IR 05000416/2024302
| ML25092A251 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 04/07/2025 |
| From: | Heather Gepford NRC/RGN-IV/DORS/OB |
| To: | Kapellas B Entergy Operations |
| References | |
| 50-416/24-302 | |
| Download: ML25092A251 (1) | |
Text
April 07, 2025
SUBJECT:
GRAND GULF NUCLEAR STATION - NRC EXAMINATION REPORT 05000416/2024302
Dear Brad Kapellas:
On January 31, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an initial operator license examination at Grand Gulf Nuclear Station, Unit 1. The enclosed report documents the examination results and licensing decisions. The preliminary examination results were discussed on February 19, 2025, with you and other members of your staff. A telephonic meeting was conducted on March 19, 2025, with Anthony Watson, Ops Training Supervisor, who was provided the NRC licensing decisions. A final exit meeting was conducted with Ryan Meyers, Operations Director, on March 25, 2025.
The examination included the evaluation of six applicants for reactor operator licenses, three applicants for instant senior reactor operator licenses, and three applicants for upgrade senior reactor operator licenses. The license examiners determined that seven of the twelve applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued.
There were no post-examination comments submitted by your staff. The enclosure contains details of this report.
There was one finding identified during this examination. This finding is of very low safety significance (Green) and is documented in this report. This finding involves a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation 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 the 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Heather J. Gepford, Ph.D., Chief Operations Branch Division of Operating Reactor Safety Docket No. 05000416 License No. NPF-29 Enclosure:
Examination Report 05000416/2024302 Attachment 1: Simulator Fidelity Report Electronic Distribution via LISTSERV Signed by Gepford, Heather J.
on 04/07/25
ML25092A251 SUNSI Review:
ADAMS:
Non-Publicly Available Non-Sensitive Keyword:
By: KDC Yes No Publicly Available Sensitive NRR-079 OFFICE OE:DORS/OB OE:DORS/OB OE:DORS/OB SOE:DORS/OB BC:DORS/OB NAME DYou CHarrington KMurphy KClayton HGepford SIGNATURE
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DATE 04/03/25 04/03/25 04/04/25 04/03/25 04/07/25
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Examination Report Docket Number:
05000416 License Number:
NPF-29 Report Number:
05000416/2024302 Enterprise Identifier:
L-2024-OLL-0048 Licensee:
Entergy Operations, Inc.
Facility:
Grand Gulf Nuclear Station, Unit 1 Location:
Port Gibson, Mississippi Inspection Dates:
January 27, 2025, to March 19, 2025 Inspectors:
K. Clayton, Senior Operations Engineer, Chief Examiner K. Murphy, Operations Engineer, Chief Examiner U/I C. Harrington, Operations Engineer D. You, Operations Engineer Approved By:
Heather J. Gepford, Ph.D., Chief Operations Branch Division of Operating Reactor Safety
SUMMARY Examination Report 05000416/2024302; January 27 - March 19, 2025; Grand Gulf Nuclear Station, Unit 1; Initial Operator Licensing Examination Report The NRC examiners evaluated the competency of six applicants for reactor operator licenses, three applicants for instant senior reactor operator licenses, and three applicants for upgrade senior reactor operator licenses at Grand Gulf Nuclear Station, Unit 1.
The licensee developed the examinations using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 12. The written examination was administered by the licensee on February 4, 2025. The NRC examiners administered the operating tests on January 27 - 31, 2025.
The NRC examiners determined that seven of the twelve applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued.
A.
NRC-Identified and Self-Revealing Findings The written examination was determined to be outside of the acceptable quality range as identified in NUREG-1021.
Failure to Establish an Off-Normal Event Procedure for the Loss of Standby Service Water Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000416/2024302-01 Open/Closed
[H.1]
Resources
.2b Examination Development The inspectors identified a Green finding and associated non-cited violation of Technical Specification 5.4.1, Procedures, for the licensees failure to establish written procedures as required by Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation),
revision 2, appendix A, section 6.g. Specifically, GGNS failed to establish written procedures for the loss of safety-related standby service water (SSW).
B.
Licensee-Identified Violations None.
REPORT DETAILS OTHER ACTIVITIES - INITIAL LICENSE EXAMINATION
.1 License Applications a.
Scope The NRC examiners reviewed all license applications submitted to ensure each applicant satisfied relevant license eligibility requirements. The NRC examiners also audited three of the license applications in detail to confirm that they accurately reflected the subject applicants qualifications. This audit focused on the applicants experience and on-the-job training, including control manipulations that provided significant reactivity changes.
b.
Findings No findings were identified.
.2 Examination Development a.
Scope The NRC examiners reviewed integrated examination outlines and draft examinations submitted by the licensee against the requirements of NUREG-1021. The NRC examiners conducted an onsite validation of the operating tests.
b.
Findings The NRC examiners provided outline, draft examination, and post-validation comments to the licensee. The licensee could not satisfactorily complete comment resolution prior to the originally scheduled examination administration dates.
During the outline reviews, the NRC identified a significant amount of repeat material from the NRC 2020 Initial Operator License Exam. This is not allowed by NUREG-1021 for several reasons, including maintaining exam security, minimizing/reducing predictability, ensuring proper development and rotation of all major events, and development of new materials on each exam.
The draft reactor operator (RO) and senior reactor operator (SRO) written examination submittals were determined to be outside of the acceptable quality range specified in NUREG-1021. For the RO portion of the exam, 22 questions (29 percent) were unsatisfactory and required significant modification or replacement. For the SRO portion of the exam, 7 questions (28 percent) were unsatisfactory and required significant modification or were replaced.
Question flaws included extensive cueing, poor stem focus, poor distractors, and questions with a low level of difficulty. Future written examination submittals need to incorporate lessons learned. These written examination submittal deficiencies were captured in the licensees corrective action program as condition report 2025-06058.
During exam validation the week of October 28, 2024, several operating test items were not ready for validation. This included materials that would not run correctly on the simulator or had been incorrectly saved on the simulator. Additionally, an in-plant JPM was located in an inaccessible area in the plant and involved equipment that had been tagged out for years. The operating test submittal deficiencies were captured in the licensees corrective action program as condition report 2025-06058.
After working through these issues, the NRC team concluded that the operating test was not ready for administration. The written examination was also not ready for administration at the conclusion of validation week, as several of the unsatisfactory questions either had not been resolved and/or validated by licensee staff.
Before leaving the site on validation week, the NRC exam team met with the Regulatory Affairs Director and the licensees exam development team to discuss these concerns.
The station agreed that they would not to be ready to administer either the written examination or the operating test the week of December 2, 2024. The station requested and received authorization from the NRC to reschedule the entire exam approximately seven weeks later, with operating test administration dates of January 27-31, 2025, and the written examination administration date of February 4, 2025. The seven-week delay for final resolution of exam comments and validation issues was captured in the licensees corrective action program as condition report 2024-06058.
The licensee satisfactorily completed all comment resolution prior to the newly scheduled exam administration dates.
.3 Operator Knowledge and Performance a.
Scope The NRC examination team administered the various portions of the operating tests to all applicants on January 27-31, 2025.
On February 4, 2025, the licensee proctored the administration of the written examinations to all twelve applicants. The licensee staff graded the written examinations, analyzed the results, and presented their analysis to the NRC on February 12, 2025.
b.
Findings No findings were identified.
Nine of the twelve applicants passed the written examination, and ten of the twelve applicants passed all parts of the operating tests. The final examinations and post-examination analysis may be accessed in the ADAMS system under the accession numbers noted in the attachment. There were no post-examination comments as indicated in the licensee submittal.
The examination team noted two generic weaknesses associated with applicant performance on the administrative job performance measures (JPM) and the dynamic scenario sections of the operating tests:
- Completing an emergency plan protective action recommendation (PAR) during an SRO administrative JPM.
- Diagnosis of a recirculation pump downshift during a dynamic scenario.
Post-examination analysis revealed fourteen generic weaknesses associated with applicant performance on the written examination:
Post turbine trip operation of bleeder trip valves
EOP reentry requirements
LPCS line break detection
SRM bypass switch operation
Recirc flow input to APRMs scram setpoints
Standby gas system differential pressure controls
RCS leakage classification and quantification
Containment spray valve operation
Fuel pool cooling and cleanup pump flow requirements
Area radiation monitor high reset requirements
Secondary containment control EOP actions
Fire pump technical manual requirements
Risk assessment maintenance requirements
Radioactive discharge controls These generic weaknesses were captured in the licensees corrective action program as condition reports 2025-01563 and 2025-01562. Copies of all individual examination reports were sent to the facility training manager for evaluation and determination of appropriate remedial training.
.4 Simulation Facility Performance a.
Scope The NRC examiners observed simulator performance regarding plant fidelity during examination validation and administration.
b.
Findings No findings were identified.
Observations regarding simulator performance issues are captured in Attachment 1, Simulator Fidelity Report, at the back of this report. These issues will be evaluated during the biennial requalification inspection in August of 2025. The associated condition reports are noted in the attachment.
.5 Examination Security a.
Scope The NRC examiners reviewed examination security for examination development during both the onsite preparation week and examination administration week for compliance
with 10 CFR 55.49 and NUREG-1021. Plans for examination security and applicant control were reviewed and discussed with licensee personnel.
b. Findings No findings were identified.
EXAMINATION FINDINGS Failure to Establish an Off-Normal Procedure for the Loss of Standby Service Water Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000416/2024302-01 Open/Closed
[H.1]
Resources
.2b Examination Development The inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification 5.4.1, Procedures, for the licensees failure to establish written procedures as required by Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), revision 2, appendix A, section 6.g. Specifically, GGNS failed to establish written procedures for the loss of safety-related standby service water (SSW).
Description: During the week of October 28, 2024, examiners performed initial licensed operator examination validation using licensed operators from on-shift crews. One dynamic simulator scenario included an event involving the loss of the A SSW pump, which provides cooling to the A drywell purge compressor among other systems. The crews responded to the event using alarm response procedures and related technical specifications only. There was no off-normal event procedure (ONEP) for a loss of SSW.
Four different crews of licensed operators validated this scenario. However, only two of the four crews addressed the A drywell purge compressor operability. Because the A drywell purge compressor is cooled by A SSW, it must be prevented from starting when a lack of cooling from SSW exists to prevent damage to the compressor within a few minutes (if running). This is accomplished by racking out the breaker to the compressor, which makes the compressor inoperable and therefore requires a TS entry. The inspectors determined the difference in operator response to the event existed because the operating crews relied solely on individual operator knowledge to address the condition instead of an approved ONEP for the loss of SSW.
The technical specification bases 3.7.1, "Standby Service Water (SSW) System and Ultimate Heat Sink (UHS), specifies the SSW System is designed to provide cooling water for the removal of heat from unit auxiliaries, such as Residual Heat Removal (RHR) System heat exchangers, standby diesel generators (DGs), and room coolers for Emergency Core Cooling System equipment required for a safe reactor shutdown following a Design Basis Accident (DBA) or transient. Additionally, technical specification bases 3.6.3.3, Drywell Purge System, states that the system ensures a uniformly mixed post-accident containment atmosphere, thereby minimizing the potential for local hydrogen burns due to a pocket of hydrogen above the flammable concentration. The drywell purge compressor also performs the function of diluting the drywell source term within the containment and suppression pool environment by pressurizing the drywell and discharging the drywell source term through the drywell suppression pool vents.
Based on the safety functions performed by these two systems, the inspectors determined that being able to address an event involving these systems, particularly the loss of standby service water, was within the bounds of procedures required by Regulatory Guide 1.33.
Specifically, Regulatory Guide 1.33, appendix A, section 6.g, specifies a loss of service water as an emergency or significant event requiring procedures. GGNS maintains an ONEP for the loss of plant service water (05-1-02-V-11); however, this ONEP provides no guidance for the loss of safety-related standby service water components.
Corrective Actions: Due to examination security concerns, GGNS entered this issue into their corrective action program following the completion of the initial licensed operator examination.
Corrective Action References: CR-GGN-2025-584 Performance Assessment:
Performance Deficiency: The failure to establish written procedures for the loss of SSW in accordance with requirements of technical specification 5.4.1, Procedures, for a system specified by Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation),
revision 2, appendix A, section 6.g, was a performance deficiency.
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 and large early release factors). Specifically, the performance deficiency resulted in two of four crews not entering all the applicable technical specifications or taking actions to protect the safety related A drywell purge compressor during simulator scenario validations with a loss of one division of SSW. This event required the crew to disable the A drywell purge compressor to prevent potential damage to it without SSW cooling available.
Significance: The inspectors assessed the significance of the finding using IMC 0609, appendix A, The Significance Determination Process (SDP) for Findings At-Power, exhibit 2, Mitigating Systems Screening Questions, effective January 1, 2021. The inspectors determined that this finding is of very low safety significance (Green) significance 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 technical specification (TS)
system longer than its TS allowed outage time; did not represent the loss of probabilistic risk assessment (PRA) function for 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 book (PRIB) 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: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Specifically, GGNS failed to ensure an ONEP for a loss of SSW was available to support nuclear safety.
Enforcement:
Violation: Technical Specification 5.4.1.a requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, revision 2, appendix A, dated February 1978. Regulatory Guide 1.33, revision 2, appendix A, section 6, Procedures for Combating Emergencies and Other Significant Events, includes loss of service water in section 6.g.
Contrary to the above, from November 1, 1984, to present, the licensee failed to establish a procedure covering the applicable procedures recommended in Regulatory Guide 1.33, revision 2, appendix A. Specifically, the licensee failed to have a procedure for combating emergencies and other significant events involving the loss of safety-related standby service water.
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 Exit Meeting Summary The chief examiner presented the preliminary examination results to you and your staff on February 19, 2025. A telephonic call was conducted on March 19, 2025, between Kelly Clayton, chief examiner, and Anthony Watson, Ops Training Supervisor, who was provided the NRC licensing decisions. A final telephonic exit was conducted on March 25, 2025, between Kelly Clayton, chief examiner, and Ryan Meyers, Operations Director. The licensee did not identify any information or materials used during the examination as proprietary.
ADAMS DOCUMENTS REFERENCED Accession No. ML25086A098 - FINAL WRITTEN EXAMS Accession No. ML25086A099 - FINAL OPERATING TEST Accession No. ML25086A094 - POST-EXAMINATION ANALYSIS AND COMMENTS
Attachment 1 ATTACHMENT 1: Simulator Fidelity Report Facility Licensee:
Grand Gulf Nuclear Station Facility Docket No.:
05000416 Operating Tests Administered on: January 27-31, 2025 This form is to be used only to report observations. These observations do not constitute audit or inspection findings and, without further verification and review in accordance with Inspection Procedure 71111.11, Licensed Operator Requalification Program and Licensed Operator Performance, are not indicative of noncompliance with 10 CFR 55.46, Simulation Facilities. No licensee action is required in response to these observations.
While conducting the simulator portion of the operating tests, examiners observed the following items:
Item Description 1.
SBT data capture missing Containment Pressure parameters During Scenario 3, noted that no data for containment pressure existed in SBT data set. CR-2025-00601 2.
SBT data recovery Mode switch, acknowledge alarm pushbutton switch issues flooded TAM logs. Also, there was no way to get data from simulator servers (required by NUREG-1021).
CR-2025-00592, CR-2025-00595, CR-2025-01565 3.
Simulator capabilities to store and backup IC snaps or saved condition Initial condition (IC) corrupt for Scenario 2.
Could not run during exam week, resulting in NRC running the spare scenario.
CR-2025-00589