ML20127J013
| ML20127J013 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 05/06/2020 |
| From: | Jason Kozal NRC/RGN-IV/DRP/RPB-C |
| To: | Emily Larson Entergy Operations |
| References | |
| IR 2020001 | |
| Download: ML20127J013 (23) | |
See also: IR 05000416/2020001
Text
May 6, 2020
Mr. Eric Larson
Site Vice President
Entergy Operations, Inc.
Grand Gulf Nuclear Station
P.O. Box 756
Port Gibson, MS 39150
SUBJECT: GRAND GULF NUCLEAR STATION - INTEGRATED INSPECTION
REPORT 05000416/2020001
Dear Mr. Larson:
On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at Grand Gulf Nuclear Station. On April 7, 2020, the NRC inspectors discussed the results of
this inspection with you and other members of your staff. The results of this inspection are
documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding
involved a violation of NRC requirements. We are treating this violation as a non-cited violation
(NCV) consistent with Section 2.3.2 of the Enforcement Policy.
A licensee-identified violation which was determined to be of very low safety significance is also
documented in this report. We are treating this violation as a non-cited violation (NCV)
consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance of the violations documented in this inspection
report, you should provide a response within 30 days of the date of this inspection report, with
the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document
Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator,
Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Grand Gulf
Nuclear Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the
NRC Resident Inspector at Grand Gulf Nuclear Station.
E. Larson 2
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public
Inspections, Exemptions, Requests for Withholding.
Sincerely,
Jason W. Digitally signed by Jason
W. Kozal
Kozal Date: 2020.05.06 16:04:18
-05'00'
Jason W. Kozal, Chief
Reactor Projects Branch C
Division of Reactor Projects
Docket No. 05000416
License No. NPF-29
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
Non-Sensitive Publicly Available
SUNSI Review
Sensitive Non-Publicly Available
OFFICE SRI:DRP/C RI:DRP/C BC:DRS/EB1 BC:DRS/EB2 BC:DRS/OB
NAME TSteadham MThomas VGaddy NTaylor GWerner/GEW
DATE 4/22/2020 04/23/2020 04/23/2020 04/22/2020 04/22/2020
OFFICE BC:DRS/RCB TL:DRS/IPAT BC:DNMS/RIB SPE:DRP/C BC:DRP/C
NAME MHaire AAgrawal ANA GWarnick GGW CYoung JKozal
DATE 04/22/2020 04/27/2020 04/23/2020 04/22/2020 05/06/2020
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number: 05000416
License Number: NPF-29
Report Number: 05000416/2020001
Enterprise Identifier: I-2020-001-0004
Licensee: Entergy Operations, Inc.
Facility: Grand Gulf Nuclear Station
Location: Port Gibson, MS
Inspection Dates: January 1, 2020 to March 31, 2020
Inspectors: I. Anchondo-Lopez, Reactor Inspector
D. Antonangeli, Health Physicist
M. Chambers, Physical Security Inspector
N. Greene, PhD, Senior Health Physicist
J. Melfi, Project Engineer
T. Steadham, Senior Resident Inspector
M. Thomas, Resident Inspector
C. Young, Senior Project Engineer
Approved By: Jason W. Kozal, Chief
Reactor Projects Branch C
Division of Reactor Projects
Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at Grand Gulf Nuclear Station, in
accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs
program for overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information. A licensee-
identified non-cited violation is documented in report Section 71153.
List of Findings and Violations
Failure to Follow Procedures with an Improper Entry into a High Radiation Area
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green [H.11] - 71124.01
Radiation Safety NCV 05000416/2020001-01 Challenge the
Open/Closed Unknown
The inspectors reviewed a self-revealed Green finding and associated non-cited violation of
Technical Specification 5.4.1 for a failure to follow procedures, which resulted in an improper
entry into a high radiation area. Specifically, on March 3, 2020, a worker received a dose rate
alarm after entering a high radiation area in an overhead section of the drywell without first
contacting radiation protection or receiving a briefing to be aware of the actual dose rates in
the area, as required by radiation protection procedures and the radiological work permit.
Additional Tracking Items
Type Issue Number Title Report Section Status
LER 05000416/2016009-01 Entry into Mode of 71153 Closed
Applicability with the
Oscillation Power Range
Monitor Upscale Settings
Incorrectly Set
LER 05000416/2018008-00 Unplanned System Actuation 71153 Closed
(Diesel Generator) Caused
by Inadvertently Opening the
Wrong Fuse Drawer
LER 05000416/2017-007-01 Engineered Safety Features 71153 Closed
System Actuations due to
the Loss of Engineered
Safety Features
Transformer 11
2
PLANT STATUS
Grand Gulf Nuclear Station, Unit 1, began this inspection period at 95 percent reactor power.
On January 3, 2020, power was lowered to 65 percent for control rod pattern improvement. The
unit was returned to 98 percent power on January 8, 2020. On January 9, 2020, power was
lowered to 71 percent for a rod pattern improvement. The unit returned to rated thermal power
on January 10, 2020. On February 22, 2020, the unit was shut down for refueling outage 22
and remained shut down for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved
IPs with their attached revision histories are located on the public website at
http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.
Samples were declared complete when the IP requirements most appropriate to the inspection
activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor
Inspection Program - Operations Phase. From January 1 - March 19, 2020, 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.
Starting on March 20, 2020, in response to the National Emergency declared by the President
of the United States on the public health risks of the coronavirus (COVID-19), resident
inspectors were directed to begin telework and to remotely access licensee information using
available technology. During this time the resident inspectors performed periodic site visits
each week and during that time conducted plant status activities as described in IMC 2515,
Appendix D; and observed risk-significant activities when warranted. In addition, resident and
regional baseline inspections were evaluated to determine if all or a portion of the objectives
and requirements stated in the IP could be performed remotely. If the inspections could be
performed remotely, they were conducted per the applicable IP. In the cases where it was
determined the objectives and requirements could not be performed remotely, management
elected to postpone and reschedule the inspection to a later date.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Residual heat removal pump C while in cooldown on February 27, 2020
(2) Residual heat removal A while in shutdown cooling on March 2, 2020
3
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated system configurations during a complete walkdown of the
reactor core isolation cooling system during the Division 3 maintenance outage on
January 8, 2020.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1) Emergency diesel generator building on February 27, 2020
(2) Fire water pump house on February 28, 2020
(3) Residual heat removal A pump room on March 4, 2020
(4) Reactor core isolation cooling room on March 4, 2020
(5) Division 1 standby service water pump room on March 5, 2020
(6) Residual heat removal B pump room on March 9, 2020
71111.07A - Heat Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
(1) Division 3 emergency diesel generator jacket water heat exchanger A and B
inspections and cleaning, Work Orders 52791443 and 52790008, on January 7, 2020
71111.08G - Inservice Inspection Activities (BWR)
BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding
Activities (IP Section 03.01) (1 Sample)
(1) The inspectors verified that the reactor coolant system boundary, reactor vessel
internals, risk-significant piping system boundaries, and containment boundary were
appropriately monitored for degradation and that repairs and replacements were
appropriately fabricated, examined, and accepted by reviewing the following activities
from March 2-5, 2020:
03.01.a - Nondestructive Examination and Welding Activities.
1. Ultrasonic Examination
a. Weld 1B21G025W17, Feedwater System - Pipe-to-Flued Head
circumferential weld
b. Weld 1B21G026W1, Feedwater System - Pipe-to-Flued Head
circumferential weld
4
c. 1B21F028D, Feedwater System - Bolt/Stud ultrasonic inspection
d. 1B21G026W4, Feedwater System - Valve-to-Pipe circumferential weld
e. N02C-IR, Reactor Coolant System - Inlet Nozzle to Reactor Pressure
Vessel Inner Radius Weld
Problem Identification and Resolution
The inspector reviewed 18 notifications that dealt with inservice inspections issues
and found that items were entered into the corrective action program at the
appropriate level and adequately addressed.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(2 Samples)
(1) The inspectors observed and evaluated licensed operator performance in the control
room during control rod sequence exchange on January 3, 2020.
(2) The inspectors observed and evaluated licensed operator performance in the control
room during shutdown for Refueling Outage 22 on February 22, 2020.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components remain capable of performing their intended function:
(1) Reactor core isolation cooling 10-year overhaul inspection on March 6, 2020
(2) Reactor core isolation cooling maintenance rule review on March 25, 2020
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed:
(1) Risk management for the Division 3 maintenance outage during the week of
January 6, 2020
(2) Outage risk management during the week of March 9, 2020
(3) Risk management while residual heat removal A in shutdown cooling on
March 6, 2020
(4) Foreign material exclusion risk to reactor core during fuel movement on
March 5, 2020
(5) Yellow outage risk management during recirculation pump B seal replacement and
control rod drive mechanism removal on March 15, 2020
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71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1) Reactor pressure and turbine control valve oscillations at 87 percent reactor power on
January 24, 2019
(2) Scram discharge volume vent and drain valves 1C11F010 and 1C11F011 after failure
to meet surveillance test procedure acceptance criteria on February 12, 2020
(3) Seismic qualification of jet pump plugs, Engineering Change 86247, on
March 31, 2020
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
(1) New procedure issuance: Procedure 02-S-01-45, "Water Inventory Control,"
Revision 0, on February 28, 2020
(2) Engineering Change 85565 replacement of the Division 3 emergency diesel
generator speed switch following its failure on March 31, 2020
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the following post maintenance test activities to verify system
operability and functionality:
(1) Division 3 emergency diesel generator post maintenance test following an extended
maintenance outage on January 10, 2020
(2) Division 3 emergency diesel generator speed switch and mag pickup functional post
maintenance test following replacement on January 20, 2020
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated outage-related activities from February 22, 2020,
through March 31, 2020
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01) (3 Samples)
(1) Fire protection system testing on March 3, 2020
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(2) Division 2 emergency core cooling system testing on March 26, 2020
(3) Containment electrical penetration local leak-rate test on March 4, 2020
Inservice Testing (IP Section 03.01) (1 Sample)
(1) Standby liquid control pump B quarterly inservice test on January 16, 2020
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
(1) Suppression pool water level penetrations local leak-rate test on March 5, 2020
FLEX Testing (IP Section 03.02) (1 Sample)
(1) 1FLEXS010 480 V battery charger emergency diesel generator annual operational
test on January 14, 2020
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated how the licensee identified the magnitude and extent of
radiation levels and the concentrations and quantities of radioactive materials and
how the licensee assessed radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated radiological protection-related instructions to plant workers.
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors evaluated licensee processes for monitoring and controlling contamination
and radioactive material.
(1) The inspectors observed workers donning and doffing personal protection equipment
at the contaminated drywell entry/exit point.
(2) The inspectors observed the actions of workers while performing tasks in the
contaminated areas of the drywell during the refueling outage.
(3) The inspectors observed the radiation protection staff perform surveys of potentially
contaminated material leaving the radiologically controlled area (RCA) and workers
monitored via the personnel contamination monitors as they exited the RCA during
the refueling outage.
7
Radiological Hazards Control and Work Coverage (IP Section 03.04) (5 Samples)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and
observation of radiological work activities.
(1) Radiation Work Permit (RWP) 2020-1502, "Drywell Coordinator, Safety and NRC
Walkdowns/Tours in the Drywell"
(2) RWP 2020-1509, "General Decon Activities and Support for the Drywell"
(3) RWP 2020-1510, "Visually Inspect/Remove/Test/Replace Snubbers in RF-22"
(4) RWP 2020-1511, "General Maintenance in the Drywell During RF-22"
(5) RWP 2020-1915, "Emergent Work for Maintenance, Tours and Inspections"
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very
(1) Turbine Building Areas (87-foot level and 133-foot level)
(2) AUX Building Areas (128-foot level, 180-foot level, 208-foot level)
(3) Containment Areas (161-foot level, 170-foot level, 208-foot level)
(4) Offgas Charcoal Vault Area (93-foot level)
(5) Radwaste Building Reactor Water Cleanup Phase Separator Decay Tank Area
(118-foot level)
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP
Section 03.06) (1 Sample)
(1) The inspectors evaluated radiation worker and radiation protection technician
performance as it pertains to radiation protection requirements.
71124.02 - Occupational ALARA Planning and Controls
Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (4 Samples)
The inspectors evaluated the licensees communication of as low as is reasonably
achievable (ALARA) and radiological work controls for the following work activities:
(1) RWP 2020-1502, "Drywell Coordinator, Safety and NRC Walkdowns/Tours in the
Drywell"
(2) RWP 2020-1509, "General Decon Activities and Support for the Drywell"
(3) RWP 2020-1510, "Visually Inspect/Remove/Test/Replace Snubbers in RF-22"
(4) RWP 2020-1915, "Emergent Work for Maintenance, Tours and Inspections"
Radiation Worker Performance (IP Section 03.04) (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance
during:
(1) The inspectors evaluated the implementation of ALARA techniques for work activities
during Refueling Outage 22.
8
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (1 Sample)
(1) January 1, 2019 - December 31, 2019
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)
(1) January 1, 2019 - December 31, 2019
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
(1) January 1, 2019 - December 31, 2019
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
(1) July 1, 2019 - December 31, 2019
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual
Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample
(IP Section 02.16) (1 Sample)
(1) July 1, 2019 - December 31, 2019
71153 - Follow-up of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02) (3 Samples)
The inspectors evaluated the following licensee event reports (LERs):
(1) LER 05000416/2016-009-01, Entry into Mode of Applicability with the Oscillation
Power Range Monitor Upscale Settings Incorrectly Set (ADAMS Accession
No. ML17228A275). The inspection conclusions associated with this LER are
documented in this report as a licensee-identified non-cited violation in the Inspection
Results.
(2) LER 05000416/2017-007-01, Engineered Safety Features System Actuations due to
the Loss of Engineered Safety Features Transformer 11 (ADAMS Accession
No. ML18346A393). The inspectors determined that the licensee's cause evaluation
associated with the issue identified that the licensee's procedures for conducting
Tan-Delta cable testing had previously failed to include a requirement to perform
cable shielding continuity testing. This performance deficiency was identified by the
licensee as being associated with a possible missed opportunity to identify cable
degradation prior to failure (not as being the direct cause of this event). The
inspectors determined that the safety significance associated with this issue was not
more than very low safety significance (Green). The testing of cables associated with
an offsite power circuit was a nonsafety-related activity. The inspectors did not
identify a violation of NRC requirements.
9
(3) LER 05000416/2018-008-00, Unplanned System Actuation (Diesel Generator)
Caused by Inadvertently Opening the Wrong Fuse Drawer (ADAMS Accession
No. ML18187A402). The inspection conclusions associated with this LER are
documented in this report as a minor violation in the Inspection Results.
INSPECTION RESULTS
Failure to Follow Procedures with an Improper Entry into a High Radiation Area
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green [H.11] - 71124.01
Radiation Safety NCV 05000416/2020001-01 Challenge the
Open/Closed Unknown
The inspectors reviewed a self-revealed Green non-cited violation of Technical
Specification 5.4.1 for a failure to follow procedures, which resulted in an improper entry into
a high radiation area. Specifically, on March 3, 2020, a worker received a dose rate alarm
after entering a high radiation area in an overhead section of the drywell without first
contacting radiation protection or receiving a briefing to be aware of the actual dose rates in
the area, as required by radiation protection procedures and the radiological work permit.
Description: On March 3, 2020, the licensee briefed two workers for entry into the drywell to
identify some snubber components. The briefing informed the workers that they would enter
a maximum general area dose rate of 20 millirem per hour on their job travel path and work
area. However, one of the workers climbed into a normally inaccessible overhead piping
area of the drywell to identify the serial number on a snubber, causing his self-reading
dosimeter (SRD) to alarm unexpectedly. His SRD recorded a maximum dose rate of
802 millirem per hour; the dose rate alarm set-point was 300 millirem per hour. The individual
was signed onto Task 1 of radiation work permit (RWP) 2020-1510. Task 1 was a high
radiation area task, but the worker had not been briefed for entry into the specific overhead
area within the high radiation area. Once the worker identified the alarm, the individual
climbed down from the overhead area, informed his co-worker, and they both exited the RCA
to contact radiation protection (RP).
The RAD Worker Instructions section of RWP 2020-1510, Task 1, included the following
statements:
Be aware of and stay away from Hot spots/pipes
Contact RP [radiation protection] for High Radiation Area entry requirements
Contact RP prior to work in normally inaccessible area for current radiological
conditions and protective requirements
Procedure EN-RP-101, Access Control for Radiologically Controlled Areas, Revision 14,
Section 5.4, required a brief of personnel entering high radiation areas on the radiological
conditions, and access was allowed only after dose rates in the area were determined and
entry personnel were made aware of them.
Procedure EN-RP-100, Radiation Worker Expectations, Revision 12, Section 5.3 [4], stated
that No entry to areas above seven [7] feet is permitted without prior permission from
[radiation protection] RP. The overhead piping area entered was above 7 feet from the floor
level and was normally inaccessible and not typically surveyed. Also, in this procedure,
10
Section 5.3 [19] stated, in part, that to enter a high radiation area, the radiation worker must
be briefed and sign on the appropriate RWP. Section 5.4 [1] stated, in part, Compliance with
an RWP is a legal requirement. Failure to comply could result in NRC violation.
As allowed by procedure, the overhead area the worker entered had not been surveyed or
posted by RP prior to his entry, as there were no work plans for this area and it was deemed
inaccessible. After the dose rate alarm, a follow-up survey identified dose rates in the
overhead piping area, near the snubber, as approximately 3500 millirem per hour on contact
and 800 millirem per hour at 30 cm. The RP staff then posted the overhead as an area with
elevated dose rates. The licensee believes the individual utilized a nearby ladder to access
the overhead area. The ladder was not posted as Contact RP prior to working or climbing
above 7 feet or controlled, as required by licensee Procedure EN-RP-108, Radiation
Protection Posting.
Corrective Actions: The licensee assessed this issue and implemented multiple immediate
corrective actions. Some of the actions taken included:
All involved parties were interviewed and coached
The individual was restricted from the RCA and placed in the licensees performance
management process
The occurrence was placed in the Site Outage Status Report to inform all licensee
staff of the requirements to follow RWP instructions and licensee procedures
Corrective Action References: This issue was placed into the corrective action program as
Condition Report CR-GGN-2020-02586.
Performance Assessment:
Performance Deficiency: A radiation worker failed to follow procedures and made an
improper entry into a high radiation area.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the program and process attribute of the Occupational
Radiation Safety Cornerstone and adversely affected the cornerstone objective to ensure the
adequate protection of the worker health and safety from exposure to radiation from
radioactive material during routine civilian nuclear reactor operation. Specifically, the failure
to follow requirements involving radiological controls had the potential to increase the
individuals dose. In addition, the inspectors reviewed NRC Inspection Manual Chapter 0612,
Appendix E, Examples of Minor Issues, to inform the more-than-minor determination.
Although Example 6.g was similar, there were no current examples that appropriately fit the
consequences of this occurrence. The failure to follow procedural requirements and making
an improper entry into the overhead area, within the high radiation area, resulted in an
exposure of roughly 40 times the general area dose rates for which the individual was briefed.
Significance: The inspectors assessed the significance of the finding using Inspection
Manual Chapter 0609, Appendix C, Occupational Radiation Safety SDP. The inspectors
determined the finding to be of very low safety significance (Green) because (1) it was not
associated with as low as is reasonably achievable (ALARA) planning or work controls;
(2) there was no overexposure; (3) there was no substantial potential for an overexposure;
and (4) the ability to assess dose was not compromised.
11
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with
uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, the
worker failed to stop and assess the radiological conditions he may enter prior to entering the
overhead area in the drywell with elevated dose rates, resulting in a dose rate alarm.
Licensee procedures require workers to adhere to RWP requirements, which required RP
approval to enter the overhead area. This enables RP to establish area dose rates and
controls, as overhead areas are not routinely surveyed or accessible.
Enforcement:
Violation: Technical Specification 5.4.1 requires, in part, that procedures be written,
implemented, and established for those areas recommended in Regulatory Guide 1.33,
Appendix A, Revision 2, 1978. Section 7(e) of this appendix requires RP procedures.
Procedure EN-RP-100, Radiation Worker Expectations, Revision 12, Section 5.3 [4], stated
that no entry to areas above 7 feet was permitted without prior permission from RP.
Contrary to the above, on March 3, 2020, an individual failed to receive permission from RP
prior to entering an area above 7 feet, resulting in an improper entry into a high radiation area
and a dose rate alarm of 802 millirem per hour.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Licensee-Identified Non-Cited Violation 71153
This violation of very low safety significance was identified by the licensee and has been
entered into the licensee corrective action program and is being treated as a non-cited
violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Technical Specification 3.3.1.1, Reactor Protection System (RPS)
Instrumentation, required Action L, requires that thermal power be reduced to less than
16.8 percent rated thermal power within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if action has not been initiated to implement
the manual backup stability protection (BSP) regions defined in the Core Operating Limits
Report (COLR) in accordance with required Actions J.1 and K.1 after one or more required
channels of the oscillation power range monitor (OPRM) upscale function has been
inoperable for longer than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Contrary to the above, on March 27, 2016, the licensee failed to reduce thermal power to less
than 16.8 percent rated thermal power within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> when action had not been initiated to
implement the manual BSP regions defined in the COLR in accordance with required
Actions J.1 and K.1 after one or more required channels of the OPRM upscale function had
been inoperable for longer than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Specifically, the unit was operated at or above
16.8 percent rated thermal power without the OPRM function being calibrated to the
appropriate setpoints as required by technical specifications.
Significance/Severity: Green. The performance deficiency associated with this non-cited
violation was determined to be more than minor because it was associated with the design
control attribute of the Mitigating Systems cornerstone and adversely affected the
cornerstone objective to ensure the availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences (i.e., core damage).
Specifically, the failure to calibrate the OPRM function to the appropriate setpoints resulted in
an RPS function being in an inoperable condition while operating on a mode or condition of
applicability. The finding was determined to be of very low safety significance (Green) in
12
accordance with Inspection Manual Chapter 0609, Appendix A, Exhibit 2.C, because the
finding did not affect a single RPS trip signal to initiate a reactor scram nor the function of
other redundant trips or diverse methods of reactor shutdown.
Corrective Action References: Condition Report CR-GGN-2016-08765
Minor Violation 71153
Minor Violation: On May 11, 2018, while performing the Division 1 emergency diesel
generator functional test portion of Division 1 loss of power (LOP)/loss of coolant accident
(LOCA) surveillance testing with the plant in Mode 5, a maintenance technician inadvertently
opened the incorrect fuse drawer associated with the 15AA (Division 1) safety electrical bus.
This action resulted in an undervoltage condition on the 15AA bus and an unplanned
automatic start of the Division 1 emergency diesel generator. Neither the Division 1
emergency diesel generator nor the associated Division 1 standby service water subsystem
were required to be operable in this mode of operation. This issue was entered into the
licensees corrective action program as Condition Report CR-GGN-2018-05485.
Technical Specification 5.4.1.a requires that written procedures shall be established,
implemented, and maintained covering the applicable procedures recommended in
Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Section 8.b of Appendix A to
Regulatory Guide 1.33 requires implementing procedures for each surveillance test listed in
the technical specifications. The licensee established Procedure 06-OP-1P75-R-0003,
Attachment IV, SDG 11, Functional Test - Test No. 6 - Div 1 LOP/LOCA Test,
Revision 138, to meet the Regulatory Guide 1.33 requirement. Step 5.8.15 of this procedure
stated to RACK OUT line PT for Bus 15AA feeder Breaker 152-1514 ESF 11 PT, in front of
Cubicle M2 of Bus 15AA.
Contrary to the above, on May 11, 2018, the licensee failed to rack out line potential
transformer (PT) for bus 15AA feeder breaker 152-1514 ESF 11 PT, in front of Cubicle M2 of
bus 15AA. Specifically, a maintenance technician opened the fuse drawer for the bus 15AA
PT fuse instead of the line PT fuse drawer.
Screening: The inspectors determined the performance deficiency was minor because it
could not be reasonably viewed as a precursor to a significant event; if left uncorrected, it
would not have the potential to lead to a more significant safety concern; and it did not
adversely affect the associated cornerstone objective to limit the likelihood of events that
upset plant stability and challenge critical safety functions during shutdown as well as power
operations. Specifically, the issue was determined to be similar to Example 4.b of Inspection
Manual Chapter 0612, Appendix E.
Enforcement: The licensee has taken actions to restore compliance. This failure to comply
with Technical Specification 5.4 constitutes a minor violation that is not subject to
enforcement action in accordance with the NRCs Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On March 5, 2020, the inspectors presented the inservice inspection results to
Mr. E. Larson, Site Vice President, and other members of the licensee staff.
13
On March 5, 2020, the inspectors presented the radiation safety inspection results to
Mr. E. Larson, Site Vice President, and other members of the licensee staff.
On April 7, 2020, the inspectors presented the integrated inspection results to
Mr. E. Larson, Site Vice President, and other members of the licensee staff.
14
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.04 Corrective Action CR-GGN- 2018-06005, 2018-06546, 2018-06784, 2018-09566
Documents
Drawings E-0740-005 Motor Operated Valves Wiring Diagrams 5
E-1185-002 Reactor Core Isolation Cooling System RCIC Injection Shutoff 10
MOV F013-A
KA762E421D Process Diagram Reactor Core Isolation Cooling System A
M-1065 P&I Diagram Condensate & Refueling Water Storage & 53
Transfer System Unit 1
M-1083A P&I Diagram Reactor Core Isolation Cooling System - Unit 1 43
M-1083B P&I Diagram Reactor Core Isolation Cooling System - Unit 1 41
M-1086 High Pressure Core Spray System Unit 1 35
Engineering EC-GGN- Admin Change to Update Drawing E0740-005 0
Changes 0000079071
Miscellaneous Clearance 1C22-1 Tagout E22-006-1E22C001
ES-18 Motor Operated Valve - Wiring and Limit Switch Control 4
Procedures 04-1-01-E51-1 Reactor Core Isolation Cooling System 142
04-1-01-P81-1 High Pressure Core Spray Diesel Generator 81
SDC-E51 Reactor Core Isolation Cooling System 3
Work Orders WO 00503748, 00507876
71111.05 Corrective Action CR-GGN- 2020-02580
Documents
Drawings E1809 Smoke Detector SP65N6251 RHR A 93 ft West
Fire Plans A-04 Fire Pre-Plan 2
71111.07A Corrective Action CR-GGN- 2020-0119, 2020-0123, 2020-0124, 2020-0125, 2020-0138
Documents
Drawings M-1061B P&I Diagram Standby Service Water System Unit 1 53
Miscellaneous AECM-90/0007 Grand Gulf Nuclear Station Response to Generic Letter 89-13
CCE 2006-0002 Generic Letter 89-13 Commitment Change
Procedures EN-DC-316 Heat Exchanger Performance and Condition Monitoring 11
EN-DC-340 Microbiologically Influenced Corrosion (MIC) Monitoring 5
Program
15
Inspection Type Designation Description or Title Revision or
Procedure Date
EN-EP-S-039-G Testing Standard for Safety Related Heat Exchangers Cooled 2
by Standby Service Water
Work Orders WO 52790008, 52791443
71111.08G Corrective Action CR-GGN- 2018-00329, 2018-01546, 2018-02542, 2018-03080, 2018-
Documents 03129, 2018-03984, 2018-05620, 2018-05668, 2018-06215,
2019-00266, 2019-01400, 2019-02395, 2019-03087, 2019-
09428, 2019-10463, 2020-02183, 2020-02270,
Corrective Action CR-GGN- 2020-02578, 2020-02602
Documents
Resulting from
Inspection
Drawings 767E977 Recirc Loop Piping 2
FW-11-07 Feedwater WTR Loop B 10
HL-1328J Feedwater CTMT to Reactor Pressure Vessel - Unit 1 6
RR-11-06 Recirc Loop A 10
RR-11-11 Recirc Loop B 10
RR-11-4 Recirc Loop A 10
Miscellaneous SEP-ISI-GGN- Program Section for ASME Section XI, Division 1 GGNS 10
001 Inservice Inspection Program
Procedures CEP-NDE-0404 Manual Ultrasonic Examination of Ferritic Piping Welds 8
(Section XI)
CEP-NDE-0407 Straight Beam Ultrasonic Examination of Bolts and Studs 6
(ASME XI)
CEP-NDE-0423 Manual Ultrasonic Examination of Austenitic Piping Welds 8
(ASME XI)
CEP-NDE-0903 VT-3 Examination 6
WDI-STD-006 Manual Ultrasonic Procedure for Examination of Nozzle Inner 10
Corner Radius Areas in Accordance with ASME Section XI,
Including Appendix VIII
WDI-STD-1107 Generic Procedure for the Manual Ultrasonic Examination of 3
Reactor Pressure Vessel Welds in Accordance with PDI-UT-6
71111.11Q Procedures EN-RE-215 Reactivity Maneuver Plan 7
71111.12 Miscellaneous CR-GGN-2017-12314 MRFF
CR-GGN-2019-1476 MRFF Evaluation
16
Inspection Type Designation Description or Title Revision or
Procedure Date
CR-GGN-2019-1597 MRFF Evaluation
Procedures EN-DC-203 Maintenance Rule Program 4
EN-DC-204 Maintenance Rule Scope and Basis 4
EN-DC-205 Maintenance Rule Monitoring 7
Work Orders WO 82842039-01
71111.13 Corrective Action CR-GGN- 2020-02571, 2020-02611
Documents
Procedures 01-S-18-6 Risk Assessment of Maintenance Activities 21
EN-OP-119 Protected Equipment Postings 12
71111.15 Calculations C-EC86247- Structural/Seismic Analysis for the LaSalle Jet Pump Plug 0
N1F14E021-8.0-
001
Corrective Action CR-GGN- 2020-00076, 2020-00901
Documents
Engineering EC-86427 Seismic Qualification of Jet Pump Plugs 0
Changes
Procedures 07-1-34-B13- Jet Pump Plug Installation and Removal 1
D006-3
Work Orders WO 00530093
71111.18 Engineering EC 85565 Replace 1P81K001 Div III EDG Speedswitch (SSA-1) 0
Changes
Miscellaneous IEE-344 - 2013
00200225 Procurement Engineering Evaluation
E100.0 Technical Specification for Environmental Safety Related 8
Parameter
Procedures 02-S-01-45 Water Inventory Control 0
EN-DC-115 Engineering Change Process 27
Work Orders WO 00537942
71111.19 Procedures 06-OP-1P81-M- HPCS Diesel Generator 13 Functional Test 136
0002
Work Orders WO 00537942-04, 52856327-04
71111.20 Drawings M-0002 General Arrangement Plan at EL. 113'-0", 111'-0", 119'-0", 5
120'-10", & 114'-6", Units 1 & 2
17
Inspection Type Designation Description or Title Revision or
Procedure Date
M-0003 General Arrangement Plan at EL. 133'-0", 148'-0", 139'-0", 6
135'-4", & 147'-7"
M-0004 General Arrangement Plan at EL. 166'-0", 161'-10", & 170'-0" 7
71111.22 Drawings M-1082 P&I Diagram Standby Liquid Control System Unit 1 29
Miscellaneous Attachment 4 Suppression Pool Level Instrument 1E30-LT-N003B
Procedures 04-1-05-E50-1 R3 Suppression Pool Water Level Penetrations
04-1-05-M61-2, LLRT Alignment Instructions for Electrical Penetrations 0
Att 1
04-1-07-E30-1 Suppression Pool Makeup System
R27
06-OP-1C41-Q- Standby Liquid Control Functional Test 131
0001
06-OP-1M61-V- Using Graftel Model 9623-7 Leak Rate Monitor 13
0002, Att I
EN-WM-105 FLEX Portable Diesel Generator 1FLEXS010 06/21/2011
O4-S-03-P64-20 Transformer Deluge Functional and Full Flow Test 6
Work Orders WO 509598-03, 52782437-01, 52842248-01, 52842631-01,
52872563, 5291252-01
71124.01 Corrective Action CR-GGN- 2019-06666; 2019-07844; 2019-07852; 2019-07933; 2019-
Documents 08263; 2019-08334; 2019-08335; 2019-08336; 2019-09421;
2019-09535; 2020-01891; 2020-02586; 2020-02676; 2020-
02688
Miscellaneous Non-Nuclear Material Inventory 02/11/2020
GIN-2020-00005 2020 National Source Tracking System Reconciliation for NRC 01/08/2020
License NPF-29
WO 52881814 Leak Test of Sealed Sources 11/21/2019
Procedures EN-RP-100 Radiation Worker Expectations 12
EN-RP-101 Access Control for Radiologically Controlled Areas 15
EN-RP-102 Conduct of Radiation Protection 5
EN-RP-106 Radiological Survey Documentation 7
EN-RP-108 Radiation Protection Posting 22
EN-RP-121 Radioactive Material Control 16
EN-RP-131 Air Sampling 17
18
Inspection Type Designation Description or Title Revision or
Procedure Date
EN-RP-143 Source Control 14
Radiation Surveys Air Sampling 010520-0017, 112019-0261, 112019-0262, 120419-0333,
(GGN-AS-) 122619-0421,
GGN-1912-00010 133' Turbine Building Truck Bay 12/01/2019
GGN-2002-00931 139' AUX Steam Tunnel Lower Level 02/27/2020
GGN-2002-00980 114' Drywell Entire Elevation 02/28/2020
GGN-2002-01052 147' Drywell 02/29/2020
GGN-2003-00091 161' Drywell Entire Elevation 03/01/2020
GGN-2003-00213 147' Drywell Post-Alarm Survey 03/03/2020
GGN-2003-00253 139' AUX Steam Tunnel Lower Level 03/03/2020
Radiation Work 2020-1502 Drywell Coordinator, Safety and NRC Walkdowns / Tours in 0
Permits (RWPs) the Drywell
2020-1509 General Decon Activities and Support for the Drywell 0
2020-1510 Visually Inspect/Remove/Test/Replace Snubbers in RF-22 0
2020-1915 Emergent Work for Maintenance, Tours, and Inspections 0
(Normal and Low Risk Only)
Self-Assessments LO-GLO-2020- Pre-NRC Radiological Hazard Assessment and Exposure 01/24/2020
00005 Controls (71124.01)
71124.02 Corrective Action CR-GGN- 2019-03675, 2019-04131, 2019-10146, 2019-10399
Documents
Miscellaneous RF-21 Lessons Learned 02/06/2020
LO-GLO-2018- Pre-NRC Inspection: Occupational ALARA Planning and 12/03/2019
00176 Controls Assessment (IP 71124.02)
Procedures EN-FAP-RP-013 Radiation Protection Outage Preparation and Execution 0
EN-RP-105 Radiological Work Permits 19
EN-RP-110-03 Collective Radiation Exposure (CRE) Reduction Guidelines 4
EN-RP-110-06 Outage Dose Estimating and Tracking 1
Radiation Work 2020-1502 Drywell Coordinator, Safety and NRC Walkdowns/Tours in the 0
Permits (RWPs) Drywell
2020-1509 General Decon Activities and Support for the Drywell 0
2020-1510 Visually Inspect/Remove/Test/Replace Snubbers in RF-22 0
2020-1915 Emergent Work for Maintenance, Tours, and Inspections 0
19
Inspection Type Designation Description or Title Revision or
Procedure Date
(Normal and Low Risk Only)
71153 Corrective Action CR-GGN- 2016-08765, 2017-12299, 2017-12314, 2018-05485
Documents
Procedures 06-IC-1C51-R- Average Power Range Monitor Calibration Channel A 100
0077A
06-OP-1P75-R- SDG 11, Functional Test - Test No. 6 - Div 1 LOP/LOCA Test 138
0003, Attachment
IV
EN-DC-159 System and Component Monitoring 9
EN-DC-205 Maintenance Rule Monitoring 7
EN-DC-310 Predictive Maintenance Program 8
EN-DC-324 Preventive Maintenance Program 18
EN-DC-346 Cable Reliability Program 6
EN-MA-138 VLF Tan Delta and Withstand Testing Of Electrical Power 4
Cables
Work Orders WO 0033200501, 0033200601
20