ML20217E013

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Trip Rept of 970825-26 Visit to Plant,Unit 1 for Interviews in Preparation of Salp.Agenda for Interviews Encl
ML20217E013
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 09/29/1997
From:
NRC (Affiliation Not Assigned)
To:
NRC (Affiliation Not Assigned)
References
NUDOCS 9710060251
Download: ML20217E013 (10)


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WASHINGTON. D.C. 80MH001 k * * *, ,/j' September 29, 1997 LICENSEE: Entergy Operations, Inc.

FACILITY: Grand Gulf Nuclear Station, Unit 1

SUBJECT:

TRIP TO FACILITY FOR INTERVIEWS IN PREPARATION OF THE SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE FOR GRAND GULF NUCLEAR STATION, UNIT 1 During the week of August 24, 1997, on August 25 and 26, John Hannon (Project Director) and I visited the site of the Grand Gulf Nuclear Station, Unit 1 (GGNS) to discuss management effectiveness, training, and self-assessments for engineering in interviews at the site as part of the staff's pre)aration for the thirteenth Systematic Assessment of Licensee Performance (SA.P) for Grand Gulf Nuclear Station. The period for the current assessment of Grand Gulf was February 25, 1996, to September 6, 1997. The areas of management effectiveness, training, and self-assessments for the functional area of engineering were determined to be the focus for the interviews due to a lack of information in these areas in the staff's Inspection Reports (irs). There were 31 irs issued for Grand Gulf in the current SALP period (i.e., from IR 50-416/96-07 to 50-416/97-19).

The agenda for interviews is attached to this report. The agenda includes the individuals contacted in the interviews.

A summary of the interviews is provided below including the additional areas of program / procedural quality, quality of engineering, and quality of engineering support for operations / maintenance.

1. Management Effectiveness The licensee conducts quality assurance (QA) audits and self-assessments. The self-assessments are (1) directed from corporate and (2) conducted by the individual functional areas. The corporate self-assessment of each site is nine weeks for seven function areas with personnel from other Entergy sites and non-Entergy sites. (The first time for Grand Gulf will be in the beginning of the next SALP period.)
  • Engineering conducted at least 6 self-assessments in 1996:

engineering self-assessment, engineering request process, microbiological 1y induced corrosion program, post modification configuration management, and customer satisfaction with design process.

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  • There were three licensee self-assessments that were inspected. The engineering self-assessment in 1995/1996 was inspected at the beginning of 1996 just before the current SALP period started.

There were also inspections in maintenance and fire protection that included a review of self-assessments. The inspections showed the self-assessments were good.

  • The staff's review of the licensee's self-assessment of engincM 1 at the end of the previous SALP period concluded that the self-assessment efforts were effective in identifying deficiencies. The shortcomings were with implementing corrective actions for identified problems. The licensee addressed these shortcomings in this SALP period.

e in a review of the chan improve effectiveness,the ges to the corrective enhancements were actions stated toprogram be the to following: A " champion" assigned to deficiencies determined to ba significant, formation of the CARB to review significant deficiencies, the root cause determination and corrective actions, and quality programs will perform audits / monitoring on significant deficiencies to determine the effectiveness of corrective actions taken and establish periodic quality review group meetings to provide for group review of proposed corrective actions. The licensee's review of the implementation of these corrective actions concluded that the enhancements have been implemented effectively.

  • During the visit to the site, the CARB was attended twice to witness how it conducted business. We concluded that the CARB was effective in reviewing deficiencies and following up on corrective actions.
  • Engineering reduced the number of personnel two years ago, but has slowly increased the number as the work load indicated additional staff was needed.
  • The licensee is currently reviewing the engineering request (ER) report backlog to determine the significance of each request and that each request is being handled properly.

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  • A large number of personnel appear to have worked for most of their career at Grand Gulf. Some discussions appeared to indicate that selected personnel were satisfied with the status quo at Grand Gulf, although this was not reflected in discussions with upper site management.
  • The self-assessments include a current review of the UFSAR which is described in the licensee's February 6,1997, response to the staff's 50.54(f) letter regarding design control. The licensee stated that they are allocating 6000 hours0.0694 days <br />1.667 hours <br />0.00992 weeks <br />0.00228 months <br /> to review the UFSAR and expect to expand this effort depending on the findings.

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  • Management tracks 7 indicators for an indication of complacency:

plant material condition, %en significant deficiencies, personnel errors, violation trends, personnel development, responsiveness of organizations, and regulatory performance. The current color-code indication for complacency is yellow, of four color codes yellow is the next lowest indication to red. It is clear that the licensee is concerned about the potential for complacency at the site and is trying to avoid it.

  • Developed minor mods team in 1996 to address smaller orojects that previously competed with and lost to large scale projects and to focus on operations and maintenance needs. This is being expanded to include systems engineering, ratesting, and closecut functions.

32 minor mods were issued in 1997.

  • There are three current safety analysis initiatives: certification of plant IPE and support of industry initiatives, revised accident source terms, and industry issues of vendor oversight and critical process review and enhancement.
  • There are three current training initiatives: engineering support personnel (ESP) training, senior reactor operator (SRO) training, and technical training.
  • 60 of 87 have completed ESP training as of June 1997. 442 hours0.00512 days <br />0.123 hours <br />7.308201e-4 weeks <br />1.68181e-4 months <br /> of training per participant. This training includes corrective action program, maintenance work orders, procurement, procedures and documents, plant modifications, probability risk assessment, and foreign material exclusion.
  • Design Engineering has a goal to have engineers SRO certified (for 1999, the goal is all management and about one-fifth of staff).
  • Technical training in-house is ASME Section VIII, vessel repair, and external is pump and pump-system seminar, valve technology symposium, probabilistic safety assessment and its application, and safety and relief valve issues.
  • Design basis improvements: UFSAR review of 16 systems, operations and maintenance procedure review for 16 systems, calculational index and relational database, system design and analysis basis document review, mechanical and electrical calculational review, and design basis training (a lesson plan was being developed).
  • The licensee decided in hindsight that its response of June 30, 1997, to the violations in IR 97-05 was, on balance, argumentative and not as constructive as it could have been, i

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2. Program / Procedural Quality
  • There is a program for design margin recovery for motor operated valves. Taking into account NRC mandates and deficiencies from vendors, the industry, and the licensee assessments, the licensee has 114 planned changes for the next two refueling outages and has completed 43 changes in the last refueling outage.
  • The licensee is currently reviewing the ER report backlog tof determine the significance of each request and is each request being handled properly.
3. Quality of Engineering
  • The Performance and System Engineering (P&SE) has determined that excessive tritium generated at and re eased from GGNS is from neutron exposure of the control rod blades. The liccnsee's strategy of having a uniform neutron exposure of blides and replacing the blades at the recommended exposure value ha; lead to this tritium

- situation. The licensee is planning to rep 1 tce half of the blades over the next two refueling outages. This replacement rate is consistent with the licensee's strategy for replacing blades, but at -

a higher rate.

  • The licensee briefly discussed the use of its pressure locking thrust prediction methodology for Generic Letter 95-07, " Pressure Locking and Thermal Binding of Safety-Related Power-0perated Gate Valves," and the test data used to evaluate acceptability of the methodology. This methodology was addressed in the licensee's response submitted June 30, 1997, to the staff's request for additional information of May 1, 1997. The response is being reviewed by the staff. There was not sufficient time for the licensee to explain in detail how its methodology is used for power-operated gate valves susceptible to pressure locking and thermal binding, and a future meeting may be needed after the staff completes its review of the licensee's response of June 30, 1997.
  • There is a program for design margin recovery for motor operated valves. Taking into account NRC mandates and deficiencies from vendors, the industry, and the licensee assessmet.ts, the licensee has 114 planned changes for the next.two refueling outages-and has completed 43 changes in the last refueling outage.
4. Quality of Engineering Support for Opkrations/ Maintenance
  • -Discussions with operations, quality assurance, and maintenance personnel indicate a good working relationship with engineering. No problems were identified.

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  • There is an ongoing 9xchange of management personnel between maintenance and engineering which has improved engineering support to maintenance.
5. Engineering Training Program Quality
  • The training provided to engineers is the INPO engineering support training. This includes a 4 week plant review, system expert qualification training (this is not required for all system engineers), and the goal is to have engineers become SRO certified.
  • There are three current training initiatives: engineering support personnel (ESP) training, SRO training, and technical training.
  • The licensee stated that 60 of 87 have completed ESP training as of June 1997. There is 442 hours0.00512 days <br />0.123 hours <br />7.308201e-4 weeks <br />1.68181e-4 months <br /> of training per participant. This training includes corrective action program, maintenance work orders, procurement, procedures and documents, plant modifications, probability risk assessment, and foreign material exclusion.
  • Engineering is working toward the goal to have all of the design engineering management and twenty percent of the design engineers staff be SRO certified by 1999.
  • Technical training in-house is ASME Section Vill, vessel repair, and off-site training is pump and pump-system seminar, valve technology symposium, probabilistic safety assessment and its application, and safety and relief valve issues.
6. Self-Assessment / Quality Verification
  • The licensee conducts QA verification audits and self-assessments. '

The self-assessments are (1) directed from corporate and (2) conducted by the individual functional areas.

  • Corporate staff members have started to conduct one major self-assessment of functional areas over 9 weeks for each site every 18 months. One week preparation of assessors from other Entergy sites and non-Entergy sites. Seven weeks assessment vertically in each of seven functional areas. Die final week of horizontal assessment including upper Entergy management. The major self-assessment for Grand Gulf begins September 1997.
  • Corporate also conducts three assessments per site, more limited than the above 9 week assessments, as requested by each Entergy site.
  • The staff's review of the licensee's self-assessment of engineering at the end of the previous SALP period concluded that the self-assessment efforts were effective in identifying deficiencies;

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however, the shortcomings were with implementing corrective actions for identifitd problems. The licensee addressed these shortcomings in this SALP period by (1) creatin the CARB to increase management attention on corrective actions, ( ) perfonning self-assessments and quality program verifications on t e effectiveness of implementing corrective actions (two were conducted in this SALP period) and (3) conducting periodic quality group meetings for review of corrective -

actions.

  • The two licensee self-assessments and quality verifications to review implementation of corrective actions reviewed 22 QDRs, violations, CRs, MNCRs, and design engineering temporary directives.

The assessments determined the effectiveness of the corrective actions in addition to what corrective actions were implemented.

The licensee's documentation of these reviews are brief, but the reviews are self-critical and sufficient to determine the effectiveness _of the corrective actions. The licensee appears to trying to find out if the corrective actions are effective and act accordingly if they are not.

  • In a review of the changes to the corrective actions program to improve effectiveness, the enhancements were stated to be the following: A " champion" assigned to deficiencies determined to be "significant," formation of the CARB to review significant deficiencies, and the root cause determination and corrective actions, and quality programs will perform audits / monitoring on significant deficiencies to determine the effectiveness of corrective actions taken and establish periodic quality review group meetings to provide for group review of proposed corrective actions.

The licensee's review of the implementation of these corrective actions concluded that the enhancements have been implemented effectively.

  • Engineering conducted 6 self-assessments in 1996: engineering self-assessment, engineering request process, microbiological 1y influenced corrosion program, post modification configuration management, and customer satisfaction with design process. The engineering self-assessment was inspected at the beginning of 1996 just before the current SALP period started. The inspection showed >

the self-ahessment was good.

  • The assessment of the ER process was to streamline the process, to consolidate multiple processes and reduce overall paperwork, and to .

have P&SE perform some activities previously assigned design engineering. Areas of improvement were in implementation and closeout of ERs training, condition report /ER interface. They decided to and are conducting another self-assessment of ERs in 1997. There was also a self-assessment of the ER process with respect to upper-tier commitments. Nine minor discrepancies were identified out of 124 commitments reviewed and they were added to the management open items list for tracking.

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  • The assessment of microbiologically induced corrosion was that the program was narrowly focused and appeared (MIC) program fragmented, and did not include all appropriate systems. Planned action was to include all vulnerable systems in program and develop a comprehen-sive program document by oone 30, 1997.
  • The assessment of post modification configuration management, conducted with QA, was that it was effective, but it identified these areas of improvement: the database doesn't show status of updates to drawings and provide access to infomation on the pending as-builts, and process for controlling UFSAR change requests resulting from modification activities should be reviewed and coordinated between design engineering and Performance and System Engineering. There was an assessment of concerns from the previous self-assessment, of program interfaces, of administrative controls.

and of industry events. Under-administrative controls. the licensee identified that a modification package war flosed out without submitting the FSAR change request to Nucl .ar Safety and Regulatory Affairs.

  • Engineering is conducting 8 self-assessments in 1997: - security doors, refueling process team, LCO parts availability, procurement graded QA, ER process improvements, site work management, design engineering work management process, and GGNS calculational database development.
7. Tour of Plant
  • On August 25, 1997, a tour of the plant area was conducted where the unirradiated fuel would be received in the 10 CFR Part 71 shipping packages. The fuel is. carried into the plant by shipping trucks.

The fuel would be removed from the trucks in metal containers and lifted up to the 208-foot level of the auxiliary building, in the spent fuel pool area adjacent to the cask washdown pit and new fuel vault. In this area, the fuel assemblies are removed from the metal containers. The metal containers would be lifted directly to the 208-foot level of the auxiliary building or moved on the 166-foot elevation from the turbine building to the auxiliary building where they would be lifted to the 208-foot level. The areas where the '

metal containers have drains to prevent the possibility of submerging a large number of the metal containers under water.

Docket No. 50-416-

Enclosure:

-. Agenda cc w/ enc 1: See next page

.a Entergy Operations, Inc. Grand Gulf Nuclear Station cc:

Executive Vice President General Manager, GGNS

& Chief Operating Officer Entergy Operations, Inc.

Entergy Operations, Inc. P. O. Box 756 P. O. Box 31995 Port Gibson, MS 39150 Jackson, MS 39286-1995 Attorney General Wise, Carter, Child & Caraway Department of Justice P. O. Box 651 State of Louisiana Jackson, MS 39205 P. O. Box 94005 Baton Rouge, LA 70804-9005 1400 L Street, N.W. - 12th Floor State Health Officer Washington, DC 20005-3502 State Board of Health P. O. Box 1700 Ofrector Jackson, MS 39205 Division of-$olid Waste Management Mississippi Department of Natural Office of the Governor Resources State of Mississippi P. O. Box 10385 Jackson, MS 39201 Jackson, MS 39209 Attorney General President, Asst. Attorney General Claiborne County Board of Supervisors State of Mississippi P. O. Box 339 P. O. Box 22947 Port Gibson, MS 39150 Jackson, MS 39225 Regional Administrator, Region IV Vice President, Operations Support U.S. Nuclear Regulatory Commission Entergy Operations, Inc.

611 Ryan Plaza Drive, Suite 1000 P.O. Box 31995

. Arlington, TX 76011 Jackson, MS 39286-1995 Senior Resident inspector Director,- Nuclear Safety U. S. Nuclear Regulatory Commission and Regulatory Affairs Route 2. Box 399 Entergy Operations, Inc.

Port Gibson, MS 39150 P.O. Box 756 Port Gibson, MS 39150 Manager of Operations Bechtel Power Corporation P.O. Box 2166 Houston, TX- 77252-2166 Mr.~ Joseph J. Hagsn Vice President, Operations GGNS Entergy. Operations, Inc.

P.-0. Box 756 Port Gibson, MS 39150

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  • The assessment of post modification configuration management, conducted with QA, was that it was effective. but it identified these areas of improvement the database doesn't show status of updates to drawings and provide access to information on the pending as-builts, and process for controlling UFSAR change requests resulting from modification activities should be reviewed and coordinated between design engineering and Performance and System Engineering. There was an assessment of concerns from the previous self-assessment, of program interfaces, of administrative controls, and of industry events. Under administrative controls, the licensee identified that a modification package was closed out without submitting the FSAR change request to Nuclear Safety and Regulatory Affairs.
  • Engineering is conducting 8 self-assessments in 1997: security doors, refueling process team, LCO parts availability, procurement graded QA, ER process improvements, site work management, design engineering work management process, and GGNS calculational database development.
7. Tour of Plant
  • On August 25, 1997, a tour of the plant area was conducted where the unirradiated fuel would be received in the 10 CFR Part 71 ship)ing packages. The fuel is carried into the plant by shipping truc(s.

The fuel would be removed from the trucks in metal containers and lifted up to the 208-foot level of the auxiliary building, in the spent fuel pool area adjacent to the cask washdown pit and new fuel vault. In this area, the fuel assemblies are removed from the metal containers. The metal containers would be lifted directly to the 208-foot level of the auxiliary building or moved on the 166-foot elevation from the turbine building to the auxiliary building where they would be lifted to the 208-foot level. -The areas where the metal containers have drains to prevent the possibility of submerging a large number of the metal containers under water.

Docket No. 50-416

Enclosure:

Agenda cc w/ enc 1: See next page DISTRIBUTION:

Docket File PUBLIC RZimmerman SCollins/FMiraglia EAdensam PD4-1 r/f KBrockman (RIV)

JDonohew JHannon PGwynn (RIV)

CHawes JClifford DChamberlain (RIV)

Dwiment Name: GG082497.TRP 0FC LA/>D4A LA/PD4-1 PD/PD3-1 i NAME JDp h /sp' CHawes dM JHannon (I DATE T h l /97 7 / M /97 #/ h /97 (

COPY YES/NO YES/NO / /kE57)l0

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0FFIClhL RECORD COPY

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