IR 05000416/2024004
| ML25041A106 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 02/13/2025 |
| From: | Douglas Dodson NRC/RGN-IV/DORS/PBC |
| To: | Kapellas B Entergy Operations |
| References | |
| EPID I-2024-004-0011 IR 2024004 | |
| Preceding documents: |
|
| Download: ML25041A106 (1) | |
Text
February 13, 2025
SUBJECT:
GRAND GULF NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000416/2024004 AND NOTICE OF VIOLATION
Dear Brad Kapellas:
On December 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Grand Gulf Nuclear Station. On January 14, 2025, the NRC inspectors discussed the results of this inspection with Grant Flynn, General Manager of Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.
The enclosed report discusses a violation associated with a finding of very low safety significance (Green). This violation was evaluated in accordance with the NRC Enforcement Policy, which can be found on the NRC website 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 subject inspection report (Enclosure 2). The NRC determined that this violation did not meet the criteria to be treated as a non-cited violation (NCV) because Entergy Operations, Inc. failed to restore compliance within a reasonable period after the violation was identified, consistent with Section 2.3.2 of the NRC Enforcement Policy.
Additionally, 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 an NCV consistent with Section 2.3.2 of the Enforcement Policy.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
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 enclosures, and your response will be made available electronically for public inspection from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC website 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 (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Douglas E. Dodson II, Chief Reactor Projects Branch C Division of Operating Reactor Safety Docket No. 05000416 License No. NPF-29 Enclosure 1: Notice of Violation Enclosure 2: Inspection Report 05000416/2024004 cc w/ encl: Distribution via LISTSERV Signed by Dodson, Douglas on 02/13/25
SUNSI Review By: NJM X
Non-Sensitive
Sensitive X
Publicly Available
Non-Publicly Available OFFICE SRI:DORS:PBC TL:ACES BC:DRSS:DIOR D:DRSS BC:DORS:PBC NAME ASmallwood BAlferink JJosey JGroom DDodson SIGNATURE
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DATE 02/10/25 02/12/25 02/11/25 02/12/25 02/13/25
Enclosure 1 NOTICE OF VIOLATION Entergy Operations, Inc.
Docket No.: 05000416 Grand Gulf License No.: NPF-29 During an NRC inspection conducted from November 18, 2024, to December 3, 2024, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
Title 10 CFR 20.1501(c) requires that the licensee shall ensure that instruments and equipment used for quantitative radiation measurements (e.g., dose rate and effluent monitoring) are calibrated periodically for the radiation measured.
Contrary to the above, from at least April 2018 to December 2, 2024, the licensee failed to ensure that instruments and equipment used for quantitative radiation measurements (e.g., dose rate and effluent monitoring) were calibrated periodically for the radiation measured. Specifically, the licensee failed to periodically calibrate and maintain the drywell personnel airlock area radiation monitor (ARM) in accordance with 10 CFR 20.1501(c).
This violation is associated with a Green Significance Determination Process finding.
Pursuant to the provisions of 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, Region IV, and a copy to the NRC resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation 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, an order or a Demand for Information may be issued as to why the 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, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or safeguards 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 withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (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). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days of receipt.
Dated this 13th day of February 2025
Enclosure 2 U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number:
05000416
License Number:
Report Number:
Enterprise Identifier:
I-2024-004-0011
Licensee:
Entergy Operations, Inc.
Facility:
Grand Gulf Nuclear Station
Location:
Port Gibson, MS
Inspection Dates:
October 1 to December 31, 2024
Inspectors:
B. Baca, Health Physicist
L. Carson, Senior Health Physicist
G. Kolcum, Senior Resident Inspector
R. Kopriva, Senior Project Engineer
J. Melfi, Project Engineer
A. Smallwood, Senior Resident Inspector
Approved By:
Douglas E. Dodson II, 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
Failure to Periodically Calibrate Area Radiation Monitors Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NOV 05000416/2024004-01 Open
[H.5] - Work Management 71124.05 The inspectors identified a Green finding and associated cited violation of 10 CFR 20.1501(c)for the licensees failure to ensure that instruments and equipment used for quantitative radiation measurements (e.g., dose rate and effluent monitoring) are calibrated periodically for the radiation measured. Specifically, the licensee failed to periodically calibrate and maintain area radiation monitor SD21K649, drywell personnel airlock monitor.
Failure to Properly Check Fuse Holder Integrity Leading to Standby Service Water Cooling Tower Fan Inoperability Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000416/2024004-02 Open/Closed
[P.5] -
Operating Experience 71152A A self-revealed Green finding and associated non-cited violation of Technical Specification 5.4.1.a was identified for the licensees failure to properly pre-plan maintenance as required by Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2. Specifically, procedure 07-S-12-51, Inspection and Cleaning of 480 Volt ITE Load Centers and Transformers, Revision 9, did not provide an adequate level of detail required to ensure proper installation of control power fuses to prevent the cooling tower fans for standby service water division 2 from unexpectedly becoming inoperable on two occasions.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000416/2023-002-00 Reactor Scram Due to Generator Stator Fault to Ground 71153 Closed LER 05000416/2024-001-00 High Pressure Core Spray Inoperable Due to Minimum Flow Valve Failure to Close 71153 Closed
PLANT STATUS
At the beginning of the inspection period Grand Gulf Nuclear Station (GGNS), Unit 1, was operating at 100 percent rated thermal power (RTP). On November 10, 2024, a reactor SCRAM was manually inserted by the operators due to a loss of seal steam controller power that led to degraded condenser vacuum. The unit was restarted on November 14, 2024, and a manual SCRAM was manually inserted at approximately 4 percent RTP by operators due to issues with the offgas system. The unit was again started on November 21, 2024, and achieved 100 percent RTP on November 24, 2024. On December 27, 2024, the station initiated a rod pattern sequence exchange, which included a power reduction to 70 percent RTP. The unit returned to 100 percent RTP on December 28, 2024. On December 29, 2024, large storms damaged power distribution lines near Franklin, MS. As a result of the damage to the electrical grid system, the grid operator requested GGNS to lower power to 88 percent RTP, 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
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)high-pressure core spray post-maintenance on October 24, 2024 (2)division 3 engineered safety feature diesel generator jacket water and lube oil cooler on November 21, 2024 (3)standby service water division 1 residual heat removal pump seal cooler on December 18, 2024
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the 15AA division 1 engineered safety feature electrical bus system on December 16, 2024.
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)1A308 electrical switchgear room, 139-foot elevation in the auxiliary building, on October 29, 2024 (2)standby service water pump house, division 1, on November 14, 2024 (3)1A104 hot machine shop, 93-foot elevation in the control building, on November 21, 2024 (4)upper cable spreading room, 189-foot elevation in the control building, on December 10, 2024 (5)division 3 switchgear area, 111-foot elevation in the control building, on December 18, 2024
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspector reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered from September 2 through October 10, 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 reactor startup on November 20, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator requalification simulator scenario on November 19, 2024.
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)high-pressure core spray relay 17AC-181 failure review completed on December 11, 2024
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSCs remain capable of performing their intended functions:
(1)divisions 1 and 2 engineered safety feature diesel generator inlet and outlet valves, Condition Report (CR)-2024-05645, on November 22, 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)verification of high-pressure core spray system during reactor core isolation cooling quarterly testing on December 20, 2024 (2)rod pattern sequence exchange risk mitigating actions on December 28, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) CR-GGN-2024-05750, reactor core isolation cooling room cooler acid flushing review completed on October 24, 2024
- (2) CR-GGN-2023-06693, division 1 standby diesel generator lube oil temperature review completed on December 28, 2024
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) (7 Samples)
- (1) Work Order (WO) 53021895, high-pressure core spray pump trip during surveillance post-maintenance retest review completed on October 17, 2024
- (2) WO 54014592, division 1 engineered safety feature standby diesel generator governor oil change review completed on December 11, 2024
- (3) WO 53010790, main steam isolation valve B21-F022A packing adjustment review completed on December 12, 2024
- (4) WO 541651600, residual heat removal division 1 pump seal cooler cleaning review completed on December 17, 2024
- (5) WO 54201597, control rod drive division 1 check valve replacement review completed on December 18, 2024
- (6) WO 00594423, standby liquid control squib valve splicing environmental qualification review completed on December 20, 2024
- (7) WO 00559060, division 1 control room air conditioning water pressure control valve, SZ51F073A, PMT review completed on December 23, 2024
Surveillance Testing (IP Section 03.01) (2 Samples)
- (1) WO 54181297, control rod block functional test review completed on November 13, 2024
- (2) WO 54014592, task 6, division 1 engineered safety feature diesel generator monthly run review completed on December 9, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) WO 54169052, residual heat removal division 1 valve stroke times and pump inservice testing review completed on December 18, 2024
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (1 Sample)
The inspectors evaluated:
- (1) Green and Blue team turnover drill at the backup emergency operations facility on October 15,
RADIATION SAFETY
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (9 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
(1)alpha proportional counter, liquid scintillation, and high purity germanium detectors in the chemistry count room (2)area radiation monitors in the auxiliary, fuel, radwaste, and reactor buildings
- (3) ARGOS-5AB personal contamination monitors and gamma exit monitors (GEM-5 portal monitors) at the radiologically controlled area egress (4)friskers stationed in the auxiliary, fuel, and radwaste building for smear counting and other surveys (5)gaseous effluent monitors (1D17K601, 1D17K617, 1D17K620, 1D17P020, 1D17P021, 1D17P022)
- (6) GEM-5 portal monitors at the protected area egress (7)liquid effluent (117K606) monitor (8)portable instruments stored for use at the radiologically controlled area such as ion chambers, friskers, telepoles, and AMS-4 continuous air monitors (9)selected self-reading (electronic alarming) dosimeters staged for use at the radiologically controlled area entry
Calibration and Testing Program (IP Section 03.02) (14 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
(1)alpha Gamma Products model G5020-C, #070901, dated April 28, 2021
- (2) AMP-100, CHP-ARM025, dated November 20, 2024, and AMP-200, CHP-ARM114, dated February 20, 2024
- (3) Canberra iSolo, CHP-C-046, dated January 4, 2024 (4)containment high range area monitors: 1D21-K648B, WO 52984316-01 dated June 20, 2023, and 1D21-K648C WO 52977211-01, dated June 21, 2023
- (5) CRONOS tool and equipment monitors: CRONOS-001 dated September 24, 2024, and CRONOS-003 dated June 11, 2024 (6)drywell high range area monitors: 1D21-K648A WO 00582007-01 dated December 24, 2023, and 1D21-K648D, WO 00582008-01, dated December 21, 2023 (7)gamma exit monitors (GEM-5) portal monitors: GEM003 dated June 11, 2024, GEM008 dated June 11, 2024, and GEM009 dated July 1, 2024 (8)high purity germanium detectors: #2, serial number P13804B, dated October 22, 2022, and #3, serial number 47-P50390B, dated January 9, 2024
- (9) Ludlum 12-4 Remball: CHP-N-014 dated August 30, 2024, and CHP-MF-136 dated January 10, 2024
- (10) Ludlum 177: CHP-CR-084 dated January 8, 2024, CHP-CR-114 dated September 3, 2024, and CHP-CR-198 dated January 8, 2024
- (11) Ludlum 3030: CHP-C-043 dated February 14, 2024, and CHP-C-063 dated January 3, 2024
- (12) Ludlum 9-3 ion chambers: CHP-DR-499 dated February 14, 2024, and CHP-DR-711 dated February 1, 2024
- (13) Mirion DMC-3000 self-reading (electronic alarming) dosimeters: #983461 dated November 6, 2023, #A065AB dated February 6, 2024, #A0C1E9 dated November 28, 2023, and #A15E47 dated January 3, 2024 (14)wide range telepoles: CHP-TEL052 dated February 15, 2024, CHP-TEL147 dated September 4, 2024, and CHP-TEL167 dated August 1, 2024 Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
(1)turbine building ventilation (1D17-K620) under WO 53035699-01 dated May 2, 2024 (2)plant service water (1D17-A-1024) under WO 54065270-01 dated October 2, 2024
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01)
The inspectors evaluated the licensees performance in controlling, labeling and securing the following radioactive materials:
- (1) Sources92-583, Cs-137 and Source 92-588, Cs-137 located at the central calibration facility near GGNS
- (2) Source 93-088, Cs-137 located at the radiation protection unit-2 count room
- (3) The inspectors walked down areas of the behind the radwaste building yard, the Unit 2 turbine building area, the Unit 2 warehouse, the north laydown yard, sea land row, ISFSI, low-level waste, and Part-37 mausoleum storage facility.
Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)
The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:
(1)the radwaste control area for the resin drying processing system (2)the waste compactor and the mobile solidification system
Waste Characterization and Classification (IP Section 03.03) (2 Samples)
The inspectors evaluated the following characterization and classification of radioactive waste:
(1)2022 and 2024 10 CFR 61 waste stream analysis for dry active waste (2)2022 and 2024 10 CFR 61 waste stream analysis for condensate polisher - A
Shipping Records (IP Section 03.05) (5 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
- (1) GGNS-2024-0052, dewatered resin, GDP, UN 3321, LSA-II
- (2) GGNS-2024-0106, irradiated hardware, Type B(U), Class - C, UN 2916, Fissile Excepted
- (5) GGNS-2024-0122, UN 2916, Radioactive Material, Type-B(U), Irradiated Hardware
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, 2023, through September 30, 2024
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
- (1) October 1, 2023, through September 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)high-pressure core spray pump breaker high frequency relay failure (2)loss of standby service water cooling tower fans due to a loose fuse clip holder
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program to identify potential trends in condition reports initiated for missing work order documentation that might be indicative of a more significant safety issue.
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reporting determinations to ensure they complied with reporting requirements:
- (1) LER 05000416/2023-002-00, Reactor Scram Due to Generator Stator Fault to Ground (ADAMS Accession No. ML23047A547). The inspectors determined that the cause of the condition described in the LER was not reasonably within the licensee's ability to foresee and correct, and therefore was not reasonably preventable. No performance deficiency nor violation of NRC requirements was identified. This LER is closed.
- (2) LER 05000416/2024-001-00, High Pressure Core Spray Inoperable due to Minimum Flow Valve Failure to Close (ADAMS Accession No. ML24087A196). The circumstances surrounding this LER and non-cited violation are documented in the Inspection Results section of Inspection Report 05000416/2024001. This LER is Closed.
INSPECTION RESULTS
Failure to Periodically Calibrate Area Radiation Monitors Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NOV 05000416/2024004-01 Open
[H.5] - Work Management 71124.05 The inspectors identified a Green finding and associated cited violation of 10 CFR 20.1501(c)for the licensees failure to ensure that instruments and equipment used for quantitative radiation measurements (e.g., dose rate and effluent monitoring) are calibrated periodically for the radiation measured. Specifically, the licensee failed to periodically calibrate and maintain area radiation monitor (ARM) SD21K649, drywell personnel airlock monitor.
Description:
The inspectors reviewed corrective actions associated with non-cited violation (NCV)05000416/2022004-03 from Inspection Report 05000416/2022004 (ADAMS Accession No. ML23026A095), for the licensees failure to periodically calibrate area radiation monitors (ARMs) and identified that the licensee had failed to restore compliance with 10 CFR 20.1501(c). Specifically, the inspectors determined nine ARMs had not been calibrated to restore compliance at the time of inspection. These monitors included: 1D21K604, 1D21K635, SD21K649, 1D21K607, 1D21K618, 1D21K634, SD21K642, 1D21K638, SD21K643.
The affected ARM functions are described in the Grand Gulf updated final safety analysis report (UFSAR), Chapter 12.3.4.1, "Area Radiation Monitoring." This chapter describes one of the ARM roles being to immediately alert plant personnel entering or working in non-radiation or low radiation areas of increasing or abnormally high radiation levels which, if unnoticed, could possibly result in inadvertent over exposures. Additionally, Chapter 12.3.4.1.4 of the UFSAR describes that the ARM system serves to warn plant personal of high radiation levels in various plant areas and is designed to operate unattended detecting and measuring ambient gamma radiation. These are functions that require the detectors to accurately measure the radiological dose rates around them.
In response to NCV 05000416/2022004-03, the licensee calibrated 25 of the initial 34 ARMs identified as not being periodically calibrated. Following the identification of nine ARMs that were still not calibrated during the inspection, the licensee calibrated eight ARMs with one remaining ARM scheduled for calibration during the next refueling outage in 2026. Thus, one ARM remained without a periodic calibration, as required by 10 CFR 20.1501(c). Inspectors noted that the licensee had an opportunity to return to calibrate 1D21K607 during the refueling outage from February through April 2023. The licensee provided no adequate justification as to why these radiation monitors were not previously calibrated at the time of inspection.
Corrective Actions: The licensee entered the issue into the corrective action program to determine appropriate actions to ensure instrument calibrations occur timely and that the not calibrated ARM(s) will be addressed.
Corrective Action References: CR-GGN-2024-06482
Performance Assessment:
Performance Deficiency: The licensee failed to periodically calibrate instruments and equipment used for quantitative radiation measurements (e.g., dose rate and effluent monitoring).
Screening: The inspectors determined the performance deficiency was more-than-minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the licensees program had not periodically calibrated the drywell personnel airlock ARM since the last inspection in 2022 to ensure the instruments and equipment used for quantitative radiation measurements (e.g., dose rate and effluent monitoring) were calibrated periodically for the radiation measured.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix C, Occupational Radiation Safety SDP. The finding was determined to be of very low safety significance (Green) because the finding was not:
- (1) related to as low as is reasonably achievable planning,
- (2) did not involve an overexposure,
- (3) did not involve a substantial potential for overexposure, and
- (4) the ability to assess dose was not compromised.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specially, the licensees process did not coordinate the calibration of nine ARMs within two years, since the last associated inspection occurred, to restore compliance until identified by the inspectors.
Enforcement:
Violation: Title 10 CFR 20.1501(c) requires that the licensee shall ensure that instruments and equipment used for quantitative radiation measurements (e.g., dose rate and effluent monitoring) are calibrated periodically for the radiation measured.
Contrary to the above, from at least April 2018 to December 2, 2024, the licensee failed to ensure that instruments and equipment used for quantitative radiation measurements (e.g.,
dose rate and effluent monitoring) were calibrated periodically for the radiation measured.
Specifically, the licensee failed to periodically calibrate and maintain the drywell personnel airlock ARM in accordance with 10 CFR 20.1501(c).
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.
Failure to Properly Check Fuse Holder Integrity Leading to Standby Service Water Cooling Tower Fan Inoperability Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000416/2024004-02 Open/Closed
[P.5] -
Operating Experience 71152A A self-revealed Green finding and associated non-cited violation of Technical Specification 5.4.1.a was identified for the licensees failure to properly pre-plan maintenance as required by Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision
2. Specifically, procedure 07-S-12-51, Inspection and Cleaning of 480 Volt ITE Load Centers
and Transformers, Revision 9, did not provide an adequate level of detail required to ensure proper installation of control power fuses to prevent the cooling tower fans for standby service water division 2 from unexpectedly becoming inoperable.
Description:
On July 6, 2024, station operators received multiple alarms in the control room due to an undervoltage condition on load center 16BB5. This load center supplies power to both of the division 2 standby service water cooling tower fans (safety-related). The licensee declared division 2 standby service water inoperable and entered Technical Specification (TS) 3.7.1, condition D.1, which has an allowed outage time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If the division 2 standby service water system could not be restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the licensee would be required to be in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The licensee determined the failure was associated with the undervoltage relays. The licensee replaced the undervoltage relays, performed post-maintenance testing, and declared the system operable and exited the TS on July 7, 2024.
On July 11, 2024, station operators received the same indications in the control room that an undervoltage condition occurred on load center 16BB5. Subsequent troubleshooting determined the installed relays replaced on July 7, 2024, were not the cause of the undervoltage condition. Further troubleshooting by the licensee on July 12, 2024, determined the 125-volt alternating current (VAC) fuse from the 480 VAC to 125 VAC power transformer that supplies power to the undervoltage relays was loose inside the spring clips of the fuse holder. The licensee identified the loose condition while checking the fuse and hearing the 125 VAC trip relays audibly actuate.
The license performed a causal analysis and identified previous issues related to fuse holders. Condition report (CR)-GGN-2005-02520 documented a reactor protection system half SCRAM when fuse C71-F18K failed. Troubleshooting by the licensee identified relaxed tension of the fuse clip for fuse C71-18P as the primary cause. This condition was identified with the use of thermography that showed a relative temperature increase of 50 degrees Fahrenheit compared to nearby fuses. Age and elevated temperatures were believed to be the cause resulting in the failure of the C71-F18K fuse.
CR-GGN-2011-01868 documented a control power failure on panel 1H22P118 that provides power to the division 3 engineered safety feature (ESF) diesel. The licensee identified a loose fuse holder for fuse FU-8 as the cause of the loss of control power; fuse FU-8 provides control power to the fuel oil pumps for the division 3 ESF diesel.
During the inspectors review of the licensees casual analysis, the inspectors identified an additional issue with a loose fuse holder that was previously documented in CR-GGN-2009-05678. This condition report identified fuse FU-7, which is in the division 3 ESF diesel control panel, as having a loose fuse holder such that the fuse could rotate easily when touched with test leads. This fuse also routes control power to the division 3 ESF diesel fuel oil pumps.
Licensee corrective actions included an evaluation for additional training for maintenance and electrical personnel and briefings for electrical and instrumentation and controls technicians on proper fuse installation and verification of connectivity between the fuse and fuse holder.
The inspectors noted that the apparent cause evaluation (ACE) for CR-GGN-2011-01868 documents that the corrective actions for the event documented in CR-GGN-2009-05678 were ineffective. The ACE states in part that the licensee failed to understand the significance of the loose fuse clip holders and believed the issue was easily fixable and detectable. The licensee also states the corrective actions should have been more robust. Contributing cause number one clearly states the procedure did not contain enough details for checking of loose fuses. The proposed corrective actions for CR-GGN-2011-01868 were intended to correct this previous oversight by updating all surveillance procedures and electrical maintenance procedures as described in corrective actions tasks, CA-11, CA-12 and CA-13. Additionally work planning was tasked with adding steps to every WO associated with high critical components to ensure fuses that are pulled to isolate electrical power are tight upon reinsertion. This step was to include both a performer and verifier.
During refueling outage (RF) 24 in March 2024, the licensee conducted maintenance on load center 16BB5, which supplies power to the division 2 standby service water cooling tower fans. WO 52936726 was performed to clean, inspect, and test load center 16BB5 and its associated transformer. The power transformer is located inside the 16BB5 bus, and the fuses route 125 VAC power from the transformer to the trip relays for the division 2 standby service water cooling tower fans. Maintenance personnel used station Procedure 07-S-12-51, Inspection and Cleaning of 480 Volt ITE Load Centers and Transformers, Revision 9 (a continuous use, quality related procedure), that provided the work instructions to complete the maintenance. Step 5.6
- (4) states, in part, that if fuses were removed in step 5.4.9, then install the power transformer fuses. The inspectors determined that neither WO 52936726 nor station procedure 07-S-12-51 contained quantitative or qualitative acceptance criteria to ensure fuses were tight upon reinstallation and satisfactorily installed. This is contrary to previous corrective actions initiated by the licensee and contrary to licensee and industry operating experience.
The licensees causal analysis concluded the inoperability of the division 2 standby service water cooling tower C and D fans was preventable based on internal and industry operating experience.
The licensee also identified Entergy procedure EN-DC-186, Fuse Control, Revision 4, has guidance on proper fuse installation. Step 5(g) states, in part, that when installing fuses to ensure proper contact and tightness between the fuse and fuse holder. The step further states, in part, to check fuse holder proper fit, free play, spring tension, and to adjust as necessary. Grand Gulf Nuclear Station procedure 07-S-12-51, which was used to complete work performed during RF24, does not include procedure EN-DC-186 as a reference or establish criteria for proper fuse installation. This corporate level procedure is neither in use at Grand Gulf Nuclear Station nor referenced in the maintenance procedures at the station.
The licensee performed an analysis to demonstrate that the standby service water function could be maintained for at least the probabilistic risk assessment mission time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The inspectors did not identify any concerns with this analysis for the subject case.
Corrective Actions: The licensee corrected the loosened fuse clips and conducted a post-maintenance confidence run for the standby service water cooling tower fans as documented in WO 54160082.
Corrective Action References: This issue was entered into the licensees corrective action program as Condition Report CR-GGN-2024-04047.
Performance Assessment:
Performance Deficiency: Failure to properly pre-plan maintenance to correctly reinstall control power fuses was a performance deficiency and represented a violation of TS 5.4.1.a.
Screening: The inspectors determined the performance deficiency was more-than-minor because it was associated with the Procedure Quality 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 (i.e., core damage). Specifically, failing to ensure the correct installation of the control power fuse led to the inoperability of the standby service water cooling tower fans.
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 that this finding is of very low safety significance (Green) because the finding did not represent a deficiency affecting design or qualification of a mitigating structure, system, or component; did not involve the loss of a single-train TS system longer than its TS allowed outage time; did not involve a loss of probabilistic risk assessment (PRA) function of one train of a multi-train system for greater than its TS allowed outage time; did not represent the loss of PRA function of two separate TS systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; did not represent the loss of a PRA system and/or function as defined in the Plant Risk Information e-Book or the licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and did not represent the loss of the PRA function of one or more non-TS trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program for greater than 3 days. Additionally, the finding did not involve external events mitigating systems, the reactor protection system, fire brigade, or flexible coping strategies.
Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and effectively collects, evaluates, and implements relevant internal and external operating experience in a timely manner. Specifically, the licensee failed to effectively implement and institutionalize fuse clip holder operating experience through changes to processes, procedures, equipment, and training programs, which resulted in the failure to properly pre-plan maintenance to correctly reinstall control power fuses.
Enforcement:
Violation: Technical Specification 5.4.1.a, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in appendix A of NRC Regulatory Guide 1.33, Revision 2. Section 9.a of Appendix A to Regulatory Guide 1.33, requires, in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Contrary to the above, from March 29 to July 12, 2024, maintenance that could affect the performance of safety-related equipment was not properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Specifically, maintenance on load center 16BB5, which supplies power to the division 2 SSW cooling tower fans, was not properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances in that work instructions did not ensure proper fit, free play, spring tension, or adjustment of the fuse clip holder.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Condition Reports Initiated for Missing Work Order Documentation 71152S During routine review of the licensee corrective action condition reports (CRs) and attendance at various licensee meetings and reviews, the inspectors became aware of missing quality assurance records. Specifically, the inspectors noted 13 condition reports documented between July 1 and December 31, 2024, which list 21 work orders that cannot be retrieved in licensee electronic systems. The licensee has conducted physical searches for paper copies of the work orders, and the work orders have not been located.
The inspectors conducted independent electronic database searches and requested additional information about the missing work orders to assess this trend. The inspectors noted that almost none of the information on system identifiers or scope was available. The inspectors learned through interviews with station personnel that software issues or misplaced physical works orders were potential causes of the missing information. The inspectors also noted that issues with printing, editing, and updating work order status have also been documented in CRs during the inspection period. Finally, the inspectors noted that most of the 21 WOs that are missing are only identifiable by work order number and are not currently retrievable.
Some of the missing work orders had potential to impact the Mitigating Systems cornerstone objective. Specifically, one of the missing work orders was associated with work on the standby liquid control system, a system designed to mitigate an anticipated transient without a SCRAM, as described in 10 CFR 50.62. The standby liquid control system is also credited with protecting against an accident source term event as described in 10 CFR 50.67.
Additionally, two work orders were related to fire protection equipment that is designed to mitigate external threats due to fire.
The inspectors noted that the failure to maintain sufficient records represented a minor performance deficiency associated with the Mitigating Systems cornerstone and was violation of Title 10 CFR Part 50, Appendix B, Criterion XVII, Quality Assurance Records. The inspectors determined the performance deficiency was minor because it did not adversely impact a cornerstone objective, could not be reasonably viewed as a precursor to a more significant event, and if left uncorrected, would not have the potential to lead to a more significant safety concern.
Title 10 CFR Part 50, Appendix B, Criterion XVII, Quality Assurance Records, states, in part that, records shall be identifiable and retrievable. Contrary to the above, from July 1, 2024, to December 31, 2024, records were not identifiable and retrievable. Specifically, 21 work orders referenced in 13 CRs were not identifiable and retrievable. The licensee entered inspector observations and the minor violation in the corrective action program as CR-GGN-2025-00060 to restore compliance. This failure to comply with 10 CFR Part 50, Appendix B, Criterion XVII, constitutes a minor violation that 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 December 3, 2024, and January 8, 2025, the inspectors presented the public radiation safety inspection results to Brad Kapellas, Site Vice President, and other members of the licensee staff.
- On January 14, 2025, the inspectors presented the integrated inspection results to Grant Flynn, General Manager of 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-YYYY-
NNNNN
23-02170, 2023-14032, 2023-14626, 2023-15297, 2024-
2430, 2024-04747, 2024-04876
NDE Reports
G-BOP-UT-24-
2
RHR B Gas Void - 139 ft. RHR Bravo Pipe Pen Room
2/10/2024
Procedures
06-OP-1E12-Q-
23
LPCI/RHR Subsystem A Quarterly Functional Test
145
Work Orders
Corrective Action
Documents
CR-GGN-YYYY-
NNNNN
23-02495, 2023-02499, 2023-15564, 2023-17515, 2024-
213
Miscellaneous
Grand Gulf Annual Requalification Results - Table 03.03-1
Examination Results
10/28/2024
Corrective Action
Documents
CR-GGN-YYYY-
NNNNN
23-14155, 2023-14194, 2023-14196, 2023-14202, 2024-
05372
Work Orders
WO 2947810, 53019673
Procedures
EN-OP-115-14
Reactivity Management
Corrective Action
Documents
CR-GGN-YYYY-
NNNNN
24-05750, 2024-06693
Work Orders
Corrective Action
Documents
CR-GGN-YYYY-
NNNNN
23-14194, 2023-14196, 2024-00259, 2024-01330, 2024-
04995, 2-24-05196, 2024-05318, 2024-05335, 2024-05645,
24-06365
06-OP-1C11-V-
0012
RPC Rod Block Functional Test
101
Procedures
06-OP-1P75-
M0001
Standby Diesel Generator 11 Functional Test Safety Related
151
Work Orders
WO 00559060, 00580572, 00594423, 53021865, 53100790,
54011818, 54014592, 54138682, 54157311, 54161600,
54169052, 54201597
Corrective Action
Documents
CR-GGN-
22-06027, 2022-08509, 2023-01194, 2023-01878, 2023-
13414, 2023-14038, 2023-14553, 2023-14567, 2023-16205,
23-16269, 2023-16450, 2024-00974, 2024-01414, 2024-
2504, 2024-02820, 2024-03213, 2024-03341, 2024-03376,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
24-03589, 2024-04800, 2024-04846, 2024-05020, 2024-
05131, 2024-05714
Corrective Action
Documents
Resulting from
Inspection
CR-HQN-
24-01200
Calibration of the Mirion FASTSCAN' WBC System
07/12/2024
23-B2.28-
SRCVER-0009
Source Verification: MODEL-89 (400) (SRC1993003)
10/23/2023
24-B2.28-
LABSTN-00001
V-570 Meter No. 3587M
04/04/2024
24-B2.28-
SRCVER-0001
Source Verification: MODEL-89 (400) (SRC1993001)
01/09/2024
24-B2.28-
SRCVER-0006
IDC-3000 Calibrator Calibration Report (SN: 161201)
05/13/2024
Miscellaneous
NUPIC Audit No.
25374
Fluke Biomedical (Fluke Electronics) Company: 10/16/2023
thru 10/20/2023
06-IC-1 D21-R-
1002
Containment/Drywell High Range Area Radiation Monitor
Calibration
113
06-IC-1D21-R-
1002
Containment/Drywell High Range Area Radiation Monitor
Calibration
114
Equipment Important to Emergency Response (EITER)
EN-EP-202-02
Operation and Calibration of the Canberra GEM-5
Operation and Calibration of the CRONOS Contamination
Monitor
EN-RP-317-03
Operation and Calibration of Sources and Laboratory
Standard Instruments
EN-RP-317-04
Calibration of Portable Area Radiation Monitors
EN-RP-317-05
Calibration of Extendable Dose Rate Instruments
EN-RP-317-07
Calibration of Portable Count Rate Instruments
Procedures
EN-RP-317-08
Calibration of Portable Scalers
Self-Assessments LO-GLO-2021-
00090
Self-Assessment for Pre-NRC Inspection: Radiation
Monitoring Instrumentation Assessment (IP 71124.05)
08/19/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
QA-14/15-2023-
GGNS-01
Combined Radiation Protection (RP) and Radwaste (RW):
September 25, 2023, to December 07, 2023
Work Orders
00553077-01, 52947307-01, 54025262-03,
CR-GGN-
22-02333, 2022-02663, 2022-03542, 2022-09390, 2022-
09835, 2022-10698, 2022-11272, 2023-01077, 2023-14031
Corrective Action
Documents
CR-HQN-
24-01019
CR-GGN
24-06265, 06285, 06669, 06745
Corrective Action
Documents
Resulting from
Inspection
CR-HQN
24-01270
01-S-02-9
Radwaste Operations
08-S-01-25
Radiation Protection Procedure Radwaste Resin Transfer
08-S-01-94
Processing of Type A and Type B Radioactive Waste
Shipments
08-S-06-50
Loading Radioactive Material
08-S-06-71
Sampling Procedures for Waste Classification
11-S-21-6
Procedure of Category 1 and Category 2 Quantities of
Radiological Material
Radioactive Material Control
EN-RP-121-01
Receipt of Radioactive Material
Radioactive Waste Management
Radioactive Shipping Procedure
Radioactive Waste Tracking Procedure
Scaling Factors
Integrated Transportation Security Plan
Procedures
Radioactive Shipment Accident Response
Mausoleum Survey
08/23/2023
Ir-192 Radiography Source Receipt
03/07/2022
133 OS RAM LP Rotor Storage Area NW
07/23/2024
RAM Class A Storage Pad
Neutron Source Box
11/19/2024
Radiation
Surveys
Unit-2 RCA Exit Elevation 133'
11/19/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
23-00095
ORSC - Review of ES Dewatering Equipment
07/11/2023
LO-GLO-2023-
00042
Self-Assessment Pre-NRC Inspection Module 71124-08
08/24/2024
Self-Assessments
QA-GGNS-14/15-
23-01
Combined Radiation Protection and Radwaste Audit
2/11/2023
GGNS-2024-
0052
UN 3321, radioactive material, Low Specific Activity II (LSAII)
7, Condensate Polisher System (CPS) Resin
GGNS-2024-
0073
RWCU - UN A 2916, powdex resin, Type B(U), Class - C,
Fissile Excepted RQ
GGNS-2024-
0106
UN 2916, Irradiated Hardware, Type B(U), Class - C, Fissile
Excepted
GGNS-2024-
0119
UN 3321 Condensate Polisher System - APS resin, GDP,
Radioactive LSA-II
Shipping Records
GGNS-2024-
22
UN 2916, Radioactive Material, Type-B(U), Irradiated
Hardware
Corrective Action
Documents
Condition Report
(CR-)
2005-02356, 2005-02520, 2009-05678, 2011-01868, 2024-
04047, 2024-04125
07-S-12-51
Inspection and Cleaning of 480V ITE Load Centers and
Transformers
Procedures
Fuse Control
Work Orders
WO 2936726, 54160082, 54161585
Corrective Action
Documents
CR-GGN-YYYY-
NNNNN
24-04341, 2024-04348, 2024-04368, 2024-04394,
24-04419, 2024-04887, 2024-04911, 2024-04912,
24-04913, 2024-04917, 2024-05026, 2024-06543,
24-06756