IR 05000416/2018003
| ML18317A240 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf |
| Issue date: | 11/13/2018 |
| From: | Jason Kozal NRC/RGN-IV/DRP |
| To: | Emily Larson Entergy Operations |
| References | |
| IR 2018003 | |
| Download: ML18317A240 (12) | |
Text
November 13, 2018
SUBJECT:
GRAND GULF NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000416/2018003
Dear Mr. Larson:
On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Grand Gulf Nuclear Station. On October 18, 2018, the NRC inspectors discussed the results of this inspection with Mr. R. Franssen, General Manager, Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
This finding did not involve a violation of NRC requirements.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Grand Gulf Nuclear Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Jason W. Kozal, Chief Project Branch C Division of Reactor Projects
Docket No. 50-416 License No. NPF-29
Enclosure:
Inspection Report 05000416/2018003
Enclosure U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number(s):
05000416
License Number(s):
Report Number(s):
Enterprise Identifier: I-2018-003-0008
Licensee:
Entergy Operations, Inc.
Facility:
Grand Gulf Nuclear Station
Location:
Port Gibson, Mississippi
Inspection Dates:
July 1, 2018 to September 30, 2018
Inspectors:
T. Steadham, Senior Resident Inspector
N. Day, Resident Inspector
L. Newman, Project Engineer
C. Young, Senior Project Engineer
Approved By:
Jason W. Kozal
Branch Chief
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at Grand Gulf Nuclear Station Unit 1 in
accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs
program for overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information. A self-revealed
finding and additional items are summarized in the tables below.
List of Findings and Violations
Failure to Develop Adequate Work Instructions
Cornerstone
Significance
Cross-cutting
Aspect
Inspection
Procedure
Mitigating
Systems
Green
Closed
H.9 - Human
Performance,
Training
71111.13 -
Maintenance
Risk
Assessments
and
Emergent
Work Control
A self-revealed, Green finding was identified when feedwater heater drain tank oscillations
caused a feedwater perturbation which required a manual reactor scram. Specifically, the
licensee failed to develop appropriate work instructions for filling and venting the feedwater
heater 6A level transmitters.
Additional Tracking Items
Type
Issue number
Title
Inspection
Procedure
Status
Grand Gulf Unplanned
Power Changes per 7000
Critical Hours Performance
Indicator
71151 -
Performance
Indicator
Verification
Closed
PLANT STATUS
Unit 1 began this inspection period shutdown for Refueling Outage 21. The unit was started up,
following Refueling Outage 21, on July 14, 2018. On July 30, 2018, due to issues with the
recirculation system protection logic, reactor power was reduced from approximately 82 percent
power to approximately 27 percent power. The unit reached full rated thermal power on
August 16, 2018. On August 21, 2018, due to a partial loss of feedwater heaters, power was
reduced to approximately 62 percent power. The unit reached full rated thermal power on
August 27, 2018. On September 14, 2018, the reactor was manually scrammed due to a partial
loss of feedwater. The unit was restarted on September 18, 2018. The unit finished the
inspection period during startup activities at approximately 95 percent power.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/
reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were
declared complete when the IP requirements most appropriate to the inspection activity were
met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed plant status activities described in
IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem
Identification and Resolution. The inspectors reviewed selected procedures and records,
observed activities, and interviewed personnel to assess licensee performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01Adverse Weather Protection
Summer Readiness (1 Sample)
The inspectors evaluated summer readiness of offsite and alternate alternating
current power systems.
Impending Severe Weather (1 Sample)
The inspectors evaluated readiness for impending adverse weather conditions for tropical
storm Gordon on September 4, 2018.
71111.04Equipment Alignment
Partial Walkdown (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Reactor core isolation cooling system due to recent refueling outage configuration on
August 12, 2018
(2) Division 1 Direct Current battery on August 20, 2018
(3) Standby liquid control subsystem B on September 6, 2018
(4) High pressure core spray on September 25, 2018
Complete Walkdown (1 Sample)
The inspectors evaluated system configurations during a complete walkdown of the residual
heat removal subsystem B on August 29, 2018.
71111.05AQFire Protection Annual/Quarterly
Quarterly Inspection (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected
areas:
(1) Lower cable spreading room, Fire Area 42, Zone OC402, on July 6, 2018
(2) Turbine building elevation 113 feet due to welding modification, Zone 1T108, on
July 16, 2018
(3) Main control room due to excessive storage in Unit 2, Fire Area 50, Zone OC503, on
July 31, 2018
(4) Emergency diesel breezeway due to deluge valve work, Fire Area 60, Zone 1D301, on
August 16, 2018
(5) Division 1 battery room and switchgear room, Fire Area 31, Zone OC202, on
September 11, 2018
Annual Inspection (1 Sample)
The inspectors evaluated fire brigade performance on August 24, 2018.
71111.06Flood Protection Measures
Internal Flooding (2 Samples)
The inspectors evaluated internal flooding mitigation protections in:
(1) Residual heat removal pump room B on September 5, 2018
(2) High pressure core spray pump room on September 25, 2018
71111.11Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 Sample)
The inspectors observed and evaluated a simulated anticipated transient without scram and
simulated auxiliary building flooding due to fire water piping break on August 9, 2018.
Operator Performance (2 Samples)
The inspectors observed and evaluated operator performance in the control room on:
(1) Reactor recirculation pump upshift on August 1, 2018
(2) Reactor startup and control rod withdrawal following forced outage due to manual reactor scram on September 18, 2018
71111.12Maintenance Effectiveness
Routine Maintenance Effectiveness (2 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with
the following equipment and/or safety significant functions:
(1) T46 emergency safeguard feature switchgear room cooling system on
September 30, 2018
(2) T51 emergency pump room ventilation system on September 30, 2018
Quality Control (1 Sample)
The inspectors evaluated maintenance and quality control activities associated with the
following equipment performance issues:
(1) Reactor core isolation cooling turbine oil commercial grade dedication and condition
monitoring as a result of out of specification oil sample results on September 10, 2018
71111.13Maintenance Risk Assessments and Emergent Work Control (3 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work
activities:
(1) Elevated risk due to residual heat removal A heat exchanger bypass valve failure on
August 24, 2018
(2) Elevated Yellow risk due to planned standby service water outage on August 15, 2018
(3) Feedwater heater 6A level transmitter calibration on September 24, 2018
71111.15Operability Determinations and Functionality Assessments (4 Samples)
The inspectors evaluated the following operability determinations and functionality
assessments:
(1) Reactor core isolation cooling outboard isolation valve 1E51F064 operability with
missing pipe insulation, Condition Report CR-GGN-2018-08565, on August 2, 2018
(2) Scaffolding not meeting procedural rattle space requirement, Condition
Report CR-GGN-2018-09366, on August 15, 2018
(3) Residual heat removal A flow element 1E12N014A bolts over torqued, Condition
Report CR-GGN-2018-06882, on August 17, 2018
(4) Out of specification reactor core isolation cooling turbine oil sample results, Condition
Report CR-GGN-2018-10179, on September 10, 2018
71111.18Plant Modifications (1 Sample)
The inspectors evaluated the following permanent modification:
(1) Weld repair to high pressure turbine drain on August 1, 2018
71111.19Post Maintenance Testing (3 Samples)
The inspectors evaluated the following post maintenance tests:
(1) Standby service water B following planned maintenance outage on August 14, 2018
(2) Residual heat removal A heat exchanger bypass valve E12F034A stem nut replacement
on August 27, 2018
(3) Division 1 emergency diesel generator governor replacement on August 27, 2018
71111.22Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine (3 Samples)
(1) Reactor recirculation pump surveillance on July 27, 2018
(2) Reactor recirculation jet pump surveillance on July 27, 2018
(3) Intermediate range Channel B calibration on August 17, 2018
In-service (1 Sample)
(1) Residual heat removal A heat exchanger bypass valve inservice testing following
maintenance on August 27, 2018
OTHER ACTIVITIES - BASELINE
71151Performance Indicator Verification (1 Sample)
The inspectors verified the licensee performance indicator submittal listed below:
(1)
BI02: Reactor Coolant System Leak Rate Sample (10/01/2017-06/30/2018)
71152Problem Identification and Resolution
Annual Follow-up of Selected Issues (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issue:
(1) Review of Division 2 battery inverter high frequency on September 11, 2018
71153Follow-up of Events and Notices of Enforcement Discretion
Events (3 Samples)
The inspectors evaluated:
(1) Recirculation pump downshift to slow speed on July 30, 2018
(2) Plant and operator response to feedwater heater 5A isolation on August 21, 2018
(3) Plant and operator response to manual reactor scram due to partial loss of feedwater on
September 14, 2018
INSPECTION RESULTS
Failure to Develop Adequate Work Instructions
Cornerstone
Significance
Cross-cutting
Aspect
Inspection
Procedure
Green
Closed
H.9 - Human
Performance,
Training
71111.13 -
Maintenance
Risk
Assessments
and Emergent
Work Control
A self-revealed, Green finding was identified when feedwater heater drain tank oscillations
caused a feedwater perturbation which required a manual reactor scram. Specifically, the
licensee failed to develop appropriate work instructions for filling and venting the feedwater
heater 6A level transmitters.
Description: On September 14, 2018, maintenance personnel were backfilling the feedwater
heater (FWH) 6A level transmitters 1N23N059A and 1N23N061A under Work Order 486066
to troubleshoot feedwater heater level oscillations.
At the digital feedwater control (INFI-90) control panel, maintenance personnel toggled the
N059A transmitter out of service. Because of the troubleshooting, the 6A FWH level was
being maintained at 0 inches, which caused the N061A transmitter to read downscale. As a
result, the INFI-90 logic determined that the N061A transmitter input was of bad quality.
INFI-90 compared the N059A and N061A values to determine which transmitter to use. The
N059A transmitter was being backfilled at the time, and was indicating approximately
15 inches.
In accordance with system design, because of the difference in values between the
two transmitters, INFI-90 determined that the N061A had failed and auto swapped to the
N059A transmitter, which was toggled out of service and was indicating a higher than actual
level. With the level controller in automatic and set to 3 inches, and detecting a level of
15 inches as indicated by N059A, the FWH 6A drain valve fully opened in an attempt to
restore level. Heater drain tank level began oscillating, resulting in a trip of condensate
booster pump A and a subsequent main feedwater pump A trip. With the feed pump tripped,
reactor water level began lowering. When reactor water level reached 13 inches and
continued lowering, operators initiated a manual reactor scram prior to water level reaching
the Level 3 automatic scram setpoint (11.4 inches). Water level subsequently stabilized in
the normal level band. All safety systems functioned as designed.
Plant personnel were unaware that the INFI-90 system would function in this manner.
Consequently, the work order lacked sufficient controls to ensure that a feedwater transient
would not be caused by an automatic swap over to the transmitter being worked on.
Corrective Actions: Licensee corrective actions included tuning the feedwater heater and
feedwater heater drain tank level control valves and initiating a root cause evaluation of the
event.
Corrective Action Reference: The licensee entered the issue into their corrective action
program as Condition Report CR-GGN-2018-10441.
Performance Assessment:
Performance Deficiency: The failure to provide adequate instructions in Work Order 486066
to prevent a feedwater transient and subsequent scram was a performance deficiency. As
required by licensee Procedure EN-WM-105, Planning, Revision 23, step 1.1, a minimum
level of direction and instruction must be provided for successful completion of the work to
prevent unexpected plant reactions. This was within the licensees ability to foresee and
correct because the licensee possessed the documented basis for the applicable operational
characteristics of the INFI-90 system prior to conducting maintenance activities.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the procedure quality attribute of the Initiating Events
Cornerstone and adversely affected the objective to limit the likelihood of events that upset
plant stability. Specifically, the performance deficiency contributed to the need for operators
to initiate a plant scram.
Significance: The inspectors assessed the significance of the finding using Inspection
Manual Chapter 0609, Appendix A, Exhibit 1, Section B. Since the finding did not cause the
loss of mitigation equipment relied upon to transition the plant from the onset of the scram to
a stable shutdown condition, the finding was determined to be of very low safety significance
(Green). Specifically, the finding did not cause a complete loss of feedwater.
Cross-cutting Aspect: The finding had a cross-cutting aspect in the area of human
performance associated with training, because the licensee failed to ensure knowledge
transfer to maintain a knowledgeable, technically competent workforce with regards to the
operation of the INFI-90 digital feedwater control system.
Enforcement: Inspectors did not identify a violation of regulatory requirements associated
with this finding.
Minor Violation
71151 -
Performance
Indicator
Verification
Minor Violation: The licensee did not include any unplanned power changes as inputs for the
Unplanned Power Changes per 7,000 Critical Hours performance indicator (PI) that was
reported to the NRC for the second quarter 2016. Based on a plant event that took place on
June 17, 2016, the inspectors noted that the PI data submitted by the licensee may not have
been accurate. In response, the licensee submitted frequently asked question (FAQ) 17-01 to
the reactor oversight process working group. This FAQ resulted in the determination that
three unplanned power changes should have been reported associated with the event in
question. Following resolution of the FAQ, the licensee reported the associated PI data.
As required by 10 CFR 50.9, Completeness and accuracy of information, information
provided to the NRC by a licensee shall be complete and accurate in all material respects.
Contrary to the above, from July 2016 through May 2017, information provided to the NRC by
the licensee was not complete and accurate in all material respects. Specifically, the data for
the Unplanned Power Changes per 7,000 Critical Hours PI did not include any unplanned
power changes for the second quarter 2016.
Screening: The inspectors determined that this violation was of minor significance in
accordance with the NRC Enforcement Policy, Section 6.9.d.11, since the PI data in question
did not ultimately result in the PI changing from Green to White.
Enforcement: The licensee entered this issue into their corrective action program as
Condition Report CR-GGN-2016-06028. The licensee took action to restore compliance by
submitting an appropriate correction to the PI data. This failure to comply with 10 CFR 50.9
constitutes a minor violation that is not subject to enforcement action in accordance with the
NRCs Enforcement Policy.
The disposition of this violation closes URI 05000416/2017001-02, Grand Gulf Unplanned
Power Changes per 7000 Critical Hours Performance Indicator.
EXIT MEETINGS AND DEBRIEFS
On October 18, 2018, the inspectors presented the quarterly resident inspector inspection
results to Mr. R. Franssen, General Manager Plant Operations, and other members of the
licensee staff. The inspectors verified no proprietary information was retained or documented in
this report.
SUNSI Review
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: JWK
Yes No
Publicly Available
Sensitive
OFFICE
SRI:DRP/C
RI:DRP/C
BC:DRS/EB1
BC:DRS/EB2
BC:DRS/OB
BC:DRS/PSB2
NAME
TSteadham
NDay
TFarnholtz
GWerner
VGaddy
HGepford
SIGNATURE
TCS
NHD
TRF
GEW
vgg
hjg
DATE
11/02/2018
11/02/2018
10/30/2018
10/30/2018
10/31/18
10/30/18
OFFICE
TL:DRS/IPAT
SPE:DRP/C
BC:DRP/C
NAME
GMiller
CYoung
JKozal
SIGNATURE
gbm
CHY
JWK
DATE
10/31/18
10/30/2018
11/13/2018