ML12157A181

Attachment 8 to GNRO-2012/00039 - from Diskette Labeled: Entergy Nuclear Grand Gulf Nuclear Station License Renewal Environmental Audit - Hydrology Patton - Attachment K Labeled Condition Reports.

ML12157A181
Person / Time
Site:	Grand Gulf
Issue date:	05/23/2012
From:	Entergy Operations
To:	Office of Nuclear Reactor Regulation
References
GNRO-2012/00039
Download: ML12157A181 (82)

Text

Attachment 8 to GNRO-2012/00039 Attachment 8 to GNRO-2012/00039 From Diskette Labeled: Entergy Nuclear Grand Gulf Nuclear Station License Renewal Environmental Audit -Hydrology Patton -Attachment K labeled "Condition Reports" Attachment K Condition Reports CR-GGN-2011-2936 Entergy CONDITION REPORT TCR-GGN-2011-02936 Originator:

Lassetter Jr,John M Originator Site Group: GGN Chemistry Mgmt GGN Supervisor Name: Scarbrough,Richard A Discovered Date: 04/28/2011 11:27 Originator Phone: 2115 Operability Required:

Y Reportability Required:

Y Initiated Date: 04/28/2011 11:40 Condition

==

Description:==

The investigation into the site groundwater monitoring program indicates the following:

One set of samples collected from UNIT 2 TURBINE BLDG sumps -when analyzed at the RBS Environmental Lab for triitum showed the following initial results: East Sump 106,400 pCi/L and U2 West Sump 100,259 pCi/L. Equates to approximately IE-4 microcuries/mi.

These sumps are on the bottom elevation of the building.

Resaon for CR is that this location is outside the Unit 1 posted RCA. Chemistry now coordinating with RP staff for confinrmatory sample collection with onsite analysis for gamma and tritium. Results expected by 17:00 4/28/11.Immediate Action

Description:

See above.Suggested Action

Description:

See above.REFERENCE ITEMS: Type Code MISC Item Desc This CR does not warrant a MRFF evaluation TRENDING (For Reference Purposes Only): Trend Type WE HEP FACTOR REPORT WEIGHT INPO BINNING KEYWORDS KEYWORDS KEYWORDS GRADE ACE Trend Code CYMG P 1 CY1 KW-TRITIUM CONTAMINATION KW-LEAK KW-10 CFR 50.75(G)19 Attachments:

Condition Reportription USER GENERATED PDF : 03/17/012 16:54:16 Condition Reportription USER GENERATED PDF :03/17/012 16:54:16 Condition Reportription USER GENERATED PDF : 03/17/012 16:54:16 Condition Reportription USER GENERATED PDF :03/17/012 16:54:16 Condition Reportription USER GENERATED PDF : 03/17/012 16:54:16 Condition Reportription USER GENERATED PDF : 03/17/012 16:54:16 Entergy CORRECTIVE ACTION CR-GGN-2011-02936 CA Number: 1 Site Group Name Assigned By: GGN Chemistry Mgmt GGN Scarbrough,Richard A Assigned To: GGN Chemistry Mgmt GGN Scarbrough,Richard A Subassigned To : Originated By: Zzggncrg 5/5/2011 14:51:30 Performed By: Scarbrough,Richard A 5/25/2011 17:16:21 Subperformed By: Approved By: Closed By: Scarbrough,Richard A 5/25/2011 22:37:00 Current Due Date: 05/26/2011 Initial Due Date: 05/26/2011 CA Type: DISP -ACE/HT Plant Constraint:

NONE CA

Description:

Caution this action to perform a Higher Tier ACE has multiple parts read them all: 1. Prior to performing the ACE confirm assigned apparent cause evaluator's qualifications through Plateau.2. You have been assigned by the CRG as the Responsible Manager for this Category "B"- ACE HIGHER TIER, Non-Significant CR. Per EN-LI-1 19 develop a corrective action plan that will address the condition, the apparent cause(s), and extent of condition issues.3. Ensure an ACE Template (see below) is completed in accordance with EN-LI-1 19 and attached in response to this CA.4. CA closure by responsible manager constitutes ACE review and approval.5. Ensure all proposed corrective actions are issued and Trend Data entered.Note 1: Cat. B dispositions can not exceed 30 days.Note 2: All Critical Component Failures require an Equipment Failure Evaluation (EFE) per EN-LI- 119-01.Note 3: Forms are available through Reflib, Site, Ech, Nuclear Management Manual, NMM Forms, EN-Common, Licensing/Corrective Actions, EN-LI-1 19.Note 4: Attachments and for Equipment Failure Checklist Form use EN-LI- 119-01 Attachments.

Response: ACE template completed and attached.

All proposed corrective actions are issued and Trend Codes included in ACE.Corrective action plan developed to address the condition, the apparent cause(s), and extent of condition issues. No critical component failures identified, therefore no EFE.Subresponse

Closure Comments: ACE reviewed and approved.

CAs issued. Reformatted ACE document (without highlighting) attached.Attachments:

Resp Description U2 Tritium ACE HT Closure Description U2 Tritium ACE Entergy CORRECTIVE ACTION I CR-GGN-2011-02936 CA Number: 2 Site I Gr Assigned By: GGN CRG-CARB-SARB GGN Assigned To: GGN Chemistry Mgmt GGN Subassigned To : GGN Chemistry Mgmt GGN oup Name Scarbrough,Richard A Lassetter Jr,John M Originated By: Zzggncrg 5/5/2011 14:54:01 Performed By: Scarbrough,Richard A 5/10/2011 16:06:07 Subperformed By: Approved By: Closed By: Scarbrough,Richard A 5/10/2011 16:06:07 Current Due Date: 05/10/2011 Initial Due Date: 05/10/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Brief CRG by performing the following:

1) Develop an ACE problem statement per LI- 119.2) Complete the 'CRG ACE Briefing form' (linked on the CA&A web page: CRG; CRG Information; CRG ACE Briefing form) and present to CRG for review and approval.3) Incorporate any CRG comments and attach the CRG-approved ACE Briefing form to this CA response.Response: CRG-Approved ACE briefing form attached.

Form includes CRG comments as noted in CA closure section.Subresponse

Closure Comments:*CA&A Note: Approved w/comments at 05-10-11 CRG: 1) Add consequences to Problem statement 2) Explore processes for routine sampling of sumps 3) Evaluate timeliness of Environmental analysis 4) Was source from Unit 1?Attachments:

Resp Description U2 tritium Entergy I CORRECTIVE ACTION I CR-GGN-2011-02936 CA Number: 3 Assigned By: Assigned To: Subassigned To : Site GGN GGN Group CAA Mgmt GGN Chemistry Mgmt GGN J Name Nadeau,James Joseph Scarbrough,Richard A Originated By: Zzggncrg 5/5/2011 14:57:08 Performed By: Scarbrough,Richard A 5/11/2011 17:10:17 Subperformed By: Approved By: Closed By: Marrs,Stephen C 5/12/2011 17:09:33 Current Due Date: 05/12/2011 Initial Due Date: 05/12/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

1) Conduct a Pre-job Briefing with the assigned ACE evaluator using the PJB checklist (linked on the CA&A web page: CRG; CRG Information; Manager's ACE Pre-job Brief Checklist).

2) Ensure a CA&A representative is present at the brief to provide oversight.

Response: ACE PJB checklist performed with CA&A oversight.

Checklist attached.Subresponse

Closure Comments: Closed per Mgr CA&A Attachments:

Resp Description U2 tritium ACE PJB Entergy I CORRECTIVE ACTION ICR-GGN-2011-02936 CA Number: 4 Assigned By: Assigned To: Subassigned To : Site GGN GGN GGN Group CAA Mgmt GGN Chemistry Mgmt GGN Chemistry Mgmt GGN Name Nadeau,James Joseph Scarbrough,Richard A O'Neal,Ronald K Originated By: Zzggncrg 5/5/2011 14:58:03 Performed By: Lassetter Jr,John M 5/18/2011 18:59:18 Subperformed By: Lassetter Jr,John M 5/18/2011 18:58:29 Approved By: Closed By: Lassetter Jr,John M 5/18/2011 18:59:18 Current Due Date: 05/19/2011 Initial Due Date: 05/19/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

The Resp. Manager and assigned ACE Evaluator should conduct a face-to-face review of the draft ACE with the CA&A Manager/designee.

Response: CA Closed per discussion with acting Chem Mgr.Subresponse

Review completed 5/18/2011 Closure Comments:

Entergy I CA DUE DATE EXTENSION CR-GGN-2011-02936 Corrective Action : CR-GGN-2011-02936 CA-00004 Version: 1 Approved:-

Requested Duedate: 05/20/2011 Previous Duedate: 05/19/2011 Requested By: Lassetter Jr,John M 05/18/2011 Approved By: CACLOSED Request

Description:

DDE necessary due to emergent meetings for Strike contingency and competing priorites for evaluator.

DDE acceptable because significant progress made on ACE. Failure Mode analysis 90% complete.

Fault Tree in progress.OE review supports site data collected to date.Approved

Description:

Entergy CORRECTIVE ACTION CR-GGN-2011-02936 CA Number: 5 Site Group Name Assigned By: GGN NSA Director GGN Richey,Marty L Assigned To: GGN Chemistry Mgmt GGN Scarbrough,Richard A Subassigned To : GGN Chemistry Mgmt GGN Lassetter Jr,John M Originated By: Zzggncrg 5/5/2011 14:59:02 Performed By: Lassetter Jr,John M 6/21/2011 16:25:31 Subperformed By: Lassetter Jr,John M 6/21/2011 16:25:01 Approved By: Closed By: Nadeau,James Joseph 6/21/2011 18:18:30 Current Due Date: 06/21/2011 Initial Due Date: 06/21/2011 CA Type: CARB REVIEW Plant Constraint:

NONE CA

Description:

CARB requested to see this CR back after disposition.

CA&A Manager approval is required for extension of this CA.Perform the following actions: 1) Notify CA&A at 2141 to place this on the CARB agenda, AND 2) Respond to this CA after presentation at CARB 3) IF CARB comments modified the ACE, THEN also attach the revised ACE.Response: Closed.Subresponse:

ACE revised with CARB comments and additional Corrective Actions per the provided comments below. ACE attached.Att3 and Att4 attached as well. Responses to the CARB comments are listed below.The presented ACE was reviewed and approved with comments (Grade = 19) by the 06-14-11 CARB. These included: Attachment 3 & 4 missing from package. Attached to this CA Weak ties between O&P issues and the identified causes; Tie 1st O&P issue to CR 2011-3445 (ACE by SysEng) Complete No conclusions in either OE section as to value or learnings from the OE. Need a conclusion or summary section. Added CC-3 is a Possible (vs contributing) contributing cause, Changed CC3 to PC2 9and renumberd CC$ as CC3)and Poss. CC3 also requires a new CA to review the results of 2011-3445 to confirm or refute it as a valid cause. Added CA Contract support needs to address Radioactivity issues (wall and bucket samples) & need to be mentioned in CAs and analysis Added in write up and a CA to include in work scope Some weak CAs -those with 'evaluate/review' need to have paired actions to followup on the results. Added followup /effectiveness review CA Closure Comments: The presented ACE was reviewed and approved with comments (Grade = 19) by the 06-14-11 CARB.Approved for M. Richey.Attachments:

Subresp Description Entergy CORRECTIVE ACTION CR-GGN-2011-02936 Attachments:

ACE w/CARB comments Att 3 Failure Modes Analysis Att 4 Fault Tree Entergy CA DUE DATE EXTENSION CR-GGN-2011-02936 Corrective Action : CR-GGN-2011-02936 CA-00005 Version: 2 Approved: Requested Duedate: 06/21/2011 Previous Duedate: 06/15/2011 Requested By: Zzggncrg 06/14/2011 Approved By: Zzggncrg 06/14/2011 Request

Description:

Acceptable since ACE was approved with comments and actions are issued. Necessary to allow time to incorporate changes as directed by CARB Chair (Director NSA).Approved

Description:

Requested and Approved by Acting Mgr CA&A per CARB Chair direction.

CA was also re-directed to Director NSA who the CARB designated as the approving authority for the final ACE.

Entergy CA DUE DATE EXTENSION CR-GGN-2011-02936 Corrective Action : CR-GGN-2011-02936 CA-00005 Version: 1 Approved:

Y Requested Duedate: 06/15/2011 Previous Duedate: 06/06/2011 Requested By: Scarbrough,Richard A 06/01/2011 Approved By: Nadeau,James Joseph 06/01/2011 Request

Description:

Is acceptable and necessary to extend due date to allow CA&A to place this item on the CARB agenda and to present to CARB for approval.Approved

Description:

Entergy I CORRECTIVE ACTION ICR-GGN-2011-02936 CA Number: 6 Assigned By: Assigned To: Subassigned To : Site GGN GGN Group CAA Mgmt GGN Operating Experience Staff GGN j "Name Nadeau,James Joseph Remskar,Andrew P Originated By: Zzggncrg 5/5/2011 15:00:26 Performed By: Remskar,Andrew P 6/22/2011 14:19:42 Subperformed By: Approved By: Closed By: Remskar,Andrew P 6/22/2011 14:19:42 Current Due Date: 06/23/2011 Initial Due Date: 06/23/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

As required by EN-LI-102 Attachment 9.5, share the CR with the Fleet.Response: ACE shared with the Entergy Fleet, no further actions in this CA are necessary.

Subresponse

Closure Comments:

Entergy CORRECTIVE ACTION CR-GGN-2011-02936 CA Number: 7 Site I Group I Name Assigned By: GGN CRG-CARB-SARB GGN Assigned To: GGN Chemistry Mgmt GGN Scarbrough,Richard A Subassigned To : GGN Chemistry Mgmt GGN Lassetter Jr,John M Originated By: Marrs,Stephen C 5/9/2011 13:05:22 Performed By: Scarbrough,Richard A 5/16/2011 18:07:27 Subperformed By: Lassetter Jr,John M 5/16/2011 09:32:37 Approved By: Closed By: Scarbrough,Richard A 5/16/2011 18:07:27 Current Due Date: 05/19/2011 Initial Due Date: 05/19/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Per 05-09-2011 GGN CRG, CR-GGN-2011-2975 was closed to this CR. Ensure the problem described in that CR is covered by the action plan in this CR.Partial CR

Description:

Follow up review and investigation related to CR-GGN-2011-02936 has confirmed that water from UNIT 2 Turbine Building sump has been pumped to the environment through installed sump pumps and piping connected between the sumps and the roof drains on Unit 2 Turbine Building.

The roof drains are connected to the station' s storm drain system. This confirmation was made at 0852 on April 29, 2011. This CR is being generated to alert station Management to this fact such that appropriate notifications and or actions can be implemented.

Response: Concur with subresponse.

Contrary to wording in the CR description, confirmation that water was pumped from U2 to storm drain was NOT made. Instead, it was confirmed that there existed a pathway from the U2 sumps to the storm drain piping.Subresponse:

Site Licensing Mgr, RP Mgr and Chem Mgr elected to make notifications per ENRPI 13. Notifications complete.

No further actions required.

CA can be closed.Closure Comments:

Entergy CORRECTIVE ACTION I CR-GGN-2011-02936 CA Number: 8 A Site C S Assigned By: GGN Chemistry Staff GGN Assigned To: GGN Chemistry Staff GGN Group Name O'Neal,Ronald K O'Neal.Ronald K Subassigned To : Originated By: O'Neal,Ronald K 5/17/2011 13:50:43 Performed By: O'Neal,Ronald K 5/19/2011 12:35:48 Subperformed By: Approved By: Closed By: O'Neal,Ronald K 5/19/2011 12:36:43 Current Due Date: 05/19/2011 Initial Due Date: 05/19/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Per EN-LI-102 Step 5.10 [I] (g), CR 2010-03091 was closed to this CR. Ensure the problem described in that CR is covered by the action plan in this CR.Partial CR

Description:

While performing a walkdown through Unit 2, noticed unusual movement in what was to be the spent fuel pool. Upon careful observation, it was determined that a school of what appears to be "koi fish" have moved into the vacated spent fuel pool without authorization.

On the smaller pool located to the North, a rather sizeable koi fish was observed swimming alone and I suspect that he/she has proceeded to devour any other koi in the smaller pool. The koi appear to be healthy and multipying.

Response: CA should read CR 2011-03091 not 2010. CA# 9 generated in this CR to document the action plan for fish found in Unit 2 spent fuel pool. This action plan will address the issues in CR 2011-03091 Subresponse

Closure Comments: Acting Chemistry Manager concurrs with closing this CA Entergy CORRECTIVE ACTION I CR-GGN-2011-02936 CA Number: 9 Assigned By: Assigned To: Subassigned To : Site GGN GGN Group Chemistry Staff GGN Chemistry Mgmt GGN Name O'Neal,Ronald K Lassetter Jr,John M Originated By: O'Neal,Ronald K 5/19/2011 12:31:45 Performed By: Lassetter Jr,John M 6/24/2011 09:51:31 Subperformed By: Approved By: Closed By: Lassetter JrJohn M 6/24/2011 09:51:31 Current Due Date: 06/29/2011 Initial Due Date: 06/29/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Document the action plan/decision for fish found in Unit 2 spent fuel pool as documented in CR 2011- 3091 Response: No action required as this condition does not pose any risk or represent a condition adverse to quality.Subresponse

Closure Comments:

Entergy CORRECTIVE ACTION CR-GGN-2011-02936 CA Number: 10 Site j Group Name I Assigned By: GGN Chemistry Mgmt GGN Assigned To: GGN Chemistry Staff GGN Bevily,Rosie W Subassigned To: Originated By: Scarbrough,Richard A 5/25/2011 17:04:43 Performed By: Lassetter Jr,John M 10/13/2011 12:45:12 Subperformed By: Approved By: Closed By: Lassetter Jr,John M 10/13/2011 12:45:12 Current Due Date: 10/15/2011 Initial Due Date: 10/15/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Evaluate current tritium in rainfall data / HVAC for environmental impact by updating the site storm drain study (reference GIN 2005-00562).

Response: Study Has been updated and reviewed.

Final comments provided.Subresponse

Closure Comments:

Entergy CA DUE DATE EXTENSION ECR-GGN-2011-02936 Corrective Action : CR-GGN-2011-02936 CA-00010 Version: 1 Approved: Requested Duedate: 09/10/2011 Previous Duedate: 08/01/2011 Requested By: Bevily,Rosie W 07/28/2011 Approved By: Lassetter Jr,John M 07/28/2011 Request

Description:

It is acceptable and necessary to extend due date to allow study to be performed on rainfall data collected in June 2011.Contract req 2126687 has been routed for contractor to perform the study.Approved

Description:

CA is administrative in nature and is to update an existing site specific technical evaluation.

The CA does not address a condition adverse to quality. Approved.=

DDE 1 by Supv.

Entergy I CA DUE DATE EXTENSION CR-GGN-2011-02936 Corrective Action : CR-GGN-2011-02936 CA-00010 Version: 2 Approved: Requested Duedate: 10/15/2011 Previous Duedate: 09/10/2011 Requested By: Lassetter Jr,John M 09/08/2011 Approved By: Lassetter Jr,John M 09/08/2011 Request

Description:

Acceptable:

CA is administrative in nature and is to update an existing site specific technical evaluation.

The CA does not address a condition adverse to quality.Necessary:

Contractor performing study needed more information initially provided to perform study.Approved

Description:

DDE2 submitted by RWBevily.

Discussed and edited requested date to include margin for 180 days since CR initiation.

DDE2 approved per discussion with Chem Mgr.

Entergy CORRECTIVE ACTION CR-GGN-2011-02936 CA Number: 11 Site Assigned By: GGN Chemistry Mgmt GGN Assigned To: GGN Chemistry Staff GGN Subassigned To : Group I Name I Bevily,Rosie W Originated By: Scarbrough,Richard A Performed By: Lassetter Jr,John M 5/25/2011 17:05:28 10/13/2011 13:33:24 Subperformed By: Approved By: Closed By: Lassetter Jr,John M 10/13/2011 13:33:24 Current Due Date: 10/20/2011 Initial Due Date: 10/20/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Based on outcome of CA 10, evaluate / recommend U2 turbine building roof repairs.Response: The site specifc storm water study update did not recomend roofing Unit 2 structures.

Unit 2 sumps are now directed to Unit 1 [reference CR 2011-5329].

This eliminated the potential for U2 sump water to impact storm drainage.

As such there would be no benefit to site storm water triitum levels associated with roofing the U2 structure.

Rainfall recapture of triitum occurs at all nearsite locatins including Unit 2. Roofing the Unit 2 open structure would reduce rainfall input to the building but would have a minimal effect on tritium recapture across the site. No action required.Subresponse

Closure Comments:

Entergy CA DUE DATE EXTENSION CR-GGN-2011-02936 Corrective Action: CR-GGN-2011-02936 CA-00011 Version: 1 Approved:F Requested Duedate: 09/23/2011 Previous Duedate: 08/15/2011 Requested By: Lassetter Jr,John M 08/12/2011 Approved By: Lassetter Jr,John M 08/12/2011 Request

Description:

Necessary:

CA10 study is not complete.

Contract issued the the week of 8/8, est completion duration 1 month.Acceptable:

At present the U2 water inputs are being routed to Unit 1 for processing as LRW. U2 sump pumps remain out of service. DDE requested is < 180 days from CR initiation.

This DDE is submitted for R Bevily after discussion 8/12 09:30.Approved

Description:

DDE 1 approved by supervisor Entergy I CA DUE DATE EXTENSION CR-GGN-2011-02936 Corrective Action: CR-GGN-2011-02936 CA-00011 Version: 2 Approved: Requested Duedate: 10/20/2011 Previous Duedate: 09/23/2011 Requested By: Bevily,Rosie W 09/21/2011 Approved By: Nash,Charles L 09/21/2011 Request

Description:

Necessary:

CA1O study is not complete.Acceptable:

At present, the U2 water inputs have been routed to Unit 1 for processing as LRW. U2 sump pumps remain out of service. DDE requested is < 180 days from CR initiation.

Approved

Description:

Entergy CORRECTIVE ACTION CR-GGN-2011-02936 CA Number: 12 Site I Group Name Assigned By: GGN Chemistry Mgmt GGN Assigned To: GGN Rad Protection Mgmt GGN Trichell,William T Subassigned To : GGN Rad Protection Staff GGN Schlapkohl,Daniel Originated By: Scarbrough,Richard A 5/25/2011 17:06:31 Performed By: Trichell,William T 7/14/2011 18:13:34 Subperformed By: Schlapkohl,Daniel 7/12/2011 14:16:16 Approved By: Closed By: Trichell,William T 7/14/2011 18:14:13 Current Due Date: 07/15/2011 Initial Due Date: 07/15/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Determine adequacy of reviews for radiological impact when U2 areas were incorporated into Unit 1 RCA Response: Concur with sub-response.

Additionally, the establishment of the RCA exit point on the 133' Unit 2 Turbine was reviewed and analyzed in regards to allow personnel ingress and egress based on the requirements of site procedures.

The evaluation was conducted to ensure that no licensed radioactive material would be released to the environment.

The evaluation took into account the controls that were in place at the time where the RCA access point was from the Unit 1 Turbine Building into the Control Building on 93' elevation.

It was identified that any floor drains, sinks and showers for personnel decontamination would have to be routed back into Unit 1. 1As with other access doors on the 93' and 113' elevation, the doors are not allowed to be opened and stay open beyond normal personnel access and equipment movement in or out. Only items with fixed contamination are allowed into the area on the unit 2 side unless anything with loose surface contamination is contained in an approved container.

Subresponse:

Work completed from ER-GG-2006-0248-0000 involving routing drain line from the decontamination area to Unit 1..Penetrations secured to isolate any positive pressure from Unit 1. This work incorporated at the time of adding Unit 2 side of the RCA to Unit 1. Wall with doors also added to entrance to Unit I to isolate any positive air movement from Unit 1 to Unit 2 side Work order 277440 completed in 2011 to collect and drain condensation from the Hot Tool Room air conditioner unit on 133' Unit 2 side to the south chemical sump on 93' TB Unit 2. Condensation from air conditioning unit above the RP control point on 133' TB Unit 2 drains to the south chemical sump. Water from this sump is pumped into the Unit I RCA.Radiological impact reviews are satisfactory.

Closure Comments: Close CA.

Entergy CORRECTIVE ACTION CR-GGN-2011-02936 CA Number: 13 Site I Group Name Assigned By: GGN Chemistry Mgmt GGN Assigned To: GGN Eng Sys BOP Mgmt GGN Shaw,Jim Subassigned To : GGN Eng Sys Mech Mgmt GGN Loyd,Christopher G Originated By: Scarbrough,Richard A 5/25/2011 17:07:36 Performed By: ShawJim 6/11/2011 17:01:38 Subperformed By: Loyd,Christopher G 6/9/2011 17:15:13 Approved By: Closed By: Shaw,Jim 6/11/2011 17:01:38 Current Due Date: 06/15/2011 Initial Due Date: 06/15/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Determine adequacy / timeliness of maintenance strategy to ensure UI Turb Ventilation system performs as designed.Suggest close this CA to CR GGN 2011- 3445 which has the following problem description:

Per UFSAR, section 9.4.4.5, the Turbine Building Ventilation system uses a pressure control system to maintain a slight negative pressure in the Turbine Building with respect to the atmosphere by modulating dampers located in the discharge duct of the building and in the duct return to the operating levels. However, a review of PDS points U41N031A and U41N03 lB, Turbine Building Pressure, dating back to May 16, 2004 indicated that the pressure is rarely maintained negative.

Charts and point data are attached to this CR description to document the pressures dating back to 2004.Response: Action complete.Subresponse

Per EN-LI-102 section 5.9[2](e), "Typically CA assigners should notify assignees Prior to assignment of an action." Exceptions to this are listed in section 5.9 of referenced procedure.

The assigner of this CA did not contact the receiving group prior to initiating this CA. Multiple attempts were made by phone and in person to contact the originator of this CA.Additionally, per EN-DC-324 section 5.2[2](b)(2) states: "Non-Essential Tasks are controlled by Maintenance".

Section 5.2[2](b)(1) states: "Essential Tasks are controlled by Engineering".

The TB Ventilation components are classified as non-critical and non-essential.

During the investigation of ACE development under CR 2011-3445, I&C has performed the loop calibration check of both the IU41N03 lA/B and no issues have been identified that would correct the current indicated TB pressures.

There is no data at this time that would indicate an inadequate maintenance strategy is causing the positive building pressures as indicated by computer points U41N031 A/B. Per the current ACE process, if it is determined that the current maintenance strategy prevented the TB Ventilation system from performing its designed function or was a contributor to this, actions will be generated in the ACE evaluation to correct these causes. Any additional or further scrutiny of the adequacy and timeliness of the current maintenance strategy for the TB Ventilation system should be performed by Maintenance per current plant procedures.

No further action is required by this CA.Closure Comments:

Entergy CORRECTIVE ACTION CR-GGN-2011-02936 CA Number: 14 Site .Groi Assigned By: GGN Chemistry Mgmt GGN Assigned To: GGN Eng Sys BOP Mgmt GGN Subassigned To : GGN Eng Sys Mech Mgmt GGN tp J Name ShawJim Loyd,Christopher G Originated By: Scarbrough,Richard A 5/25/2011 17:08:15 Performed By: Shaw,Jim 6/11/2011 17:00:29 Subperformed By: Loyd,Christopher G 6/11/2011 16:44:32 Approved By: Closed By: Shaw,Jim 6/11/2011 17:00:29 Current Due Date: 08/15/2011 Initial Due Date: 08/15/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Determine changes needed to-configuration control / allowable temperature in turbine building (reference the current GGNS Top 10 Equipment Reliability List).Response: Agree with sub-response.

The attributes of the Top 10 Plan are owned by the Maintenance Manager and not Engineering and the CA should be directed to the Top 10 owner. Additionally, the CA needs to be clarified, prior to assignment, as to the desired intent and desired outcome of the CA as the current CA description is clear and multiple attempts to contact the CA originator by telephone and physically have been unsuccessful.

Subresponse

The contents of this CA is not understood by the recipient.

Per EN-LI-102 section 5.9[2](e), "Typically CA assigners should notify assignees Prior to assignment of an action." Exceptions to this are listed in section 5.9 of referenced procedure.

The assigner of this CA did not contact the receiving group prior to initiating this CA. Multiple attempts were made by phone and in person to contact the originator of this CA to discuss its contents.

No further action is required.Closure Comments:

Entergy CORRECTIVE ACTION I CR-GGN-2011-02936 CA Number: 15 Assigned By: Assigned To: Subassigned To : Site I GGN GGN Group Chemistry Mgmt GGN Chemistry Staff GGN j Name Jackson,Dennis E Originated By: Scarbrough,Richard A 5/25/2011 17:09:11 Performed By: Jackson,Dennis E 6/28/2011 10:01:14 Subperformed By: Approved By: Closed By: Jackson,Dennis E 6/28/2011 10:01:14 Current Due Date: 07/01/2011 Initial Due Date: 07/01/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Develop ratios of U1 and U2 source terms for comparison Response: See attached comparison for P-11, P-45, or reactor water as the source.Subresponse

Closure Comments: Attachments:

Resp Description Should we see other isotopes Entergy CORRECTIVE ACTION CR-GGN-2011-02936 CA Number: 16 Assigned By: Assigned To: Subassigned To : Site I GGN GGN GGN Group Chemistry Mgmt GGN Eng Sys BOP Mgmt GGN Eng Sys Mech Staff GGN] Name Shaw,Jim Stuart,Howard Martin Originated By: Scarbrough,Richard A 5/25/2011 17:09:58 Performed By: Shaw,Jim 8/15/2011 15:13:51 Subperformed By: Stuart,Howard Martin 8/9/2011 12:05:36 Approved By: Closed By: Shaw,Jim 8/15/2011 15:13:51 Current Due Date: 08/26/2011 Initial Due Date: 08/26/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Evaluate boundary for the Ul to U2 tunnel pathway Response: Action complete Subresponse

The tunnel wall was inspect and it appears to be in an acceptabe condition.

The wall is soild in all areas that could be closely inspected.

However, the wall is not water proofed on the U2 side like the rest of the tunnel boundarys.

Pictures taken of the wall are attched.This action was to evaluate the U2 Tunnel Wall. No further actions are required.Closure Comments: Attachments:

Subresp Description Pics Entergy CA DUE DATE EXTENSION I CR-GGN-2011-02936 Corrective Action : CR-GGN-2011-02936 CA-00016 Version: 1 Requested Duedate: 07/27/2011 Requested By: Stuart,Howard Martin Approved By: Shaw,Jim Approved: Previous Duedate: 06/30/2011 06/29/2011 06/29/2011 Request

Description:

This DDE is acceptable because actions have already been taken to prevent tritium from reaching the environment.

This DDE is necessary because more time is needed to empty the Unit 2 tunnel and obtain the support needed for entry.Approved

Description:

Approved Entergy I CA DUE DATE EXTENSION CR-GGN-2011-02936 Corrective Action: CR-GGN-2011-02936 CA-00016 Version: 2 Approved: Requested Duedate: 08/26/2011 Previous Duedate: 07/27/2011 Requested By: Stuart,Howard Martin 07/27/2011 Approved By: Shaw,Jim 07/27/2011 Request

Description:

This DDE is acceptable because actions have already been taken to prevent tritium from reaching the environment.

This DDE is necessary because more time is needed to empty the Unit 2 tunnel. The tunnel is proving difficult to empty because all of the water from the Unit 2 Aux building is currently draining into the tunnel. Actions are in place to have the tunnel empty by the end of the week 7/28/2011.

However, this may be challenged due to rain forecasts.

Therefore, the extension will allow adequate time to account for further weather delays.Approved

Description:

Approved Entergy CORRECTIVE ACTION CR-GGN-2011-02936 CA Number: 17 Site ] Group Name Assigned By: GGN Chemistry Mgmt GGN Assigned To: GGN Eng Sys BOP Mgmt GGN ShawJim Subassigned To : GGN Eng Sys Mech Staff GGN Stuart,Howard Martin Originated By: Scarbrough,Richard A 5/25/2011 17:10:39 Performed By: Shaw,Jim 7/27/2011 16:27:49 Subperformed By: Stuart,Howard Martin 7/27/2011 16:12:14 Approved By: Closed By: Shaw,Jim 7/27/2011 16:27:49 Current Due Date: 07/27/2011 Initial Due Date: 07/27/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Review U I to U2 piping for adequate boundaries Response: Action complete Subresponse

All of the systems at GGN were reviewed and evaluated on the attached spreadsheet.

There were no boundaries found that were potential contributors to the Tritium found in the Unit 2 sumps.The systems were evaluated based on the shared equipment between Unit 1 and Unit 2 turbine buildings.

First, the systems with no shared equipment were immediately ruled out. This was determined by searching for shared components for each system in asset suite. For example SB33(wildcard) was searched and no hits were received.

Therefore, no shared equipment exists for B33 and the system was ruled out.Second, the systems with no equipment in the turbine buildings were ruled out. This was determined by reviewing the location of every shared valve for each system that had shared equipment.

If there were no shared valves in the turbine buildings then the system was ruled out.Third, the systems with no piping or ventilation between units were ruled out. This was determined by reviewing the P&IDs for each system that was not already ruled out. If the system did not have any piping or ventilation between units then the system was ruled out. For example, the plant vibration monitoring system is a shared system with equipment in the turbine building.

However, the system does not contain any piping or ventilation.

Therefore, it was ruled out.Based on these criteria the systems listed in green on the attached spreadsheet were further evaluated via walkdowns or chemical analysis to determine if they were potential sources of the tritium found in the Unit 2 sumps. No systems were identified to be potential sources.Closure Comments: Attachments:

Subresp Description Systems Entergy CA DUE DATE EXTENSION CR-GGN-2011-02936 Corrective Action : CR-GGN-2011-02936 CA-00017 Version: 1 Requested Duedate: 07/27/2011 Requested By: Stuart,Howard Martin Approved By: Shaw,Jim Approved:

F Previous Duedate: 06/30/2011 06/29/2011 06/29/2011 Request

Description:

This DDE is acceptable because actions have already been taken to prevent tritium from reaching the environment.

This DDE is necessary because more time is needed to empty the Unit 2 tunnel and obtain the support needed for entry.Approved

Description:

Approved Entergy CORRECTIVE ACTION CR-GGN-2011-02936 CA Number: 18 Site .Group I Name Assigned By: GGN Chemistry Mgmt GGN Assigned To: GGN Rad Protection Mgmt GGN Trichell,William T Subassigned To : GGN Rad Protection Staff GGN Freeman,Lester W Originated By: Scarbrough,Richard A 5/25/2011 17:11:25 Performed By: Trichell,William T 7/14/2011 12:14:30 Subperformed By: Freeman,Lester W 7/8/2011 16:20:57 Approved By: Closed By: Trichell,William T 7/14/2011 17:06:59 Current Due Date: 07/15/2011 Initial Due Date: 07/15/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Evaluate potential personnel exposure prior to restricting access to U2 locations identified with tritium and currently posted as radiologically controlled.

Response: Concur with sub-response.

Subresponse

Per RP Dosimetry Supervisor's interviews with Plant Safety Coordinator, these Unit-2 areas have been restricted since at least 2003 for Industrial Safety issues [i.e. Histoplasmosis (bird droppings), Poor Lighting, Trip Hazards with equipment stored in various areas, Electrical Hazards since some temporary power is still present from construction activities, and Confined Spaces concerns].

Any dose considerations would be after the U2 RCA Access Point and RP lab on the 139' elevation was constructed in 2008, but these areas are three elevations below the access point without any concentrated flowpath.With the sumps located in and below the Industrial Safety restricted/locked U2 Turbine locations, these areas identified are not designated work environments which would pose absorption concerns nor are they entering drinking water basins which would be the other tritium intake pathway. Additional restrictions are not necessary since workers don't wade in nor drink water from these identified sumps.Closure Comments: Close CA.

Entergy CORRECTIVE ACTION I CR-GGN-2011-02936 CA Number: 19 Site I Assigned By: GGN Chemistry Mgmt GGN Assigned To: GGN Chemistry Mgmt GGN Subassigned To : Group Name Scarbrough,Richard A Originated By: Scarbrough,Richard A 5/26/2011 13:32:54 Performed By: Scarbrough,Richard A 5/26/2011 13:36:18 Subperformed By: Approved By: Closed By: Scarbrough,Richard A 5/26/2011 13:36:18 Current Due Date: 06/03/2011 Initial Due Date: 06/03/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

The ACE attached to the CA closure section of CA 1 has an error in the listed ODCM limit. Correct the error in the response section of this CA and attache the revised/corrected ACE.Response: Original Text: An additional limitation on tritium is located in ODCM 6.11.1. This limit applies strictly to liquid discharges and is not to exceed ten times the 1OCFR20 Appendix B column II value of IE-3 micro curies / milliliter

(?Ci/ml).

This converts tol,000,000 pCi/l. Revised Text: An additional limitation on tritium is located in ODCM 6.11.1.This limit applies only to liquid discharges and is not to exceed ten times the 1OCFR20 Appendix B column II value of IE-3 micro curies / milliliter

(?Ci/ml).

Ten times the IOCFR20 Appendix B column II value of 1E-3 micro curies /milliliter is 10,000,000 pCi/l (ten million pico curies per liter)Subresponse

Closure Comments: Attachments:

Resp Description ACE revised ODCM limit Entergy CORRECTIVE ACTION CR-GGN-2011-02936 CA Number: 20 Site ! (Assigned By: GGN Chemistry Mgmt GGN Assigned To: GGN Chemistry Staff GGN Subassigned To : 3roup I Name I Jackson,Dennis E Originated By: Lassetter Jr,John M 6/2/2011 10:13:03 Performed By: Jackson,Dennis E 6/16/2011 15:00:04 Subperformed By: Approved By: Closed By: Nash,Charles Leroy 6/22/2011 12:06:35 Current Due Date: 07/07/2011 Initial Due Date: 07/07/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Add this comment to Licensing Commitment Number 16807 for the 2011 Annual Radioactive Effluent Release Report: If determined that the Unit 2 sump pathway to the Storm Drain system or the lack of negative pressure in the U1 Turbine Bldg constitue an Unmonitored Radioactive Release, include this information, as necessary in the 2011 Annual Radioactive Effluent Release Report (ARERR).Response: Abbreviated comments on both issues added to commitment to add reminder when preparing 2011 ARERR. See attached.Subresponse

Closure Comments: Approved; no addditional actions required per this CA.Attachments:

Resp Description email confirmation Entergy CORRECTIVE ACTION I CR-GGN-2011-02936 CA Number: 21 Assigned By: Assigned To: Subassigned To : Site GGN GGN Group Chemistry Mgmt GGN Chemistry Mgmt GGN J Name Scarbrough,Richard A Scarbrough,Richard A Originated By: Scarbrough,Richard A 6/14/2011 13:22:25 Performed By: Scarbrough,Richard A 6/14/2011 13:23:50 Subperformed By: Approved By: Closed By: Scarbrough,Richard A 6/14/2011 13:23:50 Current Due Date: 06/17/2011 Initial Due Date: 06/17/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Attach revised ACE to correct the limitation on tritium is located in ODCM 6.11.1 in pCi/L FROM 1,000,000 to 10,000,000 Response: Revised ACE attached.Subresponse

Closure Comments: Attachments:

Resp Description 2936 revised with correct ODCM limit Entergy CORRECTIVE ACTION I CR-GGN-2011-02936 CA Number: 22 Assigned By: Assigned To: Subassigned To : Site I GGN GGN Group Chemistry Mgmt GGN Chemistry Mgmt GGN Name Lassetter Jr,John M Originated By: Lassetter Jr,John M Performed By: Lassetter Jr,John M Subperformed By: Approved By: Closed By: Lassetter Jr,John M 6/21/2011 15:39:18 9/14/2011 11:25:46 9/14/2011 11:25:46 Current Due Date: 09/15/2011 Initial Due Date: 09/15/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Review the results of CR GGN 2011-3445 apparent cause and confirm or refute PC2 (possible cause) as listed in the final ACE for CR.GGN 2011-2936.

Entergy CORRECTIVE ACTION CR-GGN-2011-02936 Response: ACE and CAs for 2011-3445 reviewed.

Information in ACE support outflow of air from UITurb Bldg at various locations.

Causes of outlow include departure from design configuration control [doors, penetraions, control of openings versus assumptions].

In addition, the ACE identified a failure to correct known conditions adverse to quality when identified.

Specifically, routine data indicated the building pressures were higher than expected without corrective actions and when ouflow of air was noted, investigation as to why was not pursued. Additional actions remain open under CR2011-3445 to collect data, perform inspections and to determine the condition of certain components.

Apparent and Contributing Causes in the approved ACE for 2011-3445 include: (AC 1) The Design Configuration of the Turbine Building Ventilation and Turbine Building have not been maintained in a manner that would ensure the Turbine Building is maintained at a slightly negative pressure as per UFSAR 9.4.4.5. This fact is evident by doors being left open that were assumed closed in design calculations and a make-up air fan/supply air fan that was not calculated for in design calculations.(AC 2) Changes have been made to the original design that have a negative impact on the system. The Hot Machine Shop exhaust was ducted into the Turbine Building exhaust. However, the sizing calculation for the Turbine Building Exhaust fans was not re-evaluated.(CC 1) Piping penetrations between Unit 1 and Unit 2 Turbine Buildings were not accounted for in the sizing calculation (M3.5.002) for the Turbine Building Exhaust fans. Piping penetrations were to be sealed with the completion of Unit 2.One penetration has been identified above the RCA access point that does not appear to be sealed.(CC 2) Per M3.5.002 the doors between the Unit 1 Turbine Building and other surrounding areas should remain closed to maintain a slight negative pressure in the building.

However, doors such as the one between the Radwaste Building and Unit 1 Turbine Building on the 93? elevation are routinely left open.(CC 3) No previous Condition Report was initiated stating the Turbine Building could not maintain a slight negative pressure, even though step 4.2.2.h of the U41 SOI states, ?Verify Turbine Building pressure decreases and is maintained at a slightly negative pressure as indicated on U41-R604.?

Operations fails to meet the requirement of this step each time the system is started, but no Condition Report has been written.(CC 4) Calculation M3.5.002 calculates in-leakage for the Turbine Building Rail-bay Roll-up door closed when sizing for the Turbine Building Exhaust fans. However, the Turbine Building Rail-bay Roll-up door is routinely left open, even though the door is posted to keep closed.(CC 5) CR-GGN-2009-06276 identified a positive pressure on the 166? elevation of the Turbine Building when installing a security modification.

However, the CR only justified the release from that area and did not evaluate why there was a positive pressure in the Turbine Building.(CC 6) Airflow data was taken for the 1U41B027, Turbine Building Makeup Air Fan Coil Unit, on 11/29/2007.

Airflow at that time was calculated to be 6198.5 cfm with a requirement of 5000 cfin. The additional airflow from the makeup air fan requires the exhaust fans to exhaust more airflow to maintain a negative pressure in the building.

Also, the makeup air fan flow was not used in the sizing calculation, M3.5.002, for the Turbine Building Exhaust fans.(Potential Contributing Cause(PCC))

The Preventive Maintenance task for inspecting and lubricating the 1U41F003 and 1U41F004 dampers was retired following the 2001 inspection.

Based on a review of CR GGN 23011-3445 ACE actions completed and information generated to date, the ACE for 2011-2936 Possible Cause 2 is supported as a contributing Cause[3].

Actions in CR GGN 2011-3445 will address the cause.Subresponse

Closure Comments:

Entergy CA DUE DATE EXTENSION CR-GGN-2011-02936 Corrective Action: CR-GGN-2011-02936 CA-00022 Version: 1 Approved:Y Requested Duedate: 09/15/2011 Previous Duedate: 08/15/2011 Requested By: Lassetter JrJohn M 08/15/2011 Approved By: Lassetter JrJohn M 08/15/2011 Request

Description:

Necessary:

U2 drains are courrently routed to UILRW processing system so no impact to environtment.

Acceptable:

More time is needed to review subject ACE and discuss findings with Eng Staff.Approved

Description:

DDE 1 approved By supv.

Entergy CORRECTIVE ACTION CR-GGN-2011-02936 CA Number: 23 Site Assigned By: GGN Assigned To: GGN Subassigned To: Group Chemistry Mgmt GGN Chemistry Mgmt GGN j1 Name Lassetter Jr,John M Originated By: Lassetter Jr,John M Performed By: Lassetter Jr,John M Subperformed By: Approved By: Closed By: Lassetter Jr,John M 6/21/2011 16:06:14 10/13/2011 13:35:39 10/13/2011 13:35:39 Current Due Date: 10/14/2011 Initial Due Date: 10/14/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Followup to ensure appropriate actions are taken or basis for no action are documented for the evaluations in Corrective Actions 10, 11, 16,19.Response: The responses to the four referenced corrective actions were reviewed.

In each case a basis was provided that no additional action was required.

This CA can be closed.Subresponse:

Closure Comments:

Entergy CA DUE DATE EXTENSION CR-GGN-2011-02936 Corrective Action : CR-GGN-2011-02936 CA-00023 Version: 1 Approved:

F/Requested Duedate: 09/28/2011 Previous Duedate: 08/31/2011 Requested By: Lassetter Jr,John M 08/30/2011 Approved By: Lassetter Jr,John M 08/30/2011 Request

Description:

Necessary:

Current workload and department staffing has impacted available resources.

Acceptable:

Monitoring of Groundwater is in place with reportability structure as required.

DDE is < 180 days from CR initiation.

Approved

Description:

DDE1 approved by Supv JEntergy I CA DUE DATE EXTENSION CR-GGN-2011-02936 Corrective Action : CR-GGN-2011-02936 CA-00023 Version: 2 Approved: Requested Duedate: 10/14/2011 Previous Duedate: 09/28/2011 Requested By: Lassetter Jr,John M 09/27/2011 Approved By: Nash,Charles L 09/27/2011 Request

Description:

Acceptable:

Followup review is in progress.

Monitoring wells are sampled regularly in accordance with the site Groundwater protection plan. Notification and reportability is addressed as needed for each sample.DDE requested is less than 180 days from CR initiation.

Necessary:

Current staffing levels have required focus on other areas. Additional time required to complete action.Approved

Description:

Approved.

Entergy CORRECTIVE ACTION CR-GGN-2011-02936 CA Number: 24 Site I Group Name Assigned By: GGN Chemistry Mgmt GGN Assigned To: GGN Chemistry Mgmt GGN Lassetter Jr,John M Subassigned To : Originated By: Lassetter Jr,John M 6/21/2011 16:13:53 Performed By: Lassetter Jr,John M 9/1/2011 09:47:42 Subperformed By: Approved By: Closed By: Lassetter Jr,John M 9/1/2011 09:47:42 Current Due Date: 09/07/2011 Initial Due Date: 09/07/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Inlcude in the CAI0 work a discussion of the impact / contribuition of tritium absorption

/ migration into concrete surfaces as a contributir to the tritium detected in Unit 2.Response: This scope was included in scope for issued contract to Key Solutions, Inc. NO further actions included for this CA.Subresponse

Closure Comments:

Entergy L CA DUE DATE EXTENSION CR-GGN-2011-02936 Corrective Action: CR-GGN-2011-02936 CA-00024 Version: 1 Approved:F Requested Duedate: 09/07/2011 Previous Duedate: 08/01/2011 Requested By: Lassetter Jr,John M 07/28/2011 Approved By: Lassetter Jr,John M 07/28/201 1 Request

Description:

Necessary:

Study has not been completed.

Contract Prep is in progress.

Est issue date 8/8/11.Acceptable:

This CA is administrative in nature and addresses the work scope in a technical evaluation.

No plant equipment is afffected and the CA does not correct a condition adverse to quality. Groundwater monitoring is ongoing.Approved

Description:

Approved DDE #1 by Supv.

Entergy I CORRECTIVE ACTION I CR-GGN-2011-02936 CA Number: 25 Assigned By: Assigned To: Subassigned To : Site GGN GGN Group Operating Experience Staff GGN Operating Experience Staff GGN Name Remskar,Andrew P Remskar,Andrew P Originated By: Remskar,Andrew P 8/1/2011 12:22:26 Performed By: Remskar,Andrew P 11/18/2011 12:39:26 Subperformed By: Approved By: Closed By: Remskar,Andrew P 11/18/2011 12:39:26 Current Due Date: 11/23/2011 Initial Due Date: 11/23/2011 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Review for sharing the ACE with the industry for posting on the INPO Nuclear Netowrk.Response: Review and discussion of this posting with the Chemistry manager determined the OE would not provide useful information because the investigation is in progress, no causes identified and action plan not developed.

Subresponse

Closure Comments:

Entergy CA DUE DATE EXTENSION CR-GGN-2011-02936 Corrective Action : CR-GGN-2011-02936 CA-00025 Version: 1 Approved:F Requested Duedate: 10/13/2011 Previous Duedate: 09/21/2011 Requested By: Remskar,Andrew P 09/20/2011 Approved By: Remskar,Andrew P 09/20/2011 Request

Description:

Due date extension is acceptable because the action is an administrative action to share the OE with the industry, it does not impact station operability or reportability.

Extension is necessary because the followup action in CA-23 are open to ensure appropriate corrective actions were taken.Approved

Description:

Extension concurred by CAA manager.

Entergy CA DUE DATE EXTENSION CR-GGN-2011-02936 Corrective Action : CR-GGN-2011-02936 CA-00025 Version: 2 Approved:Y Requested Duedate: 11/23/2011 Previous Duedate: 10/13/2011 Requested By: Remskar,Andrew P 10/12/2011 Approved By: Remskar,Andrew P 10/12/2011 Request

Description:

Extension necessary because incorporation of followup actions in CA-00023 have not been completed.

Extension acceptable because the action is to share the ACE with the industry and is an administrative action.Approved

Description:

Extension concurred with by CAA manager.

Entergy CORRECTIVE ACTION CR-GGN-2011-02936 CA Number: 26 Site Group Assigned By: GGN Timeliness Justification Senior Mgmt GGN Assigned To: GGN Chemistry Mgmt GGN Subassigned To : Name Browning,Jeremy G Nash,Charles L Originated By: Jones,Milton L 11/10/2011 11:44:13 Performed By: Nash,Charles L 11/16/2011 11:15:20 Subperformed By: Approved By: Closed By: Giles,Gerald R 11/23/2011 11:29:57 Current Due Date: 11/23/2011 Initial Due Date: 11/23/2011 CA Type: PERIODIC REVIEW Plant Constraint:

NONE CA

Description:

Perform TWO actions: (1) Document the CR Periodic (Initial)

Review and (2) State whether LTCA Classification is or is not applicable.

The necessary information should be documented and attached to your response using the EN-LI-102 Attachment 9.8 for the Review. Also, if Long Term Corrective Action (LTCA) classification is applicable, use Attachment 9.9 to document that determination.

These forms are available in the Reference Library under Nuclear Management Manual, NMM Forms.Use of the forms is not mandatory but your response must address all items listed in the CR Review section of the form.Consider applicability of LTCA classification and include a statement of the results in this CA for Director approval.This action requires closure by Director/GM thereby documenting the required review and approval level.Per LI-102, the expectation for condition report completion and closure is within 6 months. CRs exceeding or expected to exceed 6 months in age require an initial review at 6 months followed by annual periodic review.As an alternative to completing the CR Periodic Review, the CR Owner can document the manager's CR closure review.

Entergy CORRECTIVE ACTION CR-GGN-2011-02936 Response: Periodic Review: 1. Will the Interim actions taken to date adequately address the issue until all corrective actions are complete?Yes 2. Will the existing corrective actions documented in the condition report, when completed, correct the condition report issue?Yes, existing corrective actions will identify and correct the conditions.

3. What is the expected CR Closure date based on remaining needed actions?Expected closure date is 12/01/2011.

4. Determine if a new condition currently exists that potentially requires a re-evaluation of operability/functionality?

No, there are no new conditions requiring a re-evaluation of operability or functonality.

5. Are all LI-102 requirements for corrective action administration and control being met, i.e. justifications for Due Date Extensions valid, Long Term Corrective Actions identified, CARB approved CAPRs identified, and appropriate approvals obtained for all?Yes.6. What activity is "preventing" the condition report from being resolved and closed?CA#25 to reveiw for sharing with INPO.7. What risk to plant operation is imposed by the condition identified and how is risk reduced to an acceptable level for the duration of the action plan?There is no risk to plant operation.

LTCA Classification:

X -Mod/Design Change Req'd 1. What risk to plant operation is imposed by the condition identified and how is risk reduced to an acceptable level for the duration of the action plan?There is no risk to plant operation imposed by this condition.

2. Explain impact to condition report timeliness.

The evaluation of the source and determination of final corrective actions is on-going.

Further time is necessary to fully understand the issue and to resolve the issue.Subresponse:

Closure Comments: UNSAT Response.

The response states that CA-25 is the only CA preventing closure. CA-25 is closed. CA-27 was assigned the same day as the response to this CA was closed. CA-27 is assigned to "Develop action plan, based on final evaluation of cause for the tritium and corrective actions identified." The due date for CA-27 is 06/28/2012.

This due date does not appear to be timely and should be reevaluated.

The response also states that there should be a LTCA based on design modification.

However, no CA is designated and there are no open CAs for implementation of a design modification.

CA-28 assigned to address this UNSAT response.

CA closed with GMPO concurrence.

Entergy CORRECTIVE ACTION I CR-GGN-2011-02936 CA Number: 27 Assigned By: Assigned To: Subassigned To : Site I GGN GGN Group Chemistry Mgmt GGN Chemistry Mgmt GGN S Name Nash,Charles L Lassetter Jr,John M Originated By: Performed By: Subperformed By: Approved By: Closed By: Nash,Charles L 11/16/2011 11:10:46 Current Due Date: 06/27/2012 Initial Due Date: 06/28/2012 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Develop action plan, based on final evaluation of cause for the tritium and corrective actions identified.

Response: Subresponse

Closure Comments:

Entergy CORRECTIVE ACTION CR-GGN-2011-02936 CA Number: 28 Site I Group I Name Assigned By: GGN General Manager GGN Browning,Jeremy G Assigned To: GGN Chemistry Mgrnt GGN Nash,Charles L Subassigned To : Originated By: Giles,Gerald R 11/23/2011 11:29:20 Performed.By:

Giles,Gerald R 12/6/2011 07:19:47 Subperformed By: Approved By: Closed By.: Giles,Gerald R 12/6/2011 07:20:48 Current Due Date: 12/08/2011 Initial Due Date: 12/08/2011 CA Type: CA QUALITY UNSAT Plant Constraint:

NONE CA

Description:

The response to CA-26 was UNSAT. The CA-26 response states that CA-25 was the only CA preventing closure. CA-25 is closed. CA-27 was assigned the same day as the response to this CA was closed. CA-27 is assigned to "Develop action plan, based on final evaluation of cause for the tritium and corrective actions identified." The due date for CA-27 is 06/28/2012.

This due date does not appear to be timely and should be reevaluated.

The response also states that there should be a LTCA based on design modification.

However, no CA isdesignated and there are no open CAs for implementation of a design modification.

CA-28 assigned to address this UNSAT response.

Take action to address the UNSAT CA-26 response 6 y reperforming the periodic review in accordance with EN-LI-102, Attachment 9.8.Response: At the time that CA26 response was identified, CA25 was the only action to be completed.

CA-25 response was completed on 11/18/2011.

When additional information was made available, CA27 was initiated to document the need for additional information.

Attachment 9.8, Periodic Review: 1. Will the Interim actions taken to date adequately address the issue until all corrective actions are complete?Yes 2. Will the existing corrective actions documented in the condition report, when completed, correct the condition report issue?Unknown, final determination of cause and additional corrective actions, if any, are yet to be determined.

.3. What is the expected CR Closure date based on remaining needed actions?Expected closure date is unknown. Aditional wells are being drilled and a final evaluation will be performed.

CA-27 was initiated to develop a final action plan, if needed.4. Determine if a new condition currently exists that potentially requires a re-evaluation of operability/functionality?

No, there are no new conditions requiring a re-evaluation of operability or functonality.

5. Are all LI-102 requirements for corrective action administration and control being met, i.e. justifications for Due Date Extensions valid, Long Term Corrective Actions identified, CARB approved CAPRs identified, and appropriate approvals obtained for all?Yes.6. What activity is "preventing" the condition report from being resolved and closed?Completion of new wells and final verification of cause. It is unclear as to what the final activities will be at this time.CA-27 was initiated to develop a final action plan, if needed.7. What risk to plant operation is imposed by the condition identified and how is risk reduced to an acceptable level for the duration of the action plan?There is no risk to plant operation.

Although the evaluation of the source and determination of final corrective actions is on-going, this CR does not qualify for a TICA deignationn Entergy CORRECTIVE ACTION CR-GGN-2011-02936 Subresponse

Closure Comments: CA complete.

CA closed with GMPO concurrence.

Entergy CORRECTIVE ACTION I CR-GGN-2011-02936 CA Number: 29 Assigned By: Assigned To: Subassigned To : Site , GGN GGN Group Chemistry Mgmt GGN Licensing Staff GGN J Name Lassetter Jr,John M Scarbrough,Richard A Originated By: Lassetter Jr,John M 12/6/2011 14:20:01 Performed By: Scarbrough,Richard A 12/14/2011 07:39:45 Subperformed By: Approved By: Closed By: Scarbrough,Richard A 12/14/2011 07:39:45 Current Due Date: 01/05/2012 Initial Due Date: 01/05/2012 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Verify that documentation required for this CR notification by EN-RP- 113 is filed per plant retention requirements.

Attach copy to this CA.Response: NRC notification form attached.

EN# 46802 included in Reportability section of this CR and CR-GGN-2 11-2975.Notification form can be found on NRC web page.Subresponse:

Closure Comments: Attachments:

Resp Description H3 notification Notification Entergy ADMIN I CR-GGN-2011-02936 Initiated Date: 4/28/2011 11:40 Owner Site and Group: GGN Chemistry Mgmt GGN Current Contact: Current Significance:

B Closed by: Summary

Description:

The investigation into the site groundwater monitoring program indicates the following:

One set of samples collected from UNIT 2 TURBINE BLDG sumps -when analyzed at the RBS Environmental Lab for triitum showed the following initial results: East Sump 106,400 pCi/L and U2 West Sump 100,259 pCi/L. Equates to approximately IE-4 microcuries/ml.

These sumps are on the bottom elevation of the building.

Resaon for CR is that this location is outside the Unit 1 posted RCA. Chemistry now coordinating with RP staff for confinrmatory sample collection with onsite analysis for gamma and tritium. Results expected by 17:00 4/28/11.Remarks

Description:

Closure

Description:

Entergy OPERABILITY I CR-GGN-2011-02936 OperabilityVersion:

1 Operability Code: NOT REQUIRED Immediate Report Code: NOT REPORTABLE Performed By: Meyer,Ryan 0 04/28/2011 19:26 Approved By: Rogers,Charles P 04/28/2011 20:53 Operability

==

Description:==

This CR describes a condition of an SSC that is not within the scope of the Operability Determination Process. Upon discovery of this condition the temporary sump pumps in the sumps described were disabled to prevent pumping the subject water out of them. This condition does not represent any environmental impact (ODCM 6.12.1) as the samples came from sumps in the U2 Turbine Building.

This condition is still under investigation by Chemistry and RP. Any future discovery due to this investigation will be addressed in a separate CR and operability/reportability will be once again addressed.

The condition described in the CR does not meet the criteria specified by 01-S-06-5 for an event or condition immediately reportable to the NRC.Approval Comments:

.Entergy I ASSIGNMENTS I CR-GGN-2011-02936 Version: 1 Significance Code: B Classification Code: HT-ACE CARB Owner Site and Group: GGN Chemistry Mgmt GGN Performed By: Marrs,Stephen C Assignment

==

Description:==

05/05/2011 11:37 Pre-CRG Return #1 -Chemistry for coding (and alignment with NSA Director)

Entergy REPORTABILITY CR-GGN-2011-02936 Reportability Version: 1 Report Number: Report Code: REPORTABLE Boilerplate Code: REPORTABLE CALL Performed By: Seiter,Jeffery Alan 04/29/2011 13:32 Reportability

==

Description:==

The reportabiity for this condition is being made under CR-GGN-2011-2975 due to the confirmatory sample for the condition was taken and documented in that CR.Reportable as 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> call-in only. IAW 1OCFR50.72(b)(2).

The requirement is due to notification to be made to a governmental agency per EN-RP-I 13.Notification Number 46802.

ATTACHMENT

9.1 TYPICAL

HIGHER TIER APPARENT CAUSE EVALUATION

& RESPONSE TEMPLATE Sheet I of 3 Condition Report Number: Assigned Department:

GGN 2011-2936 CHEM PROBLEM STATEMENT:

On April 28, 2011 results for samples collected on Apr 7, 2011 from the Unit 2 Turbine Building East and West sumps, located outside the RCA, measured approximately 100,000 picocuries per liter tritium, which is above minimum detection limit. Additionally, the sump pumps were in automatic and are connected to storm drain piping which drains to Outfall 007.Does this ACE report require an Equipment Failure Evaluation D Yes X No (EFE)?IF Yes, THEN complete EN-LI- 119-01 Equipment Failure Evaluation and attach in PCRS IF No, THEN an EFE analysis is not required.Was an HPER assigned & performed for this CR? D] Yes X No IF Yes, THEN ensure results of the EN-HU-103 HPER are discussed in the Event Description.

EVENT DESCRIPTION:

In May 2010, GGNS detected tritium in onsite monitoring wells [groundwater].

Levels detected at that time and since then have not exceeded any reportability criteria.Reportability criteria for tritium in water samples are found in Offsite Dose Calculation Manual[ODCM] Table 6.12.1 and are > 20,000 picocuries

/ liter (pCi/l) drinking water; > 30,000 pCi/l non-drinking water, when averaged over a calendar quarter. Maximum on-site tritium measured to date in monitoring wells is 11,600 pCi/l for a single sample.An additional limitation on tritium is located in ODCM 6.11.1. This limit applies strictly to liquid discharges and is not to exceed ten times the 1OCFR20 Appendix B column II value of 1E-3 micro curies / milliliter

([tCi/ml).

This converts to 1,000,000 pCi/l.

The investigation of the monitoring well tritium detection included a review and sampling of onsite water bodies including sumps located in Unit 2. These sumps were of interest because of a known connection with the plant storm drain system. The plant storm drain system has the potential to affect ground water.Although an exact date is not available, prior to 1990, automatic sump pumps were installed in the Unit 2 Turbine Building (TB) East floor drain sump, routing input to the site storm drain system.Other pumps were installed in the U2 structure to route other sumps in the U2 turbine building to the U2 TB East sump. The original U2 piping was modified to route the U2 East Floor Drain sump pump to a section of U2 TB roof drain piping that connects to the storm drain system on East side of the U2 turbine building.

The east side of the U2 turbine building is the area where the highest levels of tritium have been detected in on-site groundwater monitoring wells. No information was located regarding an evaluation of the installation of the sumps as it relates to a potential to create an unmonitored release and no information was located indicating the U2 sumps were sampled for radioactivity prior to April 2011.As part of the review and sampling plan for tritium detection in groundwater monitoring wells, the U2 east and west turbine building sumps were sampled on April 7, 2011. These samples were processed with routine priority to an offsite counting facility at River Bend Station (RBS). RBS is the Entergy Southern fleet laboratory for environment samples. The GGNS lab facilities are not suited for environmental analysis because close proximity to the power plant increases the likelihood of false positives.

U2 turbine sump sample tritium results were received on April 28, 2011. This is an acceptable cycle time for routine sample processing.

Shorter turnaround times are available when requested.

RBS environmental lab results were: U2 East Sump 106,400 pCi/l and U2 West Sump 100,259 pCi/1 versus a minimum detection level of approximately 500 pCi/l. Condition report GGN 2011-2936 was initiated on Apr 28, 2011. Confirmatory samples were collected April 28, 2011 and on-site analysis at GGNS confirmed the RBS results.Refer to Attachment I -HISTORY, for additional background on GGNS groundwater monitoring, basis for the program and sequence of events that resulted in the self-identified condition described in CR GGN 2011-2936.

ANALYSIS and APPARENT/CONTRIBUTING CAUSE(S): A failure modes analysis (FMA) and fault tree were used to determine apparent, contributing and possible causes of the condition.

The FMA resulted in four possible failure modes. The four failure modes are discussed below.Failure modes analysis (Attachment III)(1) Unit 1 TB exhaust: Routine gaseous effluents from nuclear power plants (NPP) contain radioactive material in gaseous and particulate form. In the absence of fuel failures, gaseous tritium can be the predominant component from a concentration standpoint.

While tritium has a relatively low dose impact, if fuel failures were present, it is possible that other species (Iodine- 131) would be present in the washout (from rain events) and result in a larger dose impact.Dispersion of the gaseous effluents is affected by the height of the release point and meteorological conditions (wind speed and variance).

GGNS release points are categorized as "ground level" versus"elevated".

The distinction is based in part on the height of the release point versus height of nearby structures.

Ground level releases are typically dispersed less effectively than elevated releases.Once released, the radioactive material is available for dilution and deposition.

Competing with the dilution of the gaseous radioactive material is a condition termed "downwash" or "washout".

This results when rain fall incorporates or entrains the tritiated moisture from the plant stack, taking it to the surface in a liquid form. The effect is well documented in industry operating experience.

Supporting evidence for this failure mode includes multiple examples of tritium detection in samples of rainfall at GGNS. Field inspections identified multiple locations in the U2 structure where the roof was not maintained (i.e. open to atmosphere), allowing rainfall containing down-washed tritium to accumulate.

No refuting evidence was identified.

AC 1 Downwash of tritium in Ul Gaseous effluents by rainfall CC, Failure to maintain U2 roof/ structure to prevent rain ingress.(2) HVAC systems draining to U2 Water is condensed when air is cooled by passing across coils in air handling units (HVAC). Any tritium-containing moisture will also be condensed.

Distance of an HVAC system intake from a gaseous tritium release point will affect the amount of tritium present in the condensation.

After U2 construction was halted, various U2 areas were incorporated into the U1 radiologically controlled area [RCA]. Some consideration of radiological impact for floor drains in these locations was noted. Drains in the 133' RCA access area for decontamination showers and sinks were routed to U 1 floor drain system. But drains in other areas show minimal modification in the form of taped drains to prevent U I material from entering the drains connecting to U2 sumps. To date, no evidence has been found that the U2 HVAC drainage from areas that interface with UI was evaluated for radiological impact when these areas were incorporated into Ul.

Supporting evidence for this failure mode includes detection of tritium in U2 HVAC condensation ranging from approximately 50,000 -300,000 pCi/l. These units are located in areas that interface with Unit 1. Additional supporting evidence includes tritium measured in the Maintenance Shop HVAC condensation at approximately 8,000 pCi/l. This HVAC system is further from UI than the U2 HVAC locations and, as expected, measured a lower concentration.

Variations in U2 sump tritium concentrations were noted. Review of piping flow paths in U2 showed a correlation between the highest HVAC concentrations and the highest sump concentrations.

Operating experience review indicates this mechanism has been confirmed at multiple NPPs.No refuting evidence was identified.

AC 2 HVAC condensation

/ recapture of tritium in air CC 2 Inadequate evaluation of radiological impact for U2 areas incorporation.

O&P issue (3) Positive pressure in the U1 turbine building The U 1 ventilation system is designed to maintain a slight negative pressure in the building.

This is to reduce the likelihood of unmonitored release of radioactive materials.

This is important because there are numerous locations where U 1 and U2 air exchange is possible.

Maintaining the negative pressure as designed would decrease the likelihood ofU I air containing radioactive materials, moving into U2 spaces. This would become more important with incorporation of some U2 locations as previously discussed.

Supporting evidence includes discussion with site engineering staff that the U l ventilation system is not performing as desired and a review of the plant instrumentation readings of building pressures over a 5-year period. Data review shows a slight degradation in the negative pressure in the building over this time and a majority of positive, not negative, readings.

It should be noted that instrumentation used to monitor the pressure is in a worst-case location, the upper elevation of the building where temperatures are highest. Some periods in the data review show consistently negative readings, indicating that the system is capable of maintaining negative pressure as designed.CC 3 Inadequate maintenance of the turbine building ventilation system. O&P issue. CR GGN 2011-3445 was initiated related to this issue on May 23, 2011.Refuting evidence includes observations that inflow of air from U2 to Ut is occurring in some, but not all, locations.

This does not eliminate this failure mode but suggests the magnitude of the issue may vary with location.

The turbine deck (elev 166' and higher) temperatures can exceed 120 deg F.It is not known if the fan coil units are operating to maintain the desired temperatures.

Configuration control of the 133' elev turbine rollup door may affect the efficiency of the ventilation system. This door is normally left open to aid in cooling and to ease material movement.

Typically the door is only closed for cold weather protection.

CC 4 Configuration control / temperature control in the turbine building (4) Ul to U2 leak from radioactive system Unit 1 contains numerous liquid systems containing radioactive material.

With a 12.3 year half life and concentrations relatively high when compared to other long-lived isotopes, tritium becomes a predominant component in many of the systems. Factors affecting the composition of radioactive material in a system include the age of the material (radioactive decay allows long-lived species to dominate), fuel conditions (fuel failures result in fission products, including Cesium-137 (Cs 137), measurable well above the minimum detection level) and the effect of demineralization (N22 condensate demineralizer effluent and feedwater show relatively few insoluble species but show tritium levels comparable to the un-demineralized input). Theoretically, tritium levels in the reactor coolant system should reach equilibrium under steady state conditions

[reference EPRI TR 1009903].In reality, tritium levels in the plant are affected by feed and bleed (liquid discharges requiring volume replacement by make-up water containing no tritium).

If a plant discharges low volumes of liquid radwaste, tritium levels tend to increase in the liquid systems. System connections between U I and U2 could allow radioactive material to migrate to the U2 sumps. In addition to this pathway, tritiated water diffuses into and through many materials, including concrete.

An inspection is needed to determine the presence and condition of an isolation wall between the U2 turbine building tunnel and a U I tunnel.Refuting and supporting evidence was available for this failure mode.Refuting evidence includes the U2 sump water analysis results showing primarily tritium, with gamma emitting isotopes either not detected or limited to Cs137. The detection of Cs137 (half life 30 years) in environmental samples is typically attributed to bomb test fallout. This source has been complicated by the Chernobyl (and more recently the Fukishima) accident.

To refute Ul to U2 liquid leakage as a failure mode, additional data is needed on U 1 systems to determine the relative amounts of tritium:gamma emitting isotopes.

This data will be used to determine the absence of other gamma emitting isotopes and the presence of only Cs 137, and is adequate for discounting U1 water as a source of the tritium in U2.Supporting evidence includes common piping between U I and U2 without an understanding of the condition of boundary valves and the connecting tunnel between UI and U2.The supporting and refuting evidence warrant additional investigation.

PC 1 (possible cause) identified as U1 to U2 leakage from radioactive system(s).

Fault tree Analysis (Att. IV)After the failure modes analysis identified candidates for further investigation, a fault tree analysis was used to take each failure mode to the point of conclusion where the potential corrective actions do not change substantially at the next level. Corrective actions were assigned to each possible cause.

O&P DISCUSSION:

Two Organization and programmatic (O&P) issues were identified.

Discussion with the site Engineering staff, field observations and data review indicate the Ul turbine building ventilation system may not be maintaining a negative pressure in all areas of the building as designed.

Several Ul Turbine Building fan coils units (FCUs) are included in the most recent Top 10 Equipment Reliability listing. The item is shown to complete May 15, 2011. Proper operation of FCUs will improve conditions in the building by lowering humidity but the overall impact on building pressure is unknown. Past action to address U1 turbine building pressure concerns do not appear to have been adequate given the system performance history (reference O&P cause code OP4F: Untimely response to a known and repetitive problem).

CA13 was issued to evaluate the adequacy of the maintenance strategy for the Ul ventilation system.Likewise it was noted that the U2 structure has not been maintained.

While this has some similarities with failure to maintain systems or equipment

[Ul turbine ventilation system] it is not considered an example of an O&P issue. The differentiation is based on a decision to not maintain the U2 structure and restrictions placed on use of/access to the majority of the area. Ingress of tritiated rainfall is considered an unanticipated consequence.

The second O&P issue deals with how modification incorporating areas of U2 into the Ul RCA were evaluated for radiological impact. Industry experience has been available for at least 10 years on the impact of ventilation equipment drainage to clean (non-contaminated) systems at NPPs. While evidence exists that liquid pathways were considered in some of the modifications, no evidence was found regarding evaluation of HVAC systems' impact (reference O&P cause code OP2J: Insufficient awareness of the impact of action on safety and reliability).

CA12 was issued to evaluate the adequacy of reviewing modifications for radiological impacts.It is worth noting that the HVAC system located above the 133' access point, in the U2 turbine building, is posted with radiological restrictions to access. Drainage from this HVAC goes directly to a U2 floor drain and contained the highest concentration of tritium measured in U2 (as of this writing).

EXTENT OF CONDITION: (see Procedure step 5.3[3](f))

Numerous locations in the U2 auxiliary and turbine buildings were sampled. Results and locations are shown in Attachment II to this ACE. Tritium was detected ,in sumps, rainfall runoff collected in the U2 building and in air conditioning condensation.

Although the presence of tritium in the U2 sumps has the potential to affect site surface water and groundwater, both have independent monitoring requirements and / or condition reports driving actions to address identified issues. This extent of condition is restricted to the condition described in this condition report. Tritium was detected in U2 at levels ranging from: less than detectable (approximately

< 500 to < 700 pCi/L)to levels comparable to near-site rainfall (approximately 1,000-50,000 pCi/1)to approximately 300,000 pCi/L. (U2 HVAC condensation)

This data is consistent with industry experience found in a review of operating experience.

CA18 was issued to evaluate potential personnel exposure for the highest levels of tritium measured in U2.SAFETY IMPLICATIONS: (see Procedure step 5.3[3](g))

INDUSTRIAL SAFETY: Tritium is a radiological safety concern. Additional groundwater monitoring well installation, U2 entries for sampling, and modifications to modify flow path does include some industrial safety precautions but they are not unique to the condition described in this condition report.NUCLEAR SAFETY: There are no nuclear safety concerns.

Data collected during this investigation has not identified an impact on safe operation of the plant. Initial data collection

[tritium and gamma isotopic analyses]

does not indicate a loss of configuration control between U I and U2. Additional corrective actions issued from this ACE will validate isolation in common piping and further investigate sample data for a U1 to U2 path. The presence of tritium in the Unit I structure, while undesirable, does not affect the operation of the plant. Plant Operations staff screened the condition report and no operability concerns were noted.

RADIOLOGICAL SAFETY: the primary concern is the presence of radioactive material outside the RCA and not demarcated as a designated radioactive materials storage area (RMA). An evaluation completed in 2005 considered the public dose impact of tritium release via the storm drain system. This evaluation bounds the concentration found in the U2 structure that could have been released to the storm drain system. Based on that evaluation, a liquid tritium concentration of approximately 100,000 pCi/l would have resulted in an annual dose to a member of the public of approximately 0.025 mrem. This dose, when combined with the normal annual effluent doses, would not have resulted in an annual or quarterly dose limit exceedance

[ref GIN 2005-00562 "Outfall 007 Storm Drain Tritium Evaluation" for the evaluation of tritium in the GGNS storm drain system and ODCM 6.11 for effluent limitations].

The sump areas have been posted by radiation protection staff to restrict access and CA 18 will evaluate the potential for any plant staff exposure prior to posting.INTERNAL (Site/Fleet)

OPERATING EXPERIENCE:

Performed the following search in PCRS Database: Time frame: No time frame was entered Keywords:

Tritium The search produced 854 hits. All 854 hits were screened for items where tritium was detected in storm drains or sumps. The screening resulted in 7 applicable events. Of the 7 events 4 were due to Ventilation issues (Condensation or poor ventilation), 2 events were normal precipitation events (washout), and 1 was from a previous contaminated tank leak that was not fully mitigated.

ANO-C-2011-424

-Water on floor in Low Level Radwaste Building truck bay. Tritium concentration

-15,000 pCi/L. Apparent cause was Ventilation system in building not operating allowing migration of tritium in building into rainwater on floor. Resulting CA's were Repair Rollup Door, Implement sump level monitoring, Evaluate sump tritium activity on routine basis and determine if storm water from area is included in the ANO Storm Water Monitoring Program.IP2-2010-3275

-Surface water sample resulted in tritium concentration of -106,000 pCi/L.Apparent cause was a previous leak from a Refueling Water Storage Tank processing skid. Collect additional samples and perform remediation of dirt and gravel in the area.IP3-2009-01609

-Unexpected high tritium concentration in Storm Drain A system, March 25, 2009.Highest value detected was 90,000 pCi/L. Based on extensive sampling and troubleshooting plan evidence indicate that the increase was due to normal episodic washout, roof drains, etc. Actions are to determine if there is a need for an 80-10 evaluation, confirmation samples to support cause.

INTERNAL (Site/Fleet)

OPERATING EXPERIENCE (continued):

CR-IP3-2010-01995

-Identified unexpectedly high H-3 results in storm drain A-2 (58,000 pCi/L).Event was different than the 2009 event. No precipitation.

Apparent cause was significant increase in source term coincided with removal of the U3 FSB exhaust fan for use at U2, and no means of sweeping, removing, or mitigating the increased tritium in the pool. Therefore, atmospheric tritium also increased proportionally.

Actions are to continue sampling storm drains for gamma and H-3.Increase sample periodicity in the area to at least monthly. More frequent samples as precipitation may dictate, and send a sample out for pure beta-emitters.

Obtain Monitoring Well samples in the effected area, including transducer readings for any changing conditions over last several months.Additional samples to confirm cause.[[::JAF-2002-3695|JAF-2002-3695]]

-Measured concentrations of tritium were found in unmonitored pathways during investigation of water loss to the CST. One sump sample resulted in tritium level -143,000 pCi/L.Apparent cause was condensation of water vapor containing tritium draining from ventilation equipment into clean area sumps. Also, absorption of tritium from building environment areas and tritium inventory buildup due to zero discharge policy. Corrective actions: Perform 80-10 Evaluation/

50.59 screen for plant sump that are contaminated with H-3 and cannot be adequately decontaminated.

Evaluate proper frequencies and methods for tritium sampling and analysis of unmonitored paths.PNP-2009-0043 -Tritium has been detected in storm drain system #005 at Pilgrim Station, at a low level of 8200 pCi/L. Apparent cause of the tritium observed in the storm drain is precipitation downwash of airborne tritium released from the reactor building vent and main stack. Actions: Develop and implement a precipitation monitoring study to determine the extent of tritium atmospheric wash out. Quarterly sampling/analysis of four onsite storm drains to assess trends in tritium levels is on-going, and is performed per established PMs. Followup samples.VTY-2007-02950

-Tritium Concentration above background levels in Plant Storm Drain DMH-13 during routine surveillance.

Tritium concentrations

-2,000 pCi/L. Apparent cause is air leakage across the Turbine Building to Administration boundary.

A contributing cause is AC drainage to non-radwaste collection.

Work request to fix drainage.EXTERNAL (Industry)

OPERATING EXPERIENCE Performed the following search in the INPO Plant Events Database: Time frame: No time frame was entered Keywords:

Tritium The search produced 157 hits. All 157 hits were screened for items where tritium was detected in storm drains or sumps. The screening resulted in 6 applicable events. (OE from Internal events were captured in previous section.)

Of the 6 events 3 were due to condensation issues (Condensation or poor ventilation), 2 events were due to leaking pipes, and one event was from water from walls.

OE25092 -Measurement of Tritium in Air Conditioning Condensate and Rainfall OE25339 -Measurement of Tritium in the freezer compartments of non-frost-free refrigerators located within the protected area OE26302 -Air Conditioning Condensate Contains Tritium OE28296 -Tritium Identified in Water Leaking From Turbine Enclosure External Walls OE31178 -(Update to OE29214) Elevated Tritium Levels Identified In Storm Drain System OE31269 -Preliminary

-Elevated Tritium Levels Identified in Storm Drain System In addition, Electric Power Research Institute

{EPRI} Technical Report 1009903 "EPRI Tritium Management Model" was reviewed for applicable OE. Appendix C of the report contains 9 examples that involve ground and surface water tritium detections associated with SSC leakage, holding pond/lake discharges, HVAC condensation and concrete source terms.

Attachment

9.1 Typical

Higher Tier Apparent Cause Evaluation

& Response Template Sheet 3 of 3 ACTIONS COMPLETED (See EN-LI-i 19 step 5.3[3]0))apparent or contributing ACTION COMPLETED cause, or extent of [note any Work Orders/Requests, ER'S, other]condition issue AC Initiated WR237347 to collect / reroute U2 turbine building HVAC drainage to Ul. Note: this WR was canceled to W0277440.AC Initiated W0277440 to reroute U2 sump drainage to Ul EOC Sampled Mechanical Maintenance Shop HVAC for tritium EOC Isolated U2 sump pump from Storm Drains on April 28, 2011 PROPOSED CORRECTIVE ACTIONS (See EN-LI-i 19 step 5.3[3]0))apparent or contributing CORRECTIVE ACTION Assigned Due cause, or extent of DESCRIPTION Department Date condition issue [note any Work Orders/Requests, ER's, other]AC 1 , Downwash of tritium CA 10 Evaluate current tritium in rainfall CHEM 8/1/11 in gaseous effluents data / HVAC for environmental impact by and updating the site storm drain study (reference GIN 2005-00562).

AC 2 Recapture of tritium in water vapor by HVAC units CC, U2 structure roof leaks CA 1I Based on outcome of CA 10, CHEM 8/15/11 evaluate / recommend U2 turbine building roof repairs.CC 2 Inadequate evaluation CA 12 Determine adequacy of reviews for Rad Prot 7/15/11 of radiological impact for radiological impact when U2 areas were U2 areas incorporation.

incorporated into Unit I RCA O&P issue 4 4 CC 3 Inadequate maintenance of the turbine building ventilation system.O&P issue CAI3 Determine adequacy / timeliness of maintenance strategy to ensure U1 Turb Ventilation system performs as designed.Suggest close this CA to CR GGN 2011-3445 which has the following problem description:

Per UFSAR, section 9.4.4.5, the Turbine Building Ventilation system uses a pressure control system to maintain a slight negative pressure in the Turbine Building with respect to the atmosphere by modulating dampers located in the discharge duct of the building and in the duct return to the operating levels.However, a review of PDS points U41N031A and U41N031 B, Turbine Building Pressure, dating back to May 16, 2004 indicated that the pressure is rarely maintained negative.

Charts and point data are attached to this CR description to document the pressures dating back to 2004.SysEng 6/15/11 CC 4 Configuration control / CA 14 Determine changes needed to SysEng 8/15/11 temperature control in the configuration control / allowable turbine building temperature in turbine building (reference the current GGNS Top 10 Equipment Reliability List).PC 1 (possible cause) UI to CA15 to Develop ratios of Ul and U2 CHEM 7/1/11 U2 leakage from radioactive source terms for comparison system. CA16 to Evaluate boundary for the U I to ENG 6/30/11 U2 tunnel pathway CA17 to Review Ul to U2 piping for ENG 6/30/11 adequate boundaries EOC: possibility of CA 18 Evaluate potential personnel RP 7/15/11 personnel exposure in U2 exposure prior to restricting access to U2 prior to discovery of locations identified with tritium and condition currently posted as radiologically controlled.

TREND DATA (coordinate entry in the PCRS Trend Table of this CR): Cause Codes: Human Performance Causal Factor(s) (List all): None O&P Causal Factor(s) (List all): OP2J: Insufficient awareness of the impact of actions on safety and reliability OP4F: Untimely response to a known and repetitive problem Equipment Causal Factors (List all): None EFE Codes ((see Procedure step 5.4 [4]): INPO ER PO&C codes: N/A Failure Mode Codes: N/A evaluator: (print name) report date: JLassetter 5/25/11 Attachment I: HISTORY In 2007 the NPP industry including Grand Gulf Nuclear Station initiated a groundwater sampling program in accordance with NEI 07-07 "Groundwater Protection Initiative (GPI). The GPI contains elements necessary to minimize the likelihood of, and aid in monitoring for, radioactive contamination of groundwater.

Elements of the GPI include monitoring recommendations, communication protocols, reporting requirements and assessment recommendations.

The initial GGNS ground water (GW) monitoring program included radioactivity analyses of groundwater collected from four of the monitoring wells installed for proposed Unit 3 site characterization.

The GGNS program expanded over the next three years as a result of data collection for site specific groundwater gradients

[flow direction]

to add additional monitoring points. In May 2010, tritium was detected in some on-site locations

[reference Condition Report GGN 2010-4892].

The GGNS program initially incorporated existing construction-era wells including monitoring

[MW], de-watering

[DW] and observation

[OW] wells. In response to the tritium detection, primarily to the east north-east of the Unit II structure, seven new monitoring wells were installed in December 2010.Well location was based on placement near at-risk SSC's [below grade piping and components containing radioactive material]

and placement near the site boundary to bound locations with the highest tritium detections.

B k I; .t , 2 .:. -DW-1&MtkW-7 Tritium measurements are summarized in the table below: May 10 Jun 10 Aug 10 Sep 10 Oct 10 Nov 10 Jan 11 Mar 11 g .5 tritium tritium tritium tritium tritium tritium tritium W pCi/ l pC pC l p ipl PCi/I PCi/i pCi/i pCi/l Well "C M MW-07 1639 1731 1839 2760 6900 2027 7135 10000 DW-01 9297* 3990 8497 11600 OW-209B 3698 4230 3257 6240 6201 6813 7774 8040* first sample NOTE: MW-7 and DW-I are adjacent wells located along the east exterior wall the U2 turbine bldg exterior wall.

Attachment I, continued Following the initial detection and confirmation of positive tritium in May 2010, CR GGN 2010-4892 investigation began with focus on identifying the source of the positive tritium detections in the onsite locations.

The investigation included a review of site spill history, locating and sampling standing water bodies and prioritization of new well installation.

Current actions underway as part of the GPI include continued sampling of onsite monitoring wells, collecting additional information about downwash impact on surface water and storm water runoff, installation of additional monitoring wells, inspection of storm drain piping integrity and dye testing to map surface water movement to groundwater.

Attachment II: Table of U2 sample results, tritium, pCi/1 U2 TB U2 TB U2 TB U2 TB U2 TB RP U2 TB RP East FD West FD South CW* Tunnel WVAC HVAC Sump 93' Sump 93' sump 93' 93' 93' 133'4/7/11 106,000 100,000 4/28/11 102,000 105,000 33,500 5/3/11 99,700 111,000 19,200 238,000 5/4/11 330,000 5/5/11 224,000 5/9/11 57,700*Chemical Waste Attachment II, continued:

Map of U2 sample results z ~L -*T F.o~~1~I I D 4#

CR-GGN-2011-2975 Ente , I CONDITION REPORT TCR-GGN-20110 75 I Originator:

Causey,Michael R Originator Site Group: GGN Eng Sys EFIN Staff GGN Supervisor Name: RicheyMarty L Discovered Date: 04/29/2011 09:22 Originator Phone: 6504 Operability Required:

Y Reportability Required:

Y Initiated Date: 04/29/2011 09:37 Condition

==

Description:==

Follow up review and investigation related to CR-GGN-2011-02936 has confirmed that water from UNIT 2 Turbine Building sump has been pumped to the environment through installed sump pumps and piping connected between the sumps and the roof drains on Unit 2 Turbine Building.

The roof drains are connected to the station' s storm drain system.This confirmation

'vas made at 0852 on April 29, 2011. This CR is being generated to alert station Management to this fact such that appropriate notifications and or actions can be implemented.

Immediate Action

Description:

Actions were taken to prevent further release of water from the Unit 2 sumps by turning off the sump pumps located in the Unit 2 Turbine Building.

Information gained from physical walkdowns of Unit 2 Turbine Building were used with Drawing C0050B and A-KC2005 (Rev A) in this confirmation activity.Suggested Action

Description:

Review the requirements for notifications and or reporting of this condition.

Make reports and or notifications as appropriate.

REFERENCE ITEMS: Type Code CR MISC Item Desc CR-GGN-2011-02936 This CR does not warrant a MRFF evaluation TRENDING (For Reference Purposes Only): Trend Type WE KEYWORDS INPO BINNING HEP FACTOR REPORT WEIGHT Trend Code CYMG KW-TRITRJM CONTAMINATION CYI P I Entergy ADMIN CR-GGN-2011-02975 Initiated Date: 4/29/2011 9:37 Owner Site and Group: GGN Chemistry Mgmt GGN Current Contact: Current Significance:

D Closed by: Marrs,Stephen C 5/9/2011 13:06 Summary

Description:

Follow up review and investigation related to CR-GGN-2011-02936 has confirmed that water from UNIT 2 Turbine Building sump has been pumped to the environment through installed sump pumps and piping connected between the sumps and the roof drains on Unit 2 Turbine Building.

The roof drains are connected to the station' s storm drain system.This confirmation was made at 0852 on April 29, 2011. This CR is being generated to alert station Management to this fact such that appropriate notifications and or actions can be implemented.

Remarks

Description:

Closure

Description:

This condition report has been closed to Condition Report CR-GGN-2011-2936 CA-07. Correction of this condition will be accomplished under the actions of the referenced condition report. This and all CRs will be reviewed by the responsible department and by CA&A to identify trends requiring additional actions. If you have questions about the disposition of this CR, contact your supervisor or manager. If additional information is still needed, contact the CA&A manager, if contacting by e-mail include the CR number in the e-mail subject. mailto:jnadeal@entergy.com Partial CR

Description:

Follow up review and investigation related to CR-GGN-2011-02936 has confirmed that water from UNIT 2 Turbine Building sump has been pumped to the environment through installed sump pumps and piping connected between the sumps and the roof drains on Unit 2 Turbine Building.

The roof drains are connected to the station' s storm drain system. This confirmation was made at 0852 on April 29, 2011. This CR is being generated to alert station Management to this fact such that appropriate notifications and or actions can be implemented.

Entergy OPERABILITY CR-GGN-2011-02975 OperabilityVersion:

1 Operability Code: EQUIPMENT FUNCTIONAL Immediate Report Code: REPORTABLE-4 HOUR Performed By: Meyer,Ryan 0 04/29/2011 17:08 Approved By: Rogers,Charles P 04/29/2011 22:08 Operability

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Description:==

The condition identified in CR-GGN-2011-2936 stated that tritium was found via Chemistry samples in the Unit 2 Turbine Building sumps. These sumps are equipped with sump pumps that route their discharge to storm drains. The condition stated here is the fact that the U2 TB sump contents have been pumped to the environment.

The subject sumps are not required to be operable per TS/TRM. Tritium levels in the environment as a result of plant effluent, however, is required to be within the limits of ODCM 6.12.1. The tritium limit for water is 20000pCi/L per the ODCM. There is no evidence that the environmental limits set forth by ODCM 6.12.1 have been exceeded.

Therefore, this condition is screened as functional.

The subject sump pumps have been disabled to prevent further discharge from the U2 TB sump. Red tag C18-1-P45-056-U2 Sump Pump has been hung and locked to administratively control these pumps. The condition described in the CR meets the criteria specified by 01-S-06-5 for an event or condition reportable to the NRC by call-in within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of discovery.

Event Notification (EN) # 46802 was called in to the NRC at 1242 EDT.Approval Comments:

EntArgy ASSIGNMENT S CR-GGN-2011-02975 Version: 1 Significance Code: D Classification Code: CLOSE TO CR Owner Site and Group: GGN Chemistry Mgmt GGN Performed By: Marrs,Stephen C 05/09/2011 11:11 Assignment

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Description:==

Close to CR 2011-2936:

The investigation into the site groundwater monitoring program indicates the following:

One set of samples collected from UNIT 2 TURBINE BLDG sumps -when analyzed at the RBS Environmental Lab for triitum showed the following initial results: East Sump 106,400 pCi/L and U2 West Sump 100,259 pCi/L. Equates to approximately 1E-4 microcuries/ml.

These sumps are on the bottom elevation of the building.

Resaon for CR is that this location is outside the Unit 1 posted RCA. Chemistry now coordinating with RP staff for confinrmatory sample collection with onsite analysis for gamma and tritium. Results expected by 17:00 4/28/11.Pre-CRG Return #1 -Chemistry for coding Entergy REPORTABILITY CR-GGN-2011-02975 Reportability Version: 2 Report Number: Report Code: REPORTABLE Boilerplate Code: REPORTABLE CALL Performed By : Seiter,Jeffery Alan 05/05/2011 11:07 Reportability

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Description:==

This is version is to clarify that the documentation of the confirmatory sample was made in CR-GGN-2011-2936.

This conditon was first identified in CR-GGN-2100-2936.

The reportabiity for this condition is being made under this CR (CR-GGN-2011-2975).

Reportable as 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> call-in only. IAW IOCFR50.72(b)(2).

The requirement is due to notification to be made to a governmental agency per EN-RP-I 13.Notification Number 46802.

Entergy REPORTABILITY CR-GGN-2011-02975 Reportability Version: 1 Report Number: Report Code: REPORTABLE Boilerplate Code: REPORTABLE CALL Performed By : Seiter,Jeffery Alan 05/02/2011 10:22 Reportability

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Description:==

This conditon was first identified in CR-GGN-2100-2936.

The reportabiity for this condition is being made under this CR (CR-GGN-2011-2975) due to the confirmatory sample for the condition was taken and documented in this CR.Reportable as 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> call-in only. IAW 1OCFR50.72(b)(2).

The requirement is due to notification to be made to a governmental agency per EN-RP- 113.Notification Number 46802.