensee Event Report 05000416/2022-003-00 on February 16, 2023.

Corrective Actions: Licensee corrective actions included replacing the failed condensate booster pump motor, implementing risk management actions to reduce the potential for another condensate booster pump transient, and evaluating long term corrective actions including modifications to the system.

Corrective Action References: This issue was entered into the licensees corrective action program as condition report CR-GGN-2022-11392.

Performance Assessment:

Performance Deficiency: The failure to perform a thorough review of all information contained in the engineering change to ensure that the document was technically adequate, procedurally compliant, accurate, and of a quality to warrant approval and issuance was contrary to licensee procedure EN-DC-115 and was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control 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 caused a reactor scram.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The SDP for Findings At-Power, exhibit 1. Because operators were able to recover feedwater, the inspectors determined that the finding did not cause the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. Consequently, the inspectors answered no to the transient initiators screening question and the finding screened to a Green significance.

Cross-Cutting Aspect: None. Because the finding was the result of deficiencies that occurred approximately 11 years prior to the event, a cross-cutting aspect is not applicable.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

Failure to Submit a Licensee Event Report Within 60 Days Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000416/2023001-04 Open/Closed Not Applicable 71153 The inspectors identified two examples of a Severity Level IV non-cited violation of 10 CFR 50.73(a), Licensee Event Report System, for the licensees failure to submit two licensee event reports within 60 days after discovery of the event. Specifically, the licensee determined on November 4, 2021, that an issue associated with jet pump summer miscalibration resulted in multiple cases of operation in a condition prohibited by technical specification 3.2.2 and the licensee event report was submitted 76 days later, on January 19, 2022. Additionally, the licensee determined on December 2, 2021, that an issue associated with oscillation power range monitors was a reportable event and the licensee event report was submitted 62 days later on February 2, 2022.

Description:

First Example: Licensee Event Report (LER) 2021-004-00 As described in Inspection Report 05000416/2021003 (ML21312A172), the inspectors identified a non-cited violation related to the licensees failure to identify a condition adverse to quality associated with the jet pump flow indications. As a result, the licensee entered the issue into the corrective action program as condition report CR-GGN-2021-05802. As part of its evaluation, the licensee performed a past operability evaluation and ultimately reported the issue as LER 2021-004-00, Procedure Inadequacy Resulted in Core Monitoring System Miscalibration and Violation of Technical Specifications, (ML22019A270) on January 19, 2022.

On November 4, 2021, the licensee concluded in the past operability evaluation that there were 1677 instances in the past 3 years where the plant was operating in a condition prohibited by technical specification (TS) LCO 3.2.2. LCO 3.2.2 required that all minimum critical power ratios (MCPR) shall be greater than or equal to the MCPR operating limits specified in the core operating limit report. Condition A of this LCO required that for any MCPR not within limits to restore MCPR(s) to within limits within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Condition B required that if the required action of condition A was not met to reduce thermal power to less than 21.8 percent RTP. For the 1677 cases identified, the licensee determined that MCPR was not within limits for greater than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> while reactor power was greater than 21.8 percent RTP.

On November 8, 2021, the licensee initiated a corrective action to condition report CR-GGN-2021-05802 to revise the past operability evaluation to update the core monitoring cases used in the thermal limit evaluation to exclude those ran during a transient and re-evaluate the results. The licensee concluded the revised evaluation on November 18, 2021, and eliminated two of the 1677 cases. In discussions with engineering, the inspectors learned that the purpose of the revised evaluation was only to determine the correct number of cases where the TSs were violated. Engineering never had any doubt that the fundamental conclusion that the TSs were violated would not change because the vast majority of the already identified cases were during steady state operations and would not have been affected by the revision.

Because the revised evaluation essentially confirmed the results of the original evaluation and only sought to finalize the most accurate number of cases where the TSs were violated, the inspectors concluded that the engineers who performed, checked, and approved the past operability evaluation discovered the reportable condition on November 4, 2021. On November 23, 2021, the licensee concluded that the identified condition prohibited by TS 3.2.2 was a reportable condition. The licensee set a due date to submit the LER within 60 days of their determining that the condition was reportable rather than 60 days from the date that the reportable condition was identified. Consequently, LER 2021-004-00 was submitted 76 days after the condition was identified (November 4, 2021).

Licensee Procedure EN-LI-108, Event Notification and Reporting, revision 19, defines time of discovery as the moment a condition is identified by anyone working at or for the facility.

This applies when dealing with Reportability. In the LER, the licensee stated that, On November 18, 2021, a past operability evaluation determined that an issue associated with the jet pump summer miscalibration was a reportable event. The inspectors determined that because the licensee originally discovered the reportable condition on November 4, 2021, and at no point during the revision process did the licensee ever have a reasonable belief that the conclusion that the plant operated in a condition prohibited by TSs would change.

The inspectors reviewed the applicable TS, the licensees documents related to the discovery such as the past operability evaluation and condition report CR-GGN-2021-05802, and the circumstances surrounding the discovery of the failure to meet TS 3.2.2, and determined that:

TS 3.2.2 was not administrative in nature;

the event was not a case of a late surveillance test where the oversight was corrected, the test was performed, and the equipment was found to be capable of performing its specified safety functions; and

TS 3.2.2 was not revised prior to discovery of the event such that the operation or condition was no longer prohibited at the time of discovery of the event.

The inspectors concluded that the underlying misunderstanding of what the date of discovery is for past operability evaluations directly led to the failure to report the event within 60 days as required by 10 CFR 50.73.

Second Example: LER 2021-005-00 As documented in this inspection report, the licensee identified on June 21, 2021, that they failed to update the detect and suppress solution - confirmation density settings for the oscillation power range monitors. In consultation with the vendor, the licensee performed a past operability evaluation as documented in condition report CR-GGN-2021-04781. On December 2, 2021, the licensee finished the past operability evaluation and determined that the failure to update this setting resulted in operation in a condition prohibited by TSs.

On December 6, 2021, the licensee reviewed the past operability evaluation and concluded that the condition was reportable as an LER due to violating TS 3.3.1.1. Similar to LER 2021-004-00, the licensee assigned a due date to submit the LER within 60 days of their determining that the condition was reportable rather than 60 days from the date that the reportable condition was identified. On February 2, 2022, the licensee submitted LER 2021-005-00, Oscillation Power Range Monitors Technical Specification Noncompliance. The inspectors concluded that this LER was submitted 62 days after the condition was identified on December 2, 2021.

The inspectors reviewed the applicable TS, the licensees documents related to the discovery such as the past operability evaluation and condition report CR-GGN-2021-04781, and the circumstances surrounding the discovery of the failure to meet TS 3.3.1.1, and determined that:

TS 3.3.1.1 was not administrative in nature;

the event was not a case of a late surveillance test where the oversight was corrected, the test was performed, and the equipment was found to be capable of performing its specified safety functions; and

TS 3.3.1.1 was not revised prior to discovery of the event such that the operation or condition was no longer prohibited at the time of discovery of the event.

During discussions with licensee management about these issues the inspectors determined that the licensee had a misunderstanding of what the correct time of discovery was for conditions such as these where a past operability evaluation had determined that a violation of Technical Specifications had occurred. Licensee management believed that the time of discovery for reporting timelines started when regulatory affairs determined that the issue was reportable - not when the past operability evaluation concluded that the plant had operated in a condition prohibited by Technical Specifications. The inspectors determined that the licensees understanding was contrary to both licensee procedure EN-LI-108 and 10 CFR 50.73(a)(1), and that this misunderstanding would likely have continued without NRC interaction.

The inspectors did not identify any additional violations as a result of these LER reviews. Both LERs are closed.

Corrective Actions: The licensee entered the late reporting concern into the corrective action program to correct the causes that led to the late reports.

Corrective Action References: This issue was entered into the licensees corrective action program as condition report CR-GGN-2023-00700

Performance Assessment:

The inspectors determined this violation was associated with a minor performance deficiency. Specifically, the licensee failed to timely submit two LERs, contrary to licensee procedure EN-LI-108. This performance deficiency was minor because the inspectors answered No to all three screening questions in appendix B of IMC 0612.

Enforcement:

The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation using traditional enforcement.

Severity: The NRC determined this violation was Severity Level IV in accordance with example 6.9.d.9 of the NRC Enforcement Policy because the licensee failed to submit an LER in accordance with 10 CFR 50.73.

Violation: Title 10 CFR 50.73(a)(1) requires, in part, that a licensee shall submit an LER for any event of the type described in this paragraph within 60 days after the discovery of the event.

Title 10 CFR 50.73(a)(2) requires, in part, that the licensee shall report any operation or condition which was prohibited by the plants TSs except as allowed by 10 CFR 50.73(a)(2)(i)(B)(1), 10 CFR 50.73(a)(2)(i)(B)(2), or 10 CFR 50.73(a)(2)(i)(B)(3).

Contrary to the above:

1. On January 4, 2022, the licensee failed to submit LER 2021-004-00 for a condition

which was prohibited by the plants TSs within 60 days after the discovery of the event and the condition was not an exception as allowed by either 10 CFR 50.73(a)(2)(i)(B)(1), 10 CFR 50.73(a)(2)(i)(B)(2), or 10 CFR 50.73(a)(2)(i)(B)(3).

2. On February 1, 2022, the licensee failed to submit LER 2021-005-00 for a condition

which was prohibited by the plants TSs within 60 days after the discovery of the event and the condition was not an exception as allowed by either 10 CFR 50.73(a)(2)(i)(B)(1), 10 CFR 50.73(a)(2)(i)(B)(2), or 10 CFR 50.73(a)(2)(i)(B)(3).

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Failure to Evaluate a Deviation for 10 CFR Part 21 (Part 21) Applicability Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000416/2023001-05 Open/Closed EA-22-104 Not Applicable 71153 The inspectors identified a Severity Level IV non-cited violation of 10 CFR 21.21(a)(1) for the licensees failure to evaluate a deviation in a basic component within 60 days of discovery. As a result, the licensee failed to evaluate a deviation identified on April 21, 2021, that was associated with a reportable defect that could have created a substantial safety hazard were it to have remained uncorrected within 60 days of discovery. The licensee completed the evaluation on August 3, 2022, and determined that the deviation was associated with a substantial safety hazard and was required to be reported under Part 21.

Description:

On February 22, 2021, during a local leak rate test for the 208-foot containment personnel airlock outer door under work order (WO) 52884887-11, the as-found leak test exceeded TS surveillance requirement 3.6.1.2.1 limit of 16,880 SCCM. Because the licensee was not able to stabilize at test pressure due to the capability of the test equipment, an exact leakage rate could not be obtained. The equalizing valve on the outer door 1M23F018D was identified to be leaking and was replaced under WO 558041-01. The issue was entered into the corrective action program as condition report CR-GGN-2021-01451.

After replacing the equalizing valve on the outer door, the licensee discovered that the equalizing valve on the inner door 1M23F018C was also leaking. The reported leak rate of 9000 SCCM was above the Appendix J administrative limit of 944 SCCM. Inner door 1M23F018C was rebuilt with new O-rings and was lubricated prior to reinstallation into the airlock. Following door 1M23F018D replacement and door 1M23F018C rebuild, the local leak rate test tested with satisfactory results.

On April 21, 2021, the licensee determined that the cause of excessive leakage for both doors 1M23F018C and D was the failure to lubricate the valves prior to installation which caused premature O-ring failure. Additionally, with the inner door opened, the leakage rate would have exceeded TS requirements. Consequently, the licensee submitted LER 05000416/2021-001-00 on May 14, 2021.

The valves were purchased on February 7, 2018, as basic components under purchase order 10537921. The procurement documents required the valves to be furnished in accordance with the vendors commercial grade dedication plan CGI-013. This dedication plan required the vendor to disassemble the valves, replace the O-rings with dedicated O-rings, lubricate the stem and O-rings, reassemble the valves, and perform final acceptance testing before shipping the valves as basic components. However, the licensee determined that neither valve was lubricated when they were installed and developed corrective actions to revise the preventive maintenance instructions to ensure replacement valves are lubricated prior to installation.

The inspectors determined that the licensee did not recognize that a deviation or failure to comply potentially associated with a substantial safety hazard existed, and therefore, did not evaluate the lack of lubrication as such. Licensee Procedure EN-LI-108-01, 10 CFR 21 Evaluations and Reporting, revision 13, required the issue to be screened for Part 21 reportability.

The licensee entered the inspectors concerns into their corrective action program, performed an evaluation, determined that the issue was a reportable Part 21 event on August 3, 2022, and made the initial notification on October 31, 2022.

The inspectors determined that the pertinent reporting criteria as required by 10 CFR 21.21(d)(4) was not provided in LER 05000416/2021-001-00, and therefore, the licensee did not meet the reporting requirement exclusion as provided by 10 CFR 21.21(d)(2).

Specifically, the licensee failed to provide the following information in their LER describing the valve failure:

identification of the basic component which failed to comply or contained a defect

identification of the firm supplying the basic component which failed to comply or contained a defect

nature of the defect or failure to comply and the safety hazard which was created or could be created by such defect or failure to comply

the date on which the information of such defect or failure to comply was obtained

any advice related to the defect or failure to comply about the basic component that has been, is being, or will be given to purchasers or licensees The inspectors reviewed the receipt inspection, certificate of conformance, and other procurement documents and determined that the cause of the valve failure to meet TS surveillance requirement 3.6.1.2.1 was not reasonably foreseeable by the licensee; therefore, no performance deficiency related to the TS violation was identified. Additionally, traditional enforcement related to the TS violation does not apply. This LER is closed.

Corrective Actions: The licensee reported the equalizing valve failure as a Part 21 notification on October 31, 2022, and provided training on Part 21 requirements to applicable staff.

Corrective Action References: This issue was entered into the licensees corrective action program as condition reports CR-GGN-2022-07146 and CR-GGN-2022-09773.

Performance Assessment:

The inspectors determined this violation was associated with a minor performance deficiency. Specifically, the failure to evaluate a deviation in a basic component for 10 CFR Part 21 reportability was contrary to licensee procedure EN-LI-108-01 and was a performance deficiency. This performance deficiency was minor because the inspectors answered No to all three screening questions in appendix B of IMC 0612. No performance deficiency was identified for the failure to meet TS surveillance requirement 3.6.1.2.1.

Enforcement:

The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation using traditional enforcement.

Severity: The NRC determined that this violation initially screens as Severity Level III in accordance with section 6.9.c.5 of the NRC Enforcement Policy. However, in reviewing the specific circumstances of this violation (i.e., the NRC resident staff was aware of the issue, and there was little to no impact to the inspection process/regulatory process; the impact to overall containment leakage is mitigated by the size of the valves; your staff entered the issue into the corrective action program and issued a licensee event report after they concluded it was reportable under 10 CFR 50.73; and the valves were only supplied to the Grand Gulf Nuclear Station and no other licensees) the NRC determined that it is more appropriately categorized as a Severity Level IV violation.

Title 10 CFR 21.21(a)(1) requires, in part, that entities subject to the regulations in 10 CFR Part 21 shall evaluate deviations and failures to comply to identify defects associated with substantial safety hazards as soon as practicable and, except as provided in 10 CFR 21.21(a)(2), in all cases within 60 days of discovery, in order to identify a reportable defect that could create a substantial safety hazard, were it to remain uncorrected.

Contrary to the above, from June 21, 2021, to August 3, 2022, the licensee failed to evaluate deviations and failures to comply to identify defects associated with substantial safety hazards as soon as practicable and in all cases within 60 days of discovery, in order to identify a reportable defect that could create a substantial safety hazard, were it to remain uncorrected. Specifically, on April 21, 2021, the licensee identified that the lack of lubrication on the containment personnel airlock equalizing valves caused the excessive leakage and failed to identify, within 60 days, that it as a substantial safety hazard. The licensee evaluated the condition as a substantial safety hazard on August 3, 2022.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Failure to Make a Timely Part 21 Report Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NOV 05000416/2023001-06 Open EA-22-104 Not Applicable 71153 The inspectors identified a Severity Level IV violation of 10 CFR 21.21(a)(3) and 10 CFR 21.21(d) for the licensees failure to make a Part 21 report within the required time limits specified in Part 21. Specifically, the licensee notified the responsible officer 55 working days after making the determination that a substantial safety hazard existed (50 working days late) and the report was made 3 calendar days after the responsible officer was notified (1 day late).

Description:

On August 3, 2022, the licensee completed an evaluation of the deviation identified with door 1M23F018C and D, as discussed previously in this inspection report, and determined that the reportable defect could create a substantial safety hazard were it to remain uncorrected.

On October 6, 2022, the inspectors questioned the licensee on the Part 21 report because it had not yet been made, and the inspectors discussed with the licensee the reporting timelines contained in 10 CFR Part 21(a)(3) and 10 CFR Part 21(d)(3). The inspectors determined that the licensees procedure for performing Part 21 reviews, procedure EN-LI-108-01, revision 14, contained reporting time requirements that were consistent with these two requirements. The inspectors were concerned that a Part 21 notification had not been made despite the site having determined several weeks prior that a reportable defect existed.

On October 14, 2022, the licensee wrote condition report CR-GGN-2022-09773 to document that the station concluded that a Part 21 notification was necessary but had not performed the follow-up steps in the proper timeframe. The licensee informed the site vice president on October 28, 2022, and made the initial Part 21 notification of a reportable defect on October 31, 2022.

Corrective Actions: The licensee reported the equalizing valve failure as a Part 21 notification on October 31, 2022, and provided training on Part 21 requirements to applicable staff.

Corrective Action References: This issue was entered into the licensees corrective action program as condition reports CR-GGN-2022-09773 and CR-GGN-2022-10127.

Performance Assessment:

The inspectors determined this violation was associated with a minor performance deficiency. Specifically, the failure to make a timely Part 21 report was contrary to licensee procedure EN-LI-108-01 and was a performance deficiency. This performance deficiency was minor because the inspectors answered No to all three screening questions in appendix B of IMC 0612.

Enforcement:

The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation using traditional enforcement.

Severity: The NRC determined this violation was Severity Level IV in accordance with example 6.9.d.13 of the NRC Enforcement Policy because the licensee failed to implement adequate 10 CFR Part 21 processes or procedures. Specifically, the licensee failed to ensure that adequate process controls were in place to ensure that the required timelines associated with the discovery of a defect associated with a substantial safety hazard were met.

Title 10 CFR 21.21(a)(3) requires, in part, that entities subject to the regulations in 10 CFR Part 21 shall ensure that a director or responsible officer is informed as soon as practicable, and, in all cases, within the 5 working days after completion of the evaluation described in 10 CFR 21.21(a)(1).

Title 10 CFR 21.21(d) requires, in part, that a director or responsible officer must notify the Commission when he or she obtains information reasonably indicating a failure to comply or a defect within two days following receipt of the information.

Contrary to the above, from August 13, 2022, to October 31, 2022, the licensee failed to notify the Commission after the discovery of a defect associated with a substantial safety hazard evaluation described in 10 CFR 21.21(a)(1). Specifically, the licensee identified that the lack of lubrication on the containment personnel airlock equalizing valves caused the excessive leakage and evaluated the condition as a substantial safety hazard on August 3, 2022, but failed to make the timeliness requirements to notify the Commission.

Enforcement Action: This violation is being cited because the licensee failed to restore compliance within a reasonable period of time after the violation was identified consistent with section 2.3.2 of the Enforcement Policy.

Licensee-Identified Non-Cited Violation 71153 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: The licensee identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, when they identified the failure to adequately update the oscillation power range monitor (OPRM) settings in both 2016 and 2019 which ultimately led to a reportable event.

Title 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that conditions adverse to quality shall be promptly identified and corrected.

Contrary to the above, from June 23, 2018, until June 23, 2021, the licensee failed to promptly identify and correct a condition adverse to quality. Specifically, with the OPRM DSS-CD Tmax set to 3.5 seconds, the ability of the OPRMs to perform their intended safety function was impacted until the setting was changed to 4.0 seconds on June 23, 2021. This failure directly led to the failure to meet TS 3.3.1.1 for the affected function and the subsequent TS noncompliance. Therefore, a separate TS 3.3.1.1 violation is not warranted.

This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy. As discussed in this inspection report, one additional violation for the failure to make a timely report was identified as a result of this LER review. This LER is closed.

Significance/Severity: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power, exhibit 2

- Mitigating Systems Screening Questions. The finding screened to Green because it only affected the OPRM RPS trip signal and did not affect the function of other redundant trips or diverse methods of reactor shutdown.

Corrective Action References: This issue was entered into the licensees corrective action program as condition reports CR-GGN-2021-04781 and CR-GGN-2021-06434

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On February 15, 2023, the inspectors presented the emergency preparedness exercise scenario review inspection results to Mike Lewis, Manager, Emergency Preparedness and other members of the licensee staff.

On March 2, 2023, the inspectors presented the occupational radiation safety inspection results to Jason Richardson, Acting General Manager of Plant Operations, and other members of the licensee staff.

On April 6, 2023, the inspectors presented the integrated inspection results to Brad Kapellas, Site Vice President, and other members of the licensee staff.

On April 11, 2023, the inspectors presented the emergency preparedness performance indicator verification and emergency plan change review inspection results to Brad Kapellas, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.04

Corrective Action

Documents

CR-GGN-

21-03871, 2022-01616, 2022-01772, 2022-05220, 2022-

10380, 2022-10931, 2023-00582, 2023-01532

71111.04

Procedures

04-1-01-P75-1

Standby Diesel Generator System

118

71111.04

Procedures

06-ME-1000-V-0001

Snubber Visual Inspection

108

71111.04

Work Orders

WO 23277

71111.05

Corrective Action

Documents

CR-GGN-

23-00520

71111.05

Procedures

06-OP-SP64-R-0049

Fire Rated Sealed Penetrations Visual Inspection

113

71111.05

Procedures

EN-DC-161

Control of Combustibles

71111.05

Procedures

GGNS-MS-53

Control of Transient Combustible Material Exclusion and

Storage Areas

71111.12

Miscellaneous

Receipt Inspection for PO 009900002

71111.12

Miscellaneous

009900002

Purchase Order

71111.12

Work Orders

WO 590923, 593088

71111.13

Corrective Action

Documents

CR-GGN-

23-00633, 2023-00634, 2023-00636, 2023-00637, 2023-

00639, 2023-00640

71111.15

Calculations

MC-Q1B33-92005

71111.15

Corrective Action

Documents

CR-GGN-

23-00478, 2023-00484, 2023-00562, 2023-00582, 2023-

00633, 2023-00721, 2023-01532

71111.15

Drawings

Q1E12G03R11

Pipe Support Drawing

71111.15

Miscellaneous

GGNS-NE-12-00025

Engineering Report

71111.18

Miscellaneous

PR-PRHQN-2021-

00383

71111.18

Procedures

EN-DC-161

Control of Combustibles

24, 25

71111.24

Corrective Action

Documents

CR-GGN-

21-01355, 2022-00634, 2022-00636, 2022-00637, 2022-

04646, 2023-00582, 2023-00633, 2023-00892

71111.24

Miscellaneous

FTR-21-0406

71111.24

Work Orders

WO 23277, 559947-01, 590923, 591227, 591510, 52916166,

2931269, 53022735

71114.01

Corrective Action

Documents

CR-GGN-

21-02198, 2022-02299, 2022-06688, 2022-06763, 2022-

06842, 2022-08537, 2022-08538, 2023-00218, 2023-01253,

23-01264, 2023-01270

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71114.01

Miscellaneous

2/22/2023 Dress Rehearsal Report

03/21/2023

71114.01

Procedures

10-S-01-12

Radiological Assessment and Protective Action

Recommendations

71114.01

Procedures

10-S-01-14

Emergency Radiological Monitoring

71114.01

Procedures

10-S-01-17

Emergency Personnel Exposure Control

71114.01

Procedures

10-S-01-34

Joint Information Center (JIC) Operations

71114.01

Procedures

10-S-01-6

Notification of Offsite Agencies and Plant On-Call

Emergency Personnel

71114.01

Procedures

EN-EP-313

Offsite Dose Assessment using the Unified RASCAL

Interface

71114.01

Procedures

EN-EP-609

Emergency Operations Facility (EOF) Operations

71114.01

Procedures

EN-EP-801

Emergency Response Organization

71114.04

Miscellaneous

CFR 50.54(q)(3)

Evaluation,

Procedure/Document

Number: EAL

Technical Bases and

Charts, Revision: 2

Facility: GGNS, Title: GGNS EAL Technical Bases and

Charts

08/15/2022

71114.04

Miscellaneous

CFR 50.54(q)(3)

Screening,

Procedure/Document

Number: EAL

Technical Bases and

Charts, Revision: 2

Facility: GGNS, Title: GGNS EAL Technical Bases and

Charts

08/15/2022

71114.04

Miscellaneous

CFR 50.54(q)(3)

Screening,

Procedure/Document

Number: EAL

Technical Bases and

Charts, Revision: 3

Facility: GGNS, Title: GGNS EAL Technical Bases and

Charts

2/07/2022

71114.04

Miscellaneous

CFR 50.54(q)(3)

Screening,

Procedure/Document

Number: EAL

Facility: GGNS, Title: GGNS EAL Technical Basis

2/07/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Technical Basis,

Revision: 3

71114.04

Miscellaneous

GNRO2022-00011

Grand Gulf Nuclear Station, Unit 1; Emergency Action Level

(EAL) Technical Basis Document, Revision 2

09/08/2022

71114.04

Miscellaneous

GNRO2023-00002

Grand Gulf Nuclear Station, Unit 1; Emergency Action Level

(EAL) Technical Bases Document Revision 3; Grand Gulf

Nuclear Station, Unit 1; Docket No. 50-416, License No.

NPF-29

2/01/2023

71114.04

Procedures

05-S-01-EP-4M1-3

Auxiliary Building Control/Radioactive Release Control

Modes 1-3

71114.04

Procedures

05-S-01-SAP-1M1-4

Severe Accident Procedure, RPV Control Modes 1-4

71114.04

Procedures

05-S-01-SAP-1M5

Severe Accident Procedure, RPV Control Mode 5

71114.04

Procedures

05-S-01-SAP-2M1-4

Severe Accident Procedure, Containment and Radioactive

Release Control Modes 1-4

71114.04

Procedures

05-S-01-SAP-2M5

Severe Accident Procedure, Containment and Radioactive

Release Control Mode 5

71114.04

Procedures

EN-EP-305

Emergency Planning 10CFR50.54(q) Review Program

71114.08

Miscellaneous

GIN 2021-00062

Grand Gulf Nuclear Station, EAL Technical Bases

71114.08

Miscellaneous

GNRO-2015/00057

Grand Gulf Nuclear Station Hostile Action Based Exercise

Scenario; Grand Gulf Nuclear Station, Unit 1; Docket No.

50-416; License No. NPF-29

08/14/2015

71114.08

Miscellaneous

GNRO/2018-00061

2019 Emergency Plan Full Participation Exercise Drill

Scenario; Grand Gulf Nuclear Station - Unit 1; Docket

No. 50-416; License No. NPF-29

01/08/2019

71114.08

Miscellaneous

GNRO2021/00001

Grand Gulf Nuclear Station 2021 Graded Exercise Scenario;

Grand Gulf Nuclear Station, Unit 1; Docket No. 50-416;

License No. NPF-29

01/14/2021

71114.08

Miscellaneous

GNRO2023-00001

Grand Gulf Nuclear Station 2023 Graded Exercise Scenario;

Grand Gulf Nuclear Station, Unit 1; Docket No. 50-416;

License No. NPF-29

01/19/2023

71114.08

Procedures

10-S-01-12

Radiological Assessment and Protective Action

Recommendations

71124.01

Corrective Action

Documents

CR-GGN-

22-02014, 2022-02368, 2022-02412, 2022-02794, 2022-

2802, 2022-03067, 2022-03269, 2022-04863, 2022-06893,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

22-06942, 2022-06943, 2022-07332, 2022-07727, 2022-

07743, 2022-08255, 2022-11356, 2022-20413

71124.01

Corrective Action

Documents

Resulting from

Inspection

CR-GGN-

23-01296, 2023-01364, 2023-01371, 2023-01372

71124.01

Procedures

EN-RP-100

Radiation Worker Expectations

71124.01

Procedures

EN-RP-101

Access Control for Radiologically Controlled Areas

71124.01

Procedures

EN-RP-108

Radiation Protection Posting

71124.01

Procedures

EN-RP-121

Radioactive Material Control

71124.01

Procedures

EN-RP-152

Conduct of Radiation Protection

71124.01

Procedures

EN-RP-210

Area Monitoring Program

71124.01

Radiation

Surveys

CTMT208

Containment 208-Foot Elevation

07/31/2022

71124.01

Radiation

Surveys

CTMT208

Containment 208-Foot Elevation

07/17/2022

71124.01

Radiation

Surveys

GGN-AS-030123-

258

Air Sampling Report

03/01/2023

71124.01

Radiation Work

Permits (RWPs)

RWP 2022-1313

Refuel Floor Miscellaneous Craft Support and Management

71124.01

Radiation Work

Permits (RWPs)

RWP 2023-1070

Funda Filter Work

71124.01

Work Orders

583982

1G41A002 - Generated to Support Spent Fuel Pool

Cleanout Project

10/03/2022

71124.01

Work Orders

590804

SG17D003: Replace Floor Drain Filter Screens

71124.04

Corrective Action

Documents

CR-GGN-

20-11673, 2021-01524, 2021-01824, 2021-07014, 2022-

2368, 2022-03127, 2022-03415, 2022-03520, 2022-09337,

22-10436, 2023-00693, 2023-00694, 2023-00695

71124.04

Corrective Action

Documents

Resulting from

Inspection

CR-GGN-

23-01409

71124.04

Corrective Action

Documents

CR-HQN-

23-00265, 2023-00269, 2023-00270, 2023-00271

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Resulting from

Inspection

71124.04

Miscellaneous

NRC Form 5 for various workers

21, 2022

71124.04

Miscellaneous

List of EDEX and Multipack Dosimetry

22

71124.04

Miscellaneous

Source Term Reduction

22

71124.04

Miscellaneous

100518-0

NVLAP Certificate of Accreditation to ISO/IEC 17025:2017:

Landauer, Inc. Ionizing Radiation Dosimetry

01/01/2023

71124.04

Miscellaneous

CR-GGN-2022-

2368

Whole Body Count and Dose Assessment

03/08/2022

71124.04

Miscellaneous

CR-GGN-2022-

03127

Whole Body Count and Dose Assessment

03/19/2022

71124.04

Miscellaneous

CR-GGN-2022-

03415

Whole Body Count and Dose Assessment

03/24/2022

71124.04

Miscellaneous

CR-GGN-2023-

01409

Whole Body Count and Dose Assessment

03/24/2022

71124.04

Miscellaneous

GGN-RPT-20-005R0

Evaluation of Grand Gulf Nuclear Station's Average Beta

and Gamma Energy

05/06/2021

71124.04

Miscellaneous

GGN-RPT-21-002R0

Neutron Monitoring at Grand Gulf Nuclear Station

08/19/2021

71124.04

Procedures

EN-RP-201

Dosimetry Administration

71124.04

Procedures

EN-RP-202

Personnel Monitoring

71124.04

Procedures

EN-RP-203

Dose Assessment

71124.04

Procedures

EN-RP-204

Special Monitoring Requirements

71124.04

Procedures

EN-RP-204-01

Effective Dose Equivalent (EDEX) Monitoring

71124.04

Procedures

EN-RP-205

Prenatal Monitoring

71124.04

Procedures

EN-RP-206

Dosimeter of Legal Record Quality Assurance

71124.04

Procedures

EN-RP-208

Whole Body Counting/In-Vitro Bioassay

71124.04

Radiation Work

Permits (RWPs)

RWP 2021-1082

DFS (Hi Storm 1F16D003BN\\ MPC # 1F16D002BN) Work Order #502624

71124.04

Radiation Work

Permits (RWPs)

RWP 2022-1508

Under Vessel Maintenance

71124.04

Radiation Work

Permits (RWPs)

RWP 2022-1516

RF23 ISI and Support Activities

71124.04

Radiation Work

Permits (RWPs)

RWP 2022-1531

Suppression Pool Diving and Vacuum with Diakont Robotic

Decon Equipment

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71124.04

Self-Assessments LO-GLO-2022-

00086

Pre-NRC Inspection Occupational Dose Assessment

IP 71124.04

01/30/2023

71151

Corrective Action

Documents

CR-GGN-

22-06665, 2022-07790, 2022-08868, 2023-00218, 2023-

219, 2023-00220

71151

Procedures

EN-LI-114

Regulatory Performance Indicator Process

71153

Corrective Action

Documents

CR-GGN-

2016-08765, 2017-12477, 2018-09890, 2019-01757, 2019-

01833, 2019-04639, 2021-01451, 2021-01536, 2021-02950,

21-04781, 2021-05802, 2021-06434, 2022-06586, 2022-

07146, 2022-09773, 2022-10127, 2022-11392

71153

Engineering

Changes

EC-23022

GGNS Extended Power Uprate Feedwater Heater Drain

System Level Control Valve Modifications

71153

Engineering

Changes

EC-91787

Issue Engineering Report GGNS-SA-21-00002 and Revise

Engineering Report GGNS-N-16-00007

71153

Miscellaneous

10462339

Purchase Order

2/04/2016

71153

Miscellaneous

10472129

Purchase Order

2/17/2016

71153

Miscellaneous

10537921

Purchase Order

2/07/2018

71153

Miscellaneous

10619352

Purchase Order

08/25/2020

71153

Miscellaneous

55636

Receiving Inspection Report

05/22/2018

71153

Procedures

EN-DC-115

Engineering Change Process

71153

Procedures

EN-LI-108

Event Notification and Reporting

71153

Procedures

EN-LI-108-01

CFR 21 Evaluations and Reporting

and 14

71153

Work Orders

WO 26443, 526444, 526445, 526446, 558041, 52782092,

2839101, 52884887