IR 05000416/2023004
| ML24024A174 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 01/25/2024 |
| From: | Jeffrey Josey NRC/RGN-IV/DORS/PBC |
| To: | Kapellas B Entergy Operations |
| Bloodgood M | |
| References | |
| IR 2023004 | |
| Download: ML24024A174 (13) | |
Text
January 25, 2024
SUBJECT:
GRAND GULF NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000416/2023004
Dear Brad Kapellas:
On December 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Grand Gulf Nuclear Station. On January 10, 2024, the NRC inspectors discussed the results of this inspection with Grant Flynn, General Manager Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
The NRC documented in NRC Inspection Report 05000416/2023001 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23110A800), dated May 10, 2023, that the NRC was evaluating whether the 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, was warranted. The NRC reviewed the violations and determined that Inspection Procedure 92723 would not be performed because some of the violations were not indicative of current licensee performance.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Jeffrey E. Josey, Chief Reactor Projects Branch C Division of Operating Reactor Safety Docket No. 05000416 License No. NPF-29
Enclosure:
As stated
Inspection Report
Docket No.
05000416 License No.
NPF-29 Report No.
05000416/2023004 Enterprise Identifier:
I-2023-004-0011 Licensee:
Entergy Operations, Inc.
Facility:
Grand Gulf Nuclear Station Location:
Port Gibson, MS Inspection Dates:
October 1, 2023, to December 31, 2023 Inspectors:
E. Powell, Resident Inspector W. Schaup, Senior Project Engineer A. Smallwood, Senior Resident Inspector C. Wynar, Senior Resident Inspector Approved By:
Jeffrey E. Josey, 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.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000416/2023-001-01 Valve Closure Test Failure Resulting in Condition Prohibited by Technical Specification 71153 Closed
PLANT STATUS
Grand Gulf Nuclear Station, Unit 1, began the inspection period at 100 percent rated thermal power (RTP). On October 1, 2023, RTP was reduced to 88 percent for a rod pattern adjustment followed by a return to full RTP on October 2, 2023. On November 17, 2023, power was reduced to 87 percent RTP to recover a control rod hydraulic control unit and swap steam jet air ejector trains. On November 18, 2023, the unit returned to 100 percent RTP. On December 15, 2023, a power reduction was initiated for a rod pattern sequence change. On December 16, 2023, with the unit at 81 percent RTP, an automatic scram occurred due to a main turbine generator trip. The unit was stabilized in Mode 3. The unit entered Mode 4 on December 17, 2023, where it remained 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
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)division 3 standby service water on November 13, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
(1)division 1 switchgear room control building, 111-foot elevation, on October 5, 2023 (2)division 3 emergency diesel generator room on November 16, 2023
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in the:
- division 1 standby service water building, door 1M110, on October 3, 2023
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a licensed operator training scenario in the simulator on November 8, 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 (SSCs) remain capable of performing their intended function:
(1)work order 54063577, fuel handling area ventilation exhaust radiation monitor hi-hi alarm failed monitor replacement on October 18, 2023 (2)work order 54019147, standby service water A check valve P41F008A replacement on November 16, 2023
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (2 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)reactor core isolation cooling level 8 vessel level functional test completion with impending severe weather on November 20, 2023 (2)protected system lineup while residual heat removal division 2 is in service for shutdown cooling on December 21, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)condition report CR-GGN-2023-16421, tear in standby service water A pump boot seal on November 9, 2023 (2)condition report CR-GGN-2023-17261, division 2 emergency diesel generator increase in starting air dewpoint on December 8, 2023 (3)1A308 and 1A309 90F normal operating temperature limit on December 22, 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 88044, residual heat removal jockey pump A replacement on November 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) (6 Samples)
(1)work order 54011153, standby service water division 3 pump breaker 52-170124 on October 18, 2023 (2)work order 54019147, task 8 post maintenance test for P41F008A check valve replacement on November 6, 2023 (3)work order 54058877, scram time testing for hydraulic control unit 32-37 nitrogen leak repair on November 18, 2023 (4)work order 52910315, valve E61F007 actuator rebuild post maintenance test on November 27, 2023 (5)work order 52972467, standby service water division 1 valve P41-F081A control room air conditioner outlet on December 16, 2023 (6)work order 54057472, control rod settle time testing on December 18, 2023
Surveillance Testing (IP Section 03.01) (1 Sample)
(1)work order 54011958 high pressure core spray condensate storage tank low level functional test channel C on October 23, 2023
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) Green team emergency preparedness drill on October 25,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS09: Residual Heat Removal Systems (IP Section 02.08)===
- (1) October 1, 2022, through September 30, 2023
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
- (1) October 1, 2022, through September 30, 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)reactor core isolation cooling oil samples due to steam leakage in system on November 6, 2023
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in the vital area door access system that might be indicative of a more significant safety issue and noted multiple deficiencies. An observation is documented in the Inspection Results section of this inspection report.
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Follow up (IP Section 03.01)
- (1) The inspectors evaluated the plugging of fire suppression piping associated with the division 1, 2 and 3 emergency diesel generators and licensee's response on September 14, 2022.
Event Report (IP Section 03.02) (1 Sample)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000416/2023003-001-01, Valve Closure Test Failure Resulting in Condition Prohibited by Technical Specification (ML23334A051). The inspectors reviewed the updated LER submittal. The previous LER submittal was reviewed in Inspection Report 05000416/2023003. The inspection conclusions associated with this LER and a minor violation are documented in the Inspection Results section of this report. This LER is Closed.
INSPECTION RESULTS
Observation: Access System for Vital Area Doors 71152S The inspectors reviewed documents entered into the corrective action program for the following:
- complete, accurate, and timely documentation of the issue identified in the corrective action program
- evaluation and timely disposition of operability and reportability issues
- consideration of extent of condition and cause, generic implications, common cause, and previous occurrences
- classification and prioritization of the problems resolution commensurate with the safety significance
- identification of corrective actions that are appropriately focused to correct the problem
- completion of corrective actions in a timely manner commensurate with the safety significance of the issue
- identification of negative trends associated with human or equipment performance that can potentially impact nuclear safety
- operating experience is adequately evaluated for applicability, and applicable lessons learned are communicated to appropriate organizations and implemented For the inspection period, the inspectors observed multiple issues involving vital area door access system deficiencies. At least 23 condition reports document issues with vital area doors from July 1, 2023, to December 31, 2023. A small portion of these issues are related to human performance, and the majority are due to issues with the door access system equipment. Vital area doors provide functions important to nuclear safety involving security, and in some cases, flooding, fire, high pressure line break, and containment. A single vital area door may have multiple functions important to nuclear safety. In some cases, NRC inspectors have been delayed in inspections due to access control issues. Site security frequently had to take measures to compensate for vital area door access during the inspection period due to equipment issues with the site access system. Specifically, condition report CR-GGN-2023-14784 states that issues with vital area doors create an additional operator burden. Furthermore, condition report CR-GGN-2023-17211 points out that a degraded condition of control room envelope vital area doors may have a negative impact on the licensee emergency response plan. The site access system for vital areas is aging and difficult to maintain. The licensee has generated an engineering change, EC 90528, to upgrade the vital area door access system and has stated a goal to implement this change by June 30, 2025. The resident staff will review the engineering change and corrective action program effectiveness of this change after implementation.
Minor Violation 71153 Follow-up of Events and Notices of Enforcement Discretion Minor Violation: On June 13, 2023, the licensee documented condition report CR-GGN-2023-13838 stating that while reviewing data from the motor operated diagnostic test on valve E61F003B, it was identified that the butterfly valves disc was traveling past the valve seat. With the valve neither fully open nor fully shut, it was unable to meet its intended safety functions. With this information, operations personnel declared valve E61F003B and the division 2 drywell purge subsystem inoperable and entered Technical Specification (TS) 3.6.3.3, Drywell Purge Systems, and TS 3.6.5.6, Two Drywell Post-Loss-of-Coolant Accident (LOCA) and Two Drywell Purge Vacuum Relief Subsystems, as documented in the station logs. The licensee reported the loss of safety function on August 3, 2023, in LER 2023-001-00 under 10 CFR 50.73(a)(2)(i)(B), any operation or condition prohibited by the plants technical specifications. LER 2023-001-00 referenced TS 3.6.5.6. The inspectors review of LER 2023-001-00 noted that it did not state TS 3.6.3.3 was also entered due to the equipment inoperability. The inspectors determined that this was a violation of 10 CFR 50.9, Completeness and Accuracy of Information, for failing to report entering both TS 3.6.3.3 and TS 3.6.5.6. The licensee entered the issue into their corrective action program as condition report CR-GGN-2023-16307. On November 30, 2023, the licensee issued a revised LER 2023-001-01, which stated both TS 3.6.5.6 and TS 3.6.3.3 were entered.
Screening: The Reactor Oversight Process SDP does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter noncompliance. Because this performance deficiency had the potential to impact the NRCs ability to perform its regulatory function, it is necessary to address this violation using traditional enforcement to adequately deter noncompliance. Using the NRC Enforcement Policy, dated January 12, 2024, the violation was determined to be minor in accordance with section 6.9.d.9 because it involved a violation of 10 CFR 50.73 where if the information initially reported had been complete and accurate the information not reported had no material impact on safety or licensed activities.
Enforcement:
The licensee has taken actions to restore compliance by summitting a revision to the LER. This minor violation is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 10, 2024, the inspectors presented the integrated inspection results to Grant Flynn, General Manager Plant Operations, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-GGN-
20-04366, 2021-03593, 2022-00109, 2022-00832
Corrective Action
Documents
CR-GGN-
22-09138
Corrective Action
Documents
CR-GGN-
23-15118
Corrective Action
Documents
CR-GGN-
21-08705, 2023-01300, 2023-13325, 2023-16218, 2023-
231
Work Orders
WO 54019147, 54063577
Corrective Action
Documents
CR-GGN-
2009-06689, 2023-16421, 2023-17261
Corrective Action
Documents
CR-GGN-
23-02049, 2023-14247, 2023-15295
Engineering
Changes
Corrective Action
Documents
CR-GGN-
23-14219, 2023-14143, 2023-15935, 2023-15984
Procedures
06-IC-1E22-Q-
0002
Condensate Storage Tank Low Level Functional Test
Channel C
2
Work Orders
WO 5408877, 52910315, 52972467, 52992399, 54011153,
54011958, 54019147, 54057472
71152A
Corrective Action
Documents
CR-GGN-
21-02816, 2021-03133, 2022-09584, 2023-00138, 2023-
296, 2023-14972
71152S
Corrective Action
Documents
CR-GGN-
23-14615, 2023-14784, 2023-15371, 2023-15508, 2023-
15520, 2023-15560, 2023-15599, 2023-15731, 2023-16041,
23-16088, 2023-16181, 2023-16203, 2023-16368, 2023-
16395, 2023-16540, 2023-16571, 2023-16595, 2023-16728,
23-16849, 2023-16972, 2023-17004, 2023-17139, 2023-
211