IR 05000416/2023002
| ML23219A164 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear  |
| Issue date: | 08/08/2023 |
| From: | David Proulx NRC/RGN-IV/DORS/PBC |
| To: | Kapellas B Entergy Operations |
| Lichvar S | |
| References | |
| IR 2023001 | |
| Download: ML23219A164 (19) | |
Text
August 08, 2023
SUBJECT:
GRAND GULF NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000416/2023002 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION REPORT 07200050/2023001
Dear Brad Kapellas:
On June 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Grand Gulf Nuclear Station. On July 13, 2023, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with section 2.3.2 of the Enforcement Policy.
A licensee-identified violation which was determined to be Severity Level IV is also documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Grand Gulf Nuclear Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Grand Gulf Nuclear Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, David L. Proulx, Acting Chief Reactor Projects Branch C Division of Operating Reactor Safety Docket No. 05000416, 07200013 License No. NPF-29
Enclosure:
As stated
Inspection Report
Docket Number:
05000416 and 07200050
License Number:
Report Number:
05000416/2023002 and 07200050/2023001
Enterprise Identifier:
I-2023-002-0011 and I-2023-001-0014
Licensee:
Entergy Operations, Inc.
Facility:
Grand Gulf Nuclear Station
Location:
Port Gibson, MS
Inspection Dates:
April 1, 2023, to June 30, 2023
Inspectors:
L. Brookhart, Senior Spent Fuel Storage Inspector
J. Freeman, Spent Fuel Storage Inspector
S. Lichvar, Acting Senior Resident Inspector
A. Smallwood, Resident Inspector
T. Steadham, Senior Resident Inspector
Approved By:
David Proulx, Acting Chief
Reactor 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. A licensee-identified non-cited violation is documented in report section: 71111.1
List of Findings and Violations
Failure to Follow Procedure 06-EL-1L11-Q-0001 for the Division 2 Engineered Safety Feature 125 Vdc Battery Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000416/2023002-01 Open/Closed
[H-14] -
Conservative Bias 71111.15 The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, when the licensee failed to correct a condition adverse to quality as prescribed in station Procedure 06-EL-1L-Q-0001, 125 Volt Battery Bank All Cell Check, revision 110, a continuous use quality procedure. Specifically, the licensee failed to accomplish the quantitative and qualitative acceptance criteria of the procedure which required the corrosion on the battery terminals for the division 2 engineered safety feature 125 Vdc battery to be corrected and the resistance measurements of the terminal connections be documented.
Additional Tracking Items
None.
PLANT STATUS
Grand Gulf Nuclear Station, Unit 1, began the inspection period at 67 percent rated thermal power (RTP) for a control rod sequence exchange. RTP returned to 100 percent on April 2, 2023, after completion of the control rod sequence exchange. On April 9, 2023, RTP was reduced to 98 percent due to a main turbine generator stator bar cooling issue. The station returned to 100 percent RTP on April 15, 2023. On May 1, 2023, the station was reduced to 98 percent RTP for main turbine generator stator bar cooling issues with a return to 100 percent RTP on May 8, 2023. On May 21, 2023, the station again reduced power to 98 percent RTP due to concerns with the main turbine generator stator bar cooling. On June 24, 2023, power was reduced to 76 percent of RTP for a control rod sequence change with a subsequent return to 98 percent RPT where the unit 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.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (2 Samples)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal warm temperatures for the following systems:
standby diesel generators on May 11, 2023
standby service water on May 11, 2023
- (2) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of potential tornadoes, thunderstorms, and derecho winds for the following systems:
Unit 1 start up transformer on June 14, 2023
Unit 1 main transformer on June 14, 2023
standby service water intake structure on June 14, 2023
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather due to a tornado watch and expected severe weather on May 11, 2023.
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)engineered safety features transformer 12 on May 11, 2023 (2)residual heat removal train C post-maintenance on May 12, 2023 (3)standby service water train B during maintenance on train A on May 24, 2023 (4)diesel building ventilation on June 13, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
(1)high pressure core spray pump room on April 24, 2023 (2)division 1 reactor protection system motor generator OC707 and upper cable room OC702 on April 25, 2023 (3)division 2 control room ventilation room on May 5, 2023 (4)main control room on May 9, 2023 (5)emergency diesel generator breezeway on June 13, 2023
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) high pressure core spray pump room cooler on May 4, 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 increased stator bar temperatures on May 4, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator training in the simulator on May 17, 2023.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:
(1)work order 53027973-01, safety-related manhole 3 cable inspections on April 26, 2023 (2)work order 53020416, division 2 engineered safety feature battery preventive maintenance and battery terminal corrosion on June 26, 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 with low pressure core spray out of service on April 25, 2023 (2)protected system lineup for division 1 reactor protection system motor generator alternate power lineup on April 25, 2023 (3)risk management actions for main turbine generator stator bar coolant passage chemical cleaning on April 26, 2023 (4)protected system lineup while standby service water train B fan D out of service on May 12, 2023 (5)standby service water division 1 maintenance outage on May 18, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)condition report CR-GGN-2023-02467, degraded flow to high pressure core spray pump room cooler on May 4, 2023 (2)condition report CR-GGN-2023-02659, scram discharge volume vent valve stroke time exceeded test criteria on May 8, 2023 (3)condition report CR-GGN-2023-13400, configuration of standby service water pump cooling water pipe on May 24, 2023 (4)condition report CR-GGN-2023-13215, feedwater piping seismic qualification on June 26, 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)engineering change EC-86813, inservice testing, re-baseline stroke times for 1C11F180 and 1C11F181 on May 9, 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) (3 Samples)
(1)work order 593598, drywell atmospheric monitoring pump replacement on May 4, 2023 (2)work order 584422, replace drywell pressure transmitter 1B21N067L on May 15, 2023 (3)work order 54004825, reactor protection system motor generator division 1 voltage output on June 1, 2023
Surveillance Testing (IP Section 03.01) (4 Samples)
(1)work order 53029464, residual heat removal pump A quarterly functional test on April 27, 2023 (2)work order 53028520, safety relief valve tail pipe pressure switch functional test on May 11, 2023 (3)work order 53015883, division 2 battery cell 1B3 resistance checks on May 11, 2023 (4)work order 54001887, load shedding sequencer division 2 monthly test on June 2, 2023
Inservice Testing (IST) (IP Section 03.01) (3 Samples)
(1)work order 52964192, high pressure core spray check valve testing on April 27, 2023 (2)work order 53029463, low pressure coolant injection motor operated valve functional test for residual heat removal division 1 on April 27, 2023 (3)work order 52972140, scram discharge volume vent and drain valve operability test on May 8, 2023
Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)
(1)increased drywell unidentified leakage shiftly surveillance on May 5, 2023
71114.01 - Exercise Evaluation
Inspection Review (IP Section 02.01-02.11) (1 Sample)
- (1) The inspectors evaluated the biennial emergency plan exercise conducted on March 22, 2023. The exercise scenario simulated a feedwater heating loss followed by fuel clad degradation, increasing plant radiation levels, a feedwater line break causing increasing drywell pressure, high pressure core spray injection valve and division 2 logic power failures; followed by increasing containment radiation levels.
The simulated scenario did not involve a radiological release offsite. The licensee completed its critique process for the exercise on April 26, 2023, and the inspectors subsequently evaluated the effectiveness of the critique process to identify performance weaknesses and deficiencies to ensure they were entered into the corrective action program for resolution.
This documents completion of this inspection sample which was documented as a partial sample in Inspection Report 05000416/2023001 (ADAMS Accession No. ML23110A800).
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)===
- (1) April 1, 2022, through March 31, 2023
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)
- (1) April 1, 2022, through March 31, 2023
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)
- (1) April 1, 2022, through March 31, 2023
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
(1)condition report CR-GGN-2021-06434 on May 4, 2023 (2)condition report CR-GGN-2022-11390 on May 4, 2023
- (3) CAPR review on June 28, 2023
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program, procedural change requests, and related documentation to identify performance trends in documentation that might lead to a more signification safety issue.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
===60853 - On-Site Fabrication of Components and Construction on an ISFSI To determine whether independent spent fuel storage installation (ISFSI) dry cask storage components were designed and fabricated in accordance with license requirements. This sample included site observations of concrete placement activities and a review of the Grand Gulf Nuclear Station's ISFSI pad design.
On-Site Fabrication of Components and Construction on an ISFSI===
- (1) On May 11-12, 2023, the inspectors conducted an inspection of Grand Gulf Nuclear Station's planning and construction of their ISFSI expansion. The licensee had designed the original ISFSI pad to hold 44 HI-STORM storage casks plus contain four temporary storage locations for shuffling purposes. At the time of the inspection, the licensee was expanding the ISFSI to have an additional concrete pad that would increase the total capacity of the ISFSI to be capable of storing 88 storage casks, plus the four temporary storage locations. The Grand Gulf ISFSI currently contained 44 HI-STORM 100 casks and the licensee planned on switching to the HI-STORM FW storage system for future canister loadings.
Inspectors observed rebar verification and concrete placement activities associated with the first pad section of the expansion effort. The licensee was constructing the ISFSI pad in accordance with the Holtec International HI-STORM FW Certificate of Compliance 72-1032 License Amendment 5, and the HI-STORM FW Final Safety Analysis Report (FSAR), revision 8.
During the concrete pad placement the inspectors reviewed the following samples:
reviewed documentation and observed construction services to ensure the ISFSI pad was designed and fabricated to meet the Holtec HI-STORM FW FSAR requirements and design procurement specifications
concrete was cured in accordance with American Concrete Institute (ACI) 318 "Building Code Requirements for Structural Concrete"
batch plant and concrete delivery trucks met American Society for Testing and Materials (ASTM) C 94, "Standard Specification for Ready Mixed Concrete," in respect to maximum mix time, maximum/minimum drum revolutions, addition of admixtures on the job site, and calibration of scales at the batch plant
concrete forms met ACI 318 in respect to wetting prior to concrete placement, removal of debris, controlling leaks, controlling form deflection, applying release agents, and removing of standing water
concrete mix design for all ingredients met the ACI code requirements and ASTM standards for water-reducing admixtures, retarding/accelerating admixtures, aggregates, cement, air entrainment admixtures, and potable water
rebar placement and construction was consistent with ACI 318 requirements for rebar size, bend diameters, tensile strength test records, and minimum concrete cover requirements to protect the rebar from corrosion
concrete testing and sampling met the ACI and ASTM standards with respect to sampling locations, methods, number of samples, and methods for molding and curing strength test cylinders
concrete placement met design specifications for air entrainment, slump, and water/cement ratio
concrete placement met ACI 318 requirements for consolidation, setup (not dragging the concrete), and finishing techniques
licensee design evaluations were reviewed to ensure the pads met static and dynamic loads, soil-structure liquefaction requirements, and subsoil modulus of elasticity requirements
INSPECTION RESULTS
Failure to Follow Procedure when a Condition Adverse to Quality was Identified with the Division 2 Engineered Safety Feature 125 Vdc Battery Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000416/2023002-01 Open/Closed
[H.7] -
Documentation 71111.12 The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, when the licensee failed to follow station procedure 06-EL-1L-Q-0001, 125 Volt Battery Bank All Cell Check, revision 110, to correct a condition adverse to quality. Specifically, the licensee failed to accomplish the quantitative and qualitative acceptance criteria of the procedure which required the corrosion on the battery terminals for the division 2 engineered safety features (ESF) 125 Vdc battery to be removed and the resistance measurements of the terminal connections be documented.
Description:
On December 8, 2022, the licensee generated condition report CR-GGN-2022-11111 to document corrosion found on the division 2 engineered safety feature (ESF) 125 Vdc battery and requested remediation of the adverse condition.
On January 11, 2023, the licensee performed work order (WO) 53020416 using Procedure 06-EL-1L11-Q-0001, 125 Volt Battery Bank All Cell Check, revision 110.
Step 11 of the procedure states, If corrosion is visible perform the following: including step 5.1.15(c) of procedure 06-EL-1L11-Q-0001. Step 5.1.15(c) states, in part, remove any surface corrosion from the battery bank and support racks. Step 11 was marked not applicable.
On January 11, 2023, the licensee identified during the performance of the division 2 ESF battery cell checks under WO 53020416 that corrosion was already present and generated condition report CR-GGN-2023-01920 and referenced condition report CR-GGN-2022-11111.
Procedure 06-EL-1L11-Q-0001, step 11, also requires Procedure 06-EL-1L11-R-0001, 125 Volt Battery Bank Physical Condition Check, revision 107, to be completed, which measures individual battery cell resistivities in accordance with surveillance requirement (SR) 3.8.4.2. Attachment 2 of procedure 06-EL-1L11-R-0001, lists as measured cell resistance of all 61 cells when completed for the ESF division 2 battery. On January 11, 2023, the cell resistance measurements were not recorded as required by procedure 06-EL-1L11-Q-0001, step 11, and attachment 2 from procedure 06-EL-1L11-R-0001 is not present in WO 53020416.
Additionally, the updated final safety analysis report (UFSAR) for GGNS, section 8.3.2.1.6.4 states, in part, 125 Vdc batteries are inspected following manufacturers recommended procedures. C&D Batteries vendor manual 460000247, C&D batteries, chargers and racks, is referenced in GGNS procedures and provided by the licensee as vendor guidance for battery maintenance. The C&D Batteries vendor manual section 6.11 states, in part, that maintenance of battery connections is one of the most important tasks for which the user is responsible. The vendor manual in section 9.3 titled Connections - Conductivity, Cleanliness, and Tightness, states, in part, to remove all corrosion byproducts and restore connections to the as-installed condition. The vendor manual recommends a minimum of four times per year for this inspection and subsequent correction of corrosion.
Condition reports CR-GGN-2023-02174 and CR-GGN-2023-02309 state that corrosion will degrade battery performance overtime. Condition report CR-GGN-2023-01762 additionally described that continued degradation could impact dc power reliability, various control indications and reactor safety features. Terminal degradation is measured by resistivity measurements using procedure 06-EL-1L11-R-0001. Baseline resistivity for all cells of the division 2 125 V ESF battery is 17.5 micro-ohms per station records.
On April 17, 2023, as documented in WO 53015883, average cell resistivity was 21.3 micro-ohms for all cells of the division 2 125 V ESF battery. The maximum observed resistivity for WO 53015883 was 41.5 micro-ohms for cell 1. While this is less than the station administrative limit of 50 micro-ohms and less than the SR 3.8.4.2 limit of 150 micro-ohms, degradation of the battery terminal connections was measurable. After cleaning the terminal connections on May 5, 2023, average cell resistance for all division 2 125 V ESF cells was 18.3 micro-ohms, approximating baseline measurements. Increased resistance measurements when corrosion was present with a subsequent decrease in resistance after corrosion removal demonstrates the degraded condition.
On April 7, 2023, and on April 14, 2023, inspectors questioned GGNS maintenance and regulatory affairs inquiring if the maintenance requirements of the UFSAR, section 8.3.2.1.6.4 were being satisfied. On May 5, 2023, GGNS completed work to correct the observed corrosion on the division 2 ESF 125 Vdc battery. On May 10, 2023, condition report CR-GGN-2023-13132 was issued to document discrepancies between the UFSAR, section 8.3.2.1.6.4, and site procedures.
During these interactions with the licensee, operating experience regarding enhanced corrosion caused by electrolyte leaks from cracked jar lids on the division 2 ESF 125 Vdc battery were discussed. Due to age and known issues with cracked jar lids of C&D station batteries, the station replaced the division 1 ESF 125 Vdc battery during the planned outage of 2022 with updated jar lids designed to reduce electrolytic corrosion.
Corrective Actions: On May 5, 2023, the licensee executed WO 53028529 restoring the condition of the division 2 ESF 125 V station battery to vendor recommended condition by cleaning the corrosion in accordance with procedure 06-EL-1L11-Q-0001 and measuring individual cell resistance. The licensee entered this issue into their corrective action program for resolution as condition report CR-GGN-2023-13172.
Corrective Action References: condition reports CR-GGN-2022-11111, CR-GGN-2023-01762, CR-GGN-2023-01920, CR-GGN-2023-02174, CR-GGN-2023-02309, CR-GGN-2023-02637, and CR-GGN-2023-13172
Performance Assessment:
Performance Deficiency: The failure to remediate the corrosion and measure cell resistance as described in procedure 06-EL-1L11-Q-0001 was a performance deficiency. Specifically, the licensee did not accomplish the requirements of the procedure including appropriate quantitative and qualitative acceptance criteria to establish that important activities had been satisfactorily completed as required by 10 CFR Part 50, appendix B, criterion V.
Screening: The inspectors determined the performance deficiency was more than minor because the performance deficiency is associated with the Human Performance attribute of the Mitigating Systems cornerstone, and the performance deficiency adversely affected the cornerstone's objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failing to remediate the corrosion and measure cell resistance allowed the condition to persist, which would, with additional time, degrade the battery to a point where it could not perform the intended safety function.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Utilizing exhibit 2, the inspectors screened the finding as Green because the mitigating system maintained its operability.
Cross-Cutting Aspect: H.14 - Conservative Bias: Individual use decision-making practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, the licensees decision-making practice that allowed continued degradation of the division 2 125 V ESF battery without correcting corrosion is not reflective of an organization with a bias for conservative decision-making.
Enforcement:
Violation:
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures.
The licensee established station procedure 06-EL-1L-Q-0001, 125 Volt Battery Bank All Cell Check, revision 110, as the implementing procedure for preventative maintenance for 125 Volt ESF Batteries, an activity affecting quality.
Procedure 06-EL-1L-Q-0001, step 11 states, If corrosion is visible perform the following including step 5.1.15(c). Step 5.1.15(c) states, in part, remove any surface corrosion from the battery bank and support racks.
Contrary to the above, from January 11, 2023, to May 5, 2023, the licensee failed to follow step 5.1.15(c) of procedure 06-EL-1L-Q-0001. Specifically, the licensee failed to remove corrosion found on the batteries and take and record cell resistance measurements as required.
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 71111.15 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: Title 10 CFR 50.59(c)(2) requires, in part, a licensee shall obtain a license amendment prior to implementing a proposed change if the change would result in either a more than a minimal increase in the likelihood of occurrence of a malfunction of a structure important to safety previously evaluated in the UFSAR or result in a departure from a method of evaluation described in the UFSAR.
Contrary to the above, on March 29, 1995, the licensee failed to obtain a license amendment prior to implementing a proposed change that resulted in a more than a minimal increase in the likelihood of occurrence of a malfunction of a structure important to safety previously evaluated in the UFSAR and a departure from a method of evaluation described in the UFSAR. Specifically, engineering change EC 92949 employed an evaluation method which resulted in a departure from a method described in the UFSAR used in establishing design bases or in safety analyses.
Significance/Severity: Minor Performance Deficiency. Severity Level IV. The inspectors determined this violation was associated with a minor performance deficiency. Specifically, the failure to obtain a license amendment prior to implementing engineering change EC 92949 was contrary to 10 CFR 50.59; however, this failure did not affect equipment operability. Using the NRC Enforcement Policy, dated January 13, 2023, the violation was determined to be a Severity Level IV violation in accordance with NRC Enforcement Policy example 6.1.d.2 because the licensee violated 10 CFR 50.59 (c)(2).
Corrective Action References: condition reports CR-GGN-2023-13215 and CR-GGN-2023-13585 Observation: Semiannual Trend Review 71152S The inspectors reviewed the licensees corrective action program, procedural change requests, and other documentation to identify performance trends in documentation that might lead to a more signification safety issue. The inspectors did not review any cross-cutting themes because none existed at the site.
To verify the licensee took corrective actions to identify adverse trends that might indicate the existence of a more significant safety issue, the inspectors noted an apparent negative trend associated with written documentation. Specifically, since January 2023, the licensee has written several condition reports regarding procedures with errors. Some examples of procedural errors that could lead to a more significant issue are listed.
Condition report CR-GGN-2023-02386 states, in part, procedure 06-IC-SD17-R-1028 called out panel 1D17-P-11A in containment on the 166-foot elevation. The correct location is the auxiliary building on the 166-foot elevation.
Condition report CR-GGN-2023-02469 states, in part, procedure 06-OP-1P41-Q-0004 called out panel 1H13-P870-1C for step 23. The correct panel designation is 1H13-P870-7C.
Condition report CR-GGN-2023-13630 states, in part, procedure 06-IC-1C71-Q-2002-04 lists a relay location as 1H13P691, and the correct location is 1H13P694.
Condition report CG-GGN-2023-13637 states, in part, procedure 06-OP-1C71-Q-2002-06 lists a relay in panel 1H13P693, and the correct location is 1H13P692.
The inspectors verified that each of these procedural errors have been entered into the licensee procedural change request program. Inspection Manual Chapter (IMC) 310 (H.7)titled Documentation states the organization maintains complete, accurate, and up-to-date documentation. NUREG-2165 titled, Safety Culture Common Language, also states, in part, under work processes (WP.3), example 2, documentation, procedures, and work packages are complete, thorough, accurate, and current. Additionally, example 4 states, in part, document changes are prioritized to ensure quality. While no findings resulted from this inspection, continued errors in procedures could lead to an issue of more significance.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On May 18, 2023, the inspectors presented the emergency preparedness exercise inspection results to Brad Kapellas, Site Vice President, and other members of the licensee staff.
On June 1, 2023, the inspectors presented the Grand Gulf ISFSI concrete placement inspection results to Brad Kapellas, Site Vice President, and other members of the licensee staff.
On July 13, 2023, the inspectors presented the integrated 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
60853
Drawings
C-7503
GGNS-ISFSI Facility Concrete Pad Foundation - Phase 2 Plan
301
60853
Drawings
E-7186-003 FCR
93641
Expanded Protected Area Grounding Plan East
300
60853
Engineering
Changes
EDCR-3128-
(S)002
ISFSI Concrete Mix Design
60853
Engineering
Changes
FCR 31281015-
R1
During ISFSI Section 1 Concrete Pour Brief Rain Shower
Occurred
05/12/2023
60853
Engineering
Evaluations
CC-N1111-04012
ISFSI Liquefaction Calculation
60853
Miscellaneous
CR-GGN-2023-
226
Condition report regarding rain shower on concrete pad during
pour
05/12/2023
60853
Miscellaneous
FCR31281001
Field Condition Report for Concrete Batch Ticket Water-
Cement Ration is In-Accurate
2/13/2023
60853
Miscellaneous
FCR31281013
Field Condition Report for Top mat of ISFSI rebar Section 1
tolerance incorrect
05/03/2023
60853
Miscellaneous
Holtec Concrete
Placement
Checklist
ISFSI Placement #1-Lessons Learned Concrete
60853
Miscellaneous
NRMCA
Trucks.pdf
List of NRMCA certified trucks
60853
Miscellaneous
Plant NRMCA
Certification.pdf
National Ready Mixed Concrete Association Certificate of
Conformance for Concrete Production Facilities. Vicksburg
Plant 51, MMC Materials, Inc.
04/01/2023
60853
Miscellaneous
PO 131780
HOLTEC Purchase order to MMC Materials for ISFSI pad
60853
Miscellaneous
SPEC-19-00002-
G
Technical Specifications for ISFSI Phase 2 Concrete Pad
60853
Procedures
HPP-3128-0186
Aggregate and Ready Mixed Concrete Testing Requirements
for ITS & NITS Applications
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-GGN-
20-05637, 2020-06686, 2022-09275, 2023-01507, 2023-
2306
Corrective Action
Documents
CR-GGN-
20-01104, 2020-07657, 2022-07577,
Corrective Action
Documents
CR-GGN-
22-05887, 2023-02467, 2023-02539
Work Orders
WO 580844, 53016817, 53025962
Work Orders
WO 53020416, 53027973
Corrective Action
Documents
CR-GGN-
21-02713, 2022-09881, 2023-01461
Miscellaneous
STI-2300-000
Special Test Instruction for Generator Stator Cleaning
Calculations
MC-Q1P41-83008
Pipe Support AQ1P41G474A01
Calculations
MC-Q1P41-97020
Determination of Minimum Allowable Standby Service Water
Flows to Safety-Related Heat Exchangers
Corrective Action
Documents
CR-GGN-
23-02467, 2023-02659, 2023-13400
Procedures
06-OP-1C11-Q-
0009-01
Scram Discharge Volume Vent and Drain Valves Operability
Test
113
Work Orders
WO 2972140, 53021954
Engineering
Changes
Procedures
06-OP-1C11-Q-
0009
Scram Discharge Volume Vent and Drain Valves Operability
Test
2
Work Orders
Corrective Action
Documents
CR-GGN-
20-00629, 2020-03376, 2021-00322, 2022-01220, 2022-
230, 2022-07704, 2022-08355, 2022-10291, 2022-11111,
23-00264, 2023-00478, 2023-00484, 2023-01107, 2023-
2046, 2023-02174
Engineering
Changes
In-service Test Reference Value Change for 1C11F010 and
1C11F011
05/16/2019
Work Orders
WO 24209, 584422, 593598, 52964192, 52972140, 53006154,
53013962, 53015883, 53021954, 53028520, 53029463,
53029464, 54001887
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-GGN-
23-01927, 2023-01982, 2023-01993, 2023-01994, 2023-
01995, 2023-01996, 2023-02059, 2023-02129
Corrective Action
Documents
CR-GGN-
20-08779, 2020-11199, 2021-03320, 2021-06434, 2022-
11390, 2023-00580,
Engineering
Changes
GGN-EC-
88635, 89459, 92718
Procedures
Technical Task Risk & Rigor
09/13/2021
Work Orders
WO 554421, 558976, 559062, 559063, 559065, 578731