ML21032A048
| ML21032A048 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 02/01/2021 |
| From: | Franssen R Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation, NRC Region 4 |
| References | |
| GNRO2020/00046, IR 2020013 | |
| Download: ML21032A048 (5) | |
Text
Entergy Operations, Inc.
P.O. Box 756 Port Gibson, Mississippi 39150 Robert Franssen Site Vice President Grand Gulf Nuclear Station Tel: 601-437-7500 10 CFR 2.201 GNRO2020/00046 February 1, 2021 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Reply to Notice of Violation Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License Number NPF-29
REFERENCES:
Grand Gulf Nuclear Station - Triennial Fire Protection Inspection Report 05000416/2020013 and Notice of Violation Pursuant to the provisions of 10 CFR 2.201, Entergy Operations Inc. (Entergy) hereby submits the Reply to Notice of Violation for Grand Gulf Nuclear Station Unit 1, in the Attachment. This Notice of Violation was issued in Nuclear Regulatory Commission Triennial Fire Protection Inspection Report 05000416/2020013 and Notice of Violation dated December 3, 2020.
In accordance with the instructions specified in the notice, Entergy was to transmit this reply within 30 days of the date of the letter transmitting the notice. During a phone call between Entergy and the Region IV Acting Engineering Branch Chief on December 22, 2020, an additional 30-day extension was verbally granted extending the due date to February 2, 2021.
This letter contains no new commitments and no revisions to existing commitments. If you have any questions or require additional information, please contact Jeffery Hardy at 1-269-764-2011.
GNRO2020/00046 Page 2 of 2 Sincerely, Robert Franssen RF/saw
Attachment:
Reply to Notice of Violation cc: NRC Region IV - Regional Administrator Division Reactor Safety NRC Senior Resident Inspector, Grand Gulf Nuclear Station State Health Officer, Mississippi Department of Health NRR Project Manager
GNRO2020/00046 Page 1 of 3 Attachment GNRO2020/00046 Reply to Notice of Violation
GNRO2020/00046 Page 2 of 3 Reply to Notice of Violation I. Cited Violation During an NRC inspection conducted from August 10-28, 2020, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
License Condition 2.C.(41) requires, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in Revision 5 to the Updated Final Safety Analysis Report and as approved in the Safety Evaluations, dated August 23, 1991, and September 29, 2006.
Updated Final Safety Analysis Report, Section 9.5.1.3 states, in part, that as noted in the Safety Evaluation Report (NUREG 0831), the NRC staffs Safety Evaluation Report concluded, based on evaluation of the fire protection program and related commitments, that the fire protection program meets the applicable guidelines of Branch Technical Position APCSB 9.5-1, dated August 23, 1978.
Branch Technical Position APCSB 9.5-1, Position C.8, states, in part, that measures should be established to assure that conditions adverse to fire protection are promptly identified and corrected.
Contrary to the above, from August 2011 to September 17, 2020, the licensee failed to promptly correct a condition adverse to fire protection. Specifically, the licensee failed to complete corrective actions for multiple spurious operation concerns identified in 2011 and documented as non-cited violation, NCV 05000416/2017008-01, Untimely Corrective Action. The licensee failed to incorporate operator manual actions into the post-fire safe shutdown procedure.
This violation is associated with a Green Significance Determination Process finding.
II. Reason for the Violation Entergy concurs with the violation. The reason for the violation is Grand Gulf engineers failed to effectively leverage the corrective action process with the appropriate corrective actions to fully resolve this adverse condition. Corrective actions taken in response to 2011 and 2017 non-cited violations addressed most of the multiple spurious operations scenarios, but left some unresolved.
III. Corrective Steps Taken and Results Achieved The unresolved multiple spurious operations scenarios were resolved.
Entergy revised Engineering Report, GGNS-EE-11-00001, GGNS Appendix R Safe Shutdown Analysis (FPP-1) on August 11, 2020. This revision corrected the issues identified by the NRC in 2011 and 2017 for multiple spurious operations scenarios.
Entergy revised Off-Normal Event Procedure 05-1-02-II-1, Shutdown From The Remote Shutdown Panel on September 22, 2020. This revision included the operator actions necessary to implement the multiple spurious operations scenarios included in GGNS-EE 00001, GGNS Appendix R Safe Shutdown Analysis.
GNRO2020/00046 Page 3 of 3 Entergy revised Fire Protection Procedure 10-S-03-02, Responses to Fires, on September 17, 2020. This revision included the operator actions necessary to implement the multiple spurious operations scenarios included in GGNS-EE-11-00001, GGNS Appendix R Safe Shutdown Analysis.
IV. Corrective Steps to be Taken Entergy is developing a workshop for engineering personnel to reinforce intellectual standards for critical thinking. This action is intended to reinforce the standards for critical thinking and principals of sound engineering technical basis documents. This action is scheduled to be completed by February 26, 2021.
Entergy is developing a reset briefing on the standards and expectations for SMART (specific, measurable, achievable, realistic, and timely) corrective action plan development. This action will reset the engineering staffs knowledge with respect to SMART corrective action development. This action is scheduled to be completed by February 26, 2021.
Entergy is developing a process to perform biweekly reviews on new priority 1, 2, and 3 corrective actions issued within Engineering. This action will ensure all corrective actions issued within Engineering meet the SMART criteria and will provide feedback coaching when gaps are identified. This action is scheduled to be completed by June 18, 2021.
Engineering Senior Leadership is briefing Engineering Supervisors and Managers on expectations of Engineering ownership/advocacy and the tools to utilize to successfully advocate for adverse conditions. This action ensure engineering leadership understands how to lead by example when advocating for adverse condition resolution. This action is scheduled to be completed by March 12, 2021.
V. Date When Full Compliance Was Achieved Full compliance was achieved in September 2020.