IR 05000416/2024003
| ML24309A113 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  (NPF-029) |
| Issue date: | 11/06/2024 |
| From: | Jeffrey Josey NRC/RGN-IV/DORS/PBC |
| To: | Kapellas B Entergy Operations |
| Schaup W | |
| References | |
| IR 2024003 | |
| Download: ML24309A113 (16) | |
Text
November 06, 2024
SUBJECT:
GRAND GULF NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000416/2024003
Dear Brad Kapellas:
On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Grand Gulf Nuclear Station. On October 9, 2024, 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.
Two findings of very low safety significance (Green) are documented in this report. Both of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Grand Gulf Nuclear Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Grand Gulf Nuclear Station.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Jeffrey E. Josey, Chief Reactor Inspection Branch Division of Radiological Safety and Security Docket No. 05000416 License No. NPF-29
Enclosure:
As stated
Inspection Report
Docket No:
05000416
License No:
Report No:
Enterprise Identifier:
I-2024-003-0011
Licensee:
Entergy Operations, Inc.
Facility:
Grand Gulf Nuclear Station
Location:
Port Gibson, MS 39150
Inspection Dates:
July 1 to September 30, 2024
Inspectors:
R. Azua, Senior Reactor Inspector
R. Kopriva, Senior Project Engineer
J. Melfi, Project Engineer
W. Schaup, Senior Project Engineer
A. Smallwood, Senior Resident Inspector
Approved By:
Jeffrey E. Josey, Chief
Reactor Inspection Branch
Division of Radiological Safety and Security
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Grand Gulf Nuclear Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Have Environmental Qualification Evaluation for Standby Liquid Control Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000416/2024003-01 Open/Closed None (NPP)71111.15 The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of 10 CFR 50.49, Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants, for the licensees failure to qualify an item of electrical equipment important to safety by acceptable methods. Specifically, the standby liquid control system is not installed in accordance with the requirements of 10 CFR 50.49.
Since the configuration in the plant is not in accordance with the environmental qualification requirements of 10 CFR 50.49, the licensee is required to qualify the standby liquid control system by one of the methods as described in 10 CFR 50.49 to qualify the configuration as installed in the plant.
Failure to Take Timely Corrective Action for Inoperable Drywell Air Cooler Condensate Flow Monitoring Instrumentation Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000416/2024003-02 Open/Closed
[H-14] -
Conservative Bias 71152A The inspectors identified a finding and associated Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly correct a condition adverse to quality. Specifically, since September 12, 2020, the drywell air cooler condensate flow monitoring system has become inoperable during the three most recent operating cycles due to clogging of the common drain line. The licensee has performed cleaning and flushing of the line repeatedly that has not resulted in resolution of this condition adverse to quality. The licensee has an engineering change proposed, but the change has not been implemented since a notice of unusual event was declared for this issue on January 7, 2021.
Additional Tracking Items
None.
PLANT STATUS
At the beginning of the inspection period, Grand Gulf Nuclear Station, Unit 1, was operating at 100 percent rated thermal power (RTP). On August 19, 2024, power was lowered to 92 percent RTP for hydraulic control unit maintenance, and subsequently returned to 100 percent RTP later the same day. On August 24, 2024, a power reduction to 64 percent was initiated for a rod pattern sequence change with a subsequent return to 100 percent RTP on August 25th, 2024, where the unit remained at or near for the rest 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 onsite 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) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of a tropical storm warning on September 10, 2024.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)division 3 engineered safety feature diesel generator during reactor core isolation cooling maintenance on August 14, 2024 (2)residual heat removal system division 3 on September 4, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 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)auxiliary building, 174-foot elevation above the steam tunnel, on August 22, 2024 (2)emergency hot shutdown room, 111-foot elevation in the control building, on September 26, 2024 (3)computer and control panel room, 148-foot elevation in the control building, on September 27, 2024
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 in the auxiliary building, 119-foot elevation, room 1A208, on August 23, 2024.
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in the reactor core isolation cooling room, 93-foot elevation, in the auxiliary building on September 17, 2024.
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 and rod sequence change on August 24, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)
- (1) The inspectors observed and evaluated licensee licensed operator requalification simulator scenarios on July 31, 2024.
- (2) The inspectors observed and evaluated the licensed operator requalification simulator scenario on August 7, 2024.
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 (WO) 454699 division 3 battery replacement on July 31, 2024
- (2) WO 52936726 standby service water division 2 cooling tower fans inoperable due to low spring tension on fuse holder on September 11, 2024
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)protected system walkdown during division 2 engineered safety feature diesel generator maintenance on July 2, 2024 (2)protected system walkdown during reactor core isolation cooling maintenance outage on August 13, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Condition Report (CR)-GGN-2024-03659 reactor core isolation coolant steam leak relative humidity in room 1A104 on July 15, 2024
- (2) CR-GGN-2024-04405 scram discharge volume vent and drain valve in service testing slow closure time on August 12, 2024
- (3) CR-GGN-2024-05134 broken hinge on control room door OC516 on September 16, 2024
- (4) CR-GGN-2024-0535 division III diesel generator stator bar temperatures during 24-hour test on September 27, 2024
- (5) CR-GGN-2021-03154 standby liquid control environmental qualification on September 30, 2024
71111.24 - Testing and Maintenance of Equipment Important to Risk
Post-Maintenance Testing (PMT) (IP Section 03.01) (7 Samples)
- (1) T42F020 fuel handling area secondary containment isolation valve stroke time retest on July 3, 2024
- (2) WO 54160082 standby service water division 2 cooling tower fans retest on July 12, 2024
- (3) WO 590030 high pressure core spray jockey pump replacement on July 25, 2024
- (4) WO 454699 task 4 division 3 battery replacement post-maintenance all cell check on August 6, 2024
- (5) WO 53019005 M41-F035 post-maintenance valve stroke testing on August 20, 2024
- (6) WO 507876 reactor core isolation cooling injection shutoff valve, E51-F013, post-maintenance test on September 3, 2024
- (7) WO 591602 reactor core isolation cooling suction from condensate storage tank valve, limit switch post-maintenance test on September 24, 2024
Surveillance Testing (IP Section 03.01) (2 Samples)
(1)reactor core isolation cooling low pressure functional test channel B on August 5, 2024 (2)high pressure core spray diesel generator function test, loss of offsite power, and reject of largest load test on September 27, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) WO 54140910 scram discharge volume vent and drain valve in service testing on September 18, 2024
Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)
(1)increased unidentified reactor system leakage on September 27, 2024
71114.06 - Drill Evaluation
Required Emergency Preparedness Drill (1 Sample)
- (1) Red team and Yellow team turnover drill at the backup emergency operations facility on August 28, 2024
Additional Drill and/or Training Evolution (1 Sample)
The inspectors evaluated:
- (1) Green team tabletop evaluated drill scenario on September 18,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) July 1, 2023, through June 30, 2024
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
- (1) July 1, 2023, through June 30, 2024
MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)
- (1) July 1, 2023, through June 30, 2024
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 system oil samples due to ongoing system steam leakage on September 18, 2024 (2)drywell air cooler condensate flow rate monitoring system inoperable on September 30,
INSPECTION RESULTS
Failure to Have Environmental Qualification Evaluation for Standby Liquid Control Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000416/2024003-01 Open/Closed None (NPP)71111.15 The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation of 10 CFR 50.49, Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants, for the licensees failure to qualify an item of electrical equipment important to safety by acceptable methods. Specifically, the standby liquid control system is not installed in accordance with the requirements of 10 CFR 50.49.
Since the configuration in the plant is not in accordance with the environmental qualification requirements of 10 CFR 50.49, the licensee is required to qualify the standby liquid control system by one of the methods as described in 10 CFR 50.49 to qualify the configuration as installed in the plant.
Description:
During review of the licensee plan of the day inspectors became aware of concerns regarding the environmental qualification of the standby liquid control (SLC) system.
The initial design of the SLC system met the requirements of 10 CFR 50.62 to reduce risk for an anticipated transient without a scram (ATWS). The accident design basis for ATWS does not include environmental qualification requirements as listed in 10 CFR 50.49. On March 14, 2001, Grand Gulf Nuclear Station (GGNS) received license amendment number 145 from the NRC licensing the station to uprate power to 4,408 megawatts thermal. As a condition of this license amendment, the accident source term (AST) requirements of 10 CFR 50.67 were made applicable to GGNS. In order to comply with the long-term radiation requirements of AST, the licensee credited the SLC system with long-term pH control of the suppression pool as described in section 3.1.4 of license amendment 145. The licensee analysis was performed in accordance with NUREG-5732, titled Iodine Chemical Forms in Light Water Reactors in Severe Accidents, and accepted by the NRC in order to meet the requirements of 10 CFR 50.67.
Environmental qualification of electric equipment important to safety for nuclear power plants in 10 CFR 50.49 (b)(1)(i)(C) states, in part, that equipment relied upon to prevent or mitigate the consequences of accidents that could result in potential offsite exposures comparable to the guidelines of 10 CFR 50.67 (b)(2) is required to be within the licensees environmental qualification program. By crediting the SLC system to meet the requirements of 10 CFR 50.67, the SLC system was also required to meet the requirements of 10 CFR 50.49.
The licensee became aware of and has been tracking this issue since April 22, 2021, as documented in condition report CR-GGN-2021-03154. The licensee does not have a completed environmental qualification assessment report for the SLC as of September 30, 2024.
Condition report CR-GGN-2021-01792 documents that the SLC pumps installed at GGNS are not currently in the environmental qualification (EQ) program at GGNS. As documented in CR-GGN-2021-03154, the licensee has confirmed the explosive squib valves, motor-operated valves, and pump motors for the standby liquid control system could meet the environmental qualification requirements. Through additional discussions with the licensee, the inspectors determined the entire system does not currently meet the environmental qualification requirements. Additionally, the licensee does not possess an auditable record of qualification as required by 10 CFR 50.49(j). The inspectors identified the following items that do not meet the environmental qualification requirements:
- SLC storage tank level transmitter 1C41N001, as documented in CR-GGN-2023-15115
- SLC system containment penetration cable boxes 1Z011 and 1Z039, as documented in CR-GGN-2024-02657
- SLC system control panel 1H22P011, as documented in CR-GGN-2024-04681
- SLC system cable splicing needs to be performed in accordance with environmental qualification requirements as documented in CR-GGN-2024-02888.
Corrective Actions: The license entered this issue into their corrective action program.
Corrective Action References: CR-GGN-2024-05513
Performance Assessment:
Performance Deficiency: Title 10 CFR 50.49 requires that electric equipment important to safety must be qualified. The inspectors determined that the licensees failure to environmentally qualify the electric equipment of the standby liquid control system was reasonably in the licensees ability to foresee and correct and therefore a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the 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 licensee failed to ensure the installed configuration of the SLC system was environmentally qualified in order to perform its safety functions.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using exhibit 2, Mitigating Systems Screening Questions, the inspectors determined this finding to be of very low safety significance (Green) because it was a deficiency affecting the design or qualification of equipment, but the equipment maintained its probabilistic risk assessment functionality.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 CFR 50.49, Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants, section (f), requires that each item of electric equipment important to safety must be qualified by one of the following methods:
1. Testing an identical item of equipment under identical conditions or under similar
conditions with a supporting analysis to show that the equipment to be qualified is acceptable.
2. Testing a similar item of equipment with a supporting analysis to show that the
equipment to be qualified is acceptable.
3. Experience with identical or similar equipment under similar conditions with a
supporting analysis to show that the equipment to be qualified is acceptable.
4. Analysis in combination with partial type test data that supports the analytical
assumptions and conclusions.
Contrary to the above, since March 14, 2001 to September 30, 2024, the licensee failed to qualify an item of electrical equipment important to safety, the SLC system, by one of the following methods:
1. Testing an identical item of equipment under identical conditions or under similar
conditions with a supporting analysis to show that the equipment to be qualified is acceptable.
2. Testing a similar item of equipment with a supporting analysis to show that the
equipment to be qualified is acceptable.
3. Experience with identical or similar equipment under similar conditions with a
supporting analysis to show that the equipment to be qualified is acceptable.
4. Analysis in combination with partial type test data that supports the analytical
assumptions and conclusions.
Specifically, the licensee has not qualified the SLC system, a system important to safety, by a method as described in 10 CFR 50.49.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Take Timely Corrective Action for Inoperable Drywell Air Cooler Condensate Flow Monitoring Instrumentation Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000416/2024003-02 Open/Closed
[H-14] -
Conservative Bias 71152A The inspectors identified a finding and associated Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly correct a condition adverse to quality. Specifically, since September 12, 2020, the drywell air cooler condensate flow monitoring system has become inoperable during the three most recent operating cycles due to clogging of the common drain line. The licensee has performed cleaning and flushing of the line repeatedly that has not resulted in resolution of this condition adverse to quality. The licensee has an engineering change proposed, but the change has not been implemented since a notice of unusual event was declared for this issue on January 7, 2021.
Description:
On September 12, 2020, operators identified that recorder 1E31R609, the drywell air cooler condensate flow monitoring system, was reading downscale. Operators declared the associated system inoperable and entered Technical Specification (TS) Action Statement 3.4.7, C1, which required a channel check of the drywell particulate and airborne radioactivity monitors to be performed at least once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This issue was documented in CR-GGN-2020-09741 as a suspected line blockage based on site operating experience.
On October 28, 2020, after performing a channel check and other observations of the system, operations personnel declared the system to be operable and exited TS 3.4.7.C.1. During a subsequent forced outage, technicians flushed the drywell air cooler condensate drain line under work order WO 550987 and identified some sludge and a lot of algae in the line.
Technicians continued to flush the line until it ran clear.
On December 21, 2020, operators identified a step change increase in drywell unidentified leakage rate from an average of approximately 0.10 gallon per minute (gpm) to 2.93 gpm, which slowly began trending back down to normal. The issue was entered into the corrective action program as CR-GGN-2020-12316. Operators determined that no degraded or nonconforming condition existed, and the licensee closed the condition report with no specific actions taken because, it alone [did] not represent a condition requiring correction within the corrective action process.
On January 7, 2021, unidentified leakage increased from a nominal 0.13 gpm to approximately 16 gpm and remained elevated for over 15 minutes. Operators declared a notification of unusual event (NOUE), but did not identify any reactor or containment parameters indicative of a reactor coolant system leak. The inspectors independent assessment concurred with the licensees in that the cause was most likely that an obstruction in the drywell cooler condensate drain line system had become dislodged, allowing approximately 220 gallons of water to enter the drywell floor sump in a relatively short period of time.
The licensee initially considered the drywell cooler condensate drain line flow monitoring system to be operable after the obstruction cleared. Additionally, as discussed in Updated Final Safety Analysis Report, Section 7.6.2.4.2.1, the system design basis was to monitor for unidentified leakage with a sensitivity of detecting a 1 gpm leak within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The inspectors were concerned that with at least three recent cases of obstructions in the system and the uncertainty of whether an obstruction still existed, there was reasonable doubt of whether the system could perform its intended function of detecting a leak of at least 1 gpm. After discussions with the licensee, operators declared the drywell cooler condensate drain line flow monitoring system inoperable on January 22, 2021, and entered TS Action Statement 3.4.7, C1.
During the refueling outage of March 2022, the licensee again cleaned and flushed the drain lines as part of corrective actions documented in CR-GGN-2021-00133. The drip pans for all six drywell coolers were cleaned, the drain lines were flushed, and a function flow test was completed as documented in corrective action (CA) 15 for CR-GGN-2021-00133 closeout. Additional CA-13 generated an engineering change (EC) to identify design changes to prevent recurrence of the blocked drain lines. These engineering changes have not been implemented as of September 30, 2024.
On October 25, 2023, the licensee documented in CR-GGN-2023-16456, that the drywell air cooler condensate flow monitoring system had become inoperable due to clogging. The licensee entered TS Action Statement 3.4.7, C1 due to the system inoperability. As part of previous corrective actions, the licensee intended to implement work order WO 54093407 for EC 540993401 during the 2024 spring refueling outage to implement drain line modifications.
The licensee did not execute this EC and related WO during the 2024 refueling outage.
On July 22, 2024, during a tour of the control room, the inspectors observed the 1E31R609 reading downscale, indicating potential clogging of the drywell air cooler drain line and inoperability of the air cooler condensate flow monitoring system as documented in CR-GGN-2024-04234. The monitor did return to scale, but subsequently failed downscale again resulting in the licensee declaring the drywell air cooler condensate flow line being inoperable. The licensee entered TS Action Statement 3.4.7, C1, which required a channel check of the drywell particulate and airborne radioactivity monitors to be performed at least once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This clogging condition of the drywell cooler condensate drain line has resulted in the inoperability of the drywell air cooler condensate flow monitoring system for the past 3 operating cycles, a condition adverse to quality.
Corrective Actions: The licensee initiated a condition report to enter this item into the corrective action program.
Corrective Action References: CR-GGN-2024-05512
Performance Assessment:
Performance Deficiency: Title 10 CFR Part 50, Appendix B, Criterion XVI, requires that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. The inspectors determined that the licensees failure to promptly correct clogging of the drywell air cooler common drain line resulting in the condensate flow monitoring system becoming inoperable, a condition adverse to quality, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the performance deficiency contributed to the inoperability of the system.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding impacted initiating events and used exhibit 1 to evaluate the condition. The finding was determined to be of very low safety significance (Green)because it did not result in an event that would exceed the reactor coolant system leak rate for a small loss of coolant accident (LOCA), and did not affect other systems used to mitigate a LOCA.
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals 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 licensee did not take a conservative approach to implement a corrective action for a condition which resulted in an inoperable technical specification instrument.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, from September 12, 2020, to September 30, 2024, a condition adverse to quality was not promptly corrected. Specifically, since September 12, 2020, the drywell air cooler condensate flow monitoring system has become inoperable during the three most recent operating cycles due to clogging of the common drain line. The licensee has performed cleaning and flushing of the line repeatedly that has not resulted in resolution of this condition adverse to quality. The licensee has an engineering change proposed, but the change has not been implemented since an NOUE was declared for this issue on January 7, 2021.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 9, 2024, 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
Corrective Action
Documents
CR-GGN-YYYY-
NNNNN
24-05115, 2024-05116
Corrective Action
Documents
CR-GGN-YYYY-
NNNNN
21-08369, 2022-00272, 2022-04694, 2022-10231, 2023-
01952, 2024-03818, 2024-04637
Corrective Action
Documents
CR-GGN-YYYY-
NNNNN
24-05349, 2024-05350, 2024-05351, 2024-05352
Corrective Action
Documents
CR-GGN-YYYY-
NNNNN
2005-02356, 2005-02520, 2009-05678, 2011-01868
Fuse Control
Procedures
Maintenance Configuration Control
Work Orders
WO 454699, 52936726, 54161585
Corrective Action
Documents
CR-GGN-YYYY-
NNNNN
24-04020
Corrective Action
Documents
CR-GGN-YYYY-
NNNNN
21-03154, 2024-03659, 2024-04405, 2024-05134, 2024-
05355
Procedures
Operability Determination Process
Corrective Action
Documents
CR-GGN-YYYY-
NNNNN
24-04047, 2024-04125, 2024-04405, 2024-04411, 2024-
05027, 2024-04020, 2024-04124, 2024-04148, 2024-04307,
24-04332, 2024-04453, 2024-04590, 2024-04700, 2024-
04798, 2024-04874, 2024-04988, 2024-05073, 2024-05146,
24-05318
06-OP-1P81-R-
0001
HPCS Diesel Generator Functional Test, Test No. 4, Loss of
offsite power and reject of largest load test
139
Procedures
Boiling Water Reactor Drywell Leakage
Work Orders
WO 454699, 507876, 590030, 591602, 53019005, 54132635,
54140910, 54143900, 54160082
Corrective Action
Documents
CR-GGN-YYYY-
NNNNN
24-05119, 2024-05121, 2024-05221