ML23026A095
| ML23026A095 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 02/01/2023 |
| From: | Jeffrey Josey NRC/RGN-IV/DORS/PBC |
| To: | Kapellas B Entergy Operations |
| References | |
| EA-22-131 IR 2022004 | |
| Download: ML23026A095 (31) | |
See also: IR 05000416/2022004
Text
February 01, 2023
Brad Kapellas
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 05000416/2022004 AND EXERCISE OF ENFORCEMENT
DISCRETION
Dear Brad Kapellas:
On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at Grand Gulf Nuclear Station. On January 5, 2023, 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.
Three findings of very low safety significance (Green) are documented in this report. Three of
these findings involved violations of NRC requirements. One Severity Level IV violation with an
associated finding is also documented in this report. We are treating these violations as
non-cited violations (NCVs) consistent with section 2.3.2 of the Enforcement Policy.
A violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 37 with respect to large
components containing category 2 quantities of radioactive material stored in robust structures
was identified. However, Entergy Operations, Inc. met all the criteria in NRC Enforcement
Guidance Memorandum 14-001, Interim Guidance for Dispositioning 10 CFR Part 37 Violations
with Respect to Large Components or Robust Structures Containing Category 1 or Category 2
Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52 for
the use of enforcement discretion. Therefore, the NRC is exercising enforcement discretion
(EA-22-131) and will not issue enforcement action for this violation. Additional details are
contained in the enclosure.
If you contest the violations or the significance or severity 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.
B. Kapellas
2
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.
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,
Jeffrey E. Josey, Chief
Projects Branch C
Division of Operating Reactor Safety
Docket No. 05000416
License No. NPF-29
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
Signed by Josey, Jeffrey
on 02/01/23
Review
Non-Sensitive
Sensitive
Publicly
Available
Non-Publicly
Available
OFFICE
SRI:DORS/C
RI:DORS/C
SPE:DORS/C
ATL:ACES
BC:DORS/C
NAME
TSteadham
ASmallwood
WSchaup
JKramer
JJosey
SIGNATURE
/RA/
/RA/
/RA/
/RA/
/RA/
DATE
01/26/23
01/26/23
01/30/23
02/01/23
02/01/23
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number:
05000416
License Number:
Report Number:
Enterprise Identifier:
I-2022-004-0012
Licensee:
Entergy Operations, Inc.
Facility:
Grand Gulf Nuclear Station
Location:
Port Gibson, MS
Inspection Dates:
October 1, 2022, to December 31, 2022
Inspectors:
D. Antonangeli, Health Physicist
N. Greene, Senior Health Physicist
R. Lanfear, Physical Security Specialist
W. Schaup, Senior Project Engineer
A. Smallwood, Resident Inspector
T. Steadham, Senior Resident Inspector
Approved By:
Jeffrey E. Josey, Chief
Projects Branch C
Division of Operating Reactor Safety
2
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.
List of Findings and Violations
Failure to Control Transient Combustibles in Accordance with Site Procedures
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
[H.5] - Work
Management
The inspectors identified a finding of very low safety significance (Green) and an associated
non-cited violation (NCV) of Facility Operating License Condition 2.C(41), Fire Protection
Program, for the failure to implement all provisions of the approved fire protection program.
Specifically, the licensee failed to control transient combustible materials per
procedure EN-DC-161, section 7.5, in a Level 1 combustible control zone.
Failure to Obtain a License Amendment for Changes Associated with Auxiliary Building
Railroad Bay Door 1A319A
Cornerstone
Severity
Cross-Cutting
Aspect
Report
Section
Not Applicable
Open/Closed
Not Applicable
The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes,
Tests and Experiments, section (c)(2) when the licensee failed to submit and obtain NRC
authorization for a change to the facility that would have required a license amendment.
Specifically, the change to door 1A319A resulted in a more than minimal increase in the
likelihood of occurrence of a malfunction of the auxiliary building during a tornado and
constituted a departure from a method of evaluation as described in the Updated Final Safety
Analysis Report.
Failure to Periodically Calibrate Radiation Monitors as Required by 10 CFR 20.1501(c)
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Occupational
Radiation Safety
Green
Open/Closed
[P.5] -
Operating
Experience
The inspectors identified a Green, non-cited violation of 10 CFR 20.1501(c) for failure to
periodically calibrate area radiation monitor equipment used to perform dose rate
measurements. Specifically, since at least April 2018, the licensee discontinued periodic
calibration of 34 area radiation monitors distributed throughout the plant. The calibration
frequency of these monitors was changed to as required.
3
Failure to Comply with the Terms of the Certificate of Compliance for a Package Delivered to
a Carrier for Transport
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Public Radiation
Safety
Green
Open/Closed
[H.7] -
Documentation
The inspectors reviewed a self-revealed, Green, non-cited violation of 10 CFR 71.17 for the
licensee's failure to comply with the terms of the Certificate of Compliance (CoC) for a
package delivered to a carrier for transport. On October 9, 2018, the licensee delivered to a
carrier for transport licensed material that failed to comply with terms of the certificate for the
packaging of the shipment. Specifically, the licensee failed to use adequate load plans during
the 2018 spent fuel pool cleanup campaign, resulting in sending six shipments of irradiated
hardware offsite to a waste processing facility with inaccurate shipping paperwork. One of the
six shipments was later confirmed, on October 17, 2022, to contain greater than 10.0 curies
per kilogram of cobalt-60 (Co-60), which exceeded the CoC limit for the package.
Additional Tracking Items
Type
Issue Number
Title
Report Section
Status
Enforcement Discretion for a
Minor Violation of
10 CFR 37.11(c) for Failure
to Comply with Exemptions
for the Monitoring, Detecting,
and Assessment of a Robust
Structure
Closed
Failure to Use the Work
Control Process to Adjust
Hand Geometry Unit
92702
Closed
Falsified Information
Regarding a Condition
Adverse to Quality
92702
Closed
Exam Proctor Provided
Inappropriate Assistance
During Engineering
Qualification Exams
92702
Closed
4
PLANT STATUS
Grand Gulf Nuclear Station, Unit 1, began the inspection period at full rated thermal power
(RTP). On October 22, 2022, operators began a slow power decrease in response to decreased
service water margin. Power was ultimately reduced to 51 percent RTP on October 30, 2022,
when operators increased power to 89 percent RTP upon recovery of some service water
margin. On November 7, 2022, operators began raising power after restoration of service water
margin. The unit reached 100 percent RTP on November 9, 2022. On December 19, 2022,
operators shutdown the unit due to a loss of main feedwater flow. On December 21, 2022,
operators began a plant startup after completing repairs. On December 26, 2022, the unit
reached 100 percent RTP where it remained at or near 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. The inspectors performed activities described in IMC 2515,
Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of
IPs. 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
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1)
division 1 control room heating ventilation and air conditioning on October 18, 2022
(2)
division 2 standby service water on November 8, 2022
(3)
secondary containment on November 18, 2022
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated system configurations during a complete walkdown of the
125 Vdc distribution system on November 9, 2022.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 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:
5
(1)
standby service water trains A and B pump rooms and valve rooms on
November 7, 2022
(2)
standby diesel generator building during fire protection dry pipe replacement on
November 22, 2022
(3)
remote shutdown panel room and auxiliary building, 119-foot general elevation, on
December 12, 2022
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
(1)
The inspectors reviewed and evaluated the licensed operator examination
failure rates for the requalification annual operating exam administered from
November 17, 2022, to December 15, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components (SSCs) remain capable of performing their intended
function:
(1)
condition report CR-GGN-2022-04731, evaluate control room heating, ventilation, and
air conditioning for 10 CFR 50.65(a)(1) status on November 16, 2022
(2)
condition report CR-GGN-2022-07146, steam leakage into reactor core isolation
cooling turbine on November 21, 2022
(3)
Grand Gulf cycle 21 maintenance rule 10 CFR 50.65(a)(3) assessment on
December 12, 2022
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to
ensure the following SSC remains capable of performing its intended function:
(1)
quality control for parts and commodities used on work order 52948976, maintenance
on standby liquid control pump B, on December 12, 2022
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (2 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)
maintenance risk assessment for work order 587571, turbine dump manifold valve
isolations on November 16, 2022
(2)
maintenance risk assessment of fire protection piping replacement in standby diesel
generator building on November 21, 2022
6
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1)
condition report CR-GGN-2022-09363, auxiliary building structural support not fully
welded to baseplate on October 3, 2022
(2)
condition report CR-GGN-2022-09683, combustible gas control system hydrogen
igniter on November 16, 2022
(3)
condition report CR-GGN-2022-09584, reactor core isolation cooling steam leakage
past turbine governor valve effect on oil quality on November 18, 2022
(4)
condition report CR-GGN-2022-10327, secondary containment door 1A319 on
November 18, 2022
71111.18 - Plant Modifications
Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)
(1)
The inspectors verified the site Severe Accident Management Guidelines were
updated in accordance with the boiling-water reactor generic severe accident
technical guidelines and validated in accordance with NEI 14-01, Emergency
Response Procedures and Guidelines for Beyond Design Basis Events and Severe
Accidents, revision 1.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system
operability and/or functionality:
(1)
work order 587571, turbine dump manifold valve isolations on November 16, 2022
(2)
work order 53014939, main steam line 1/2 isolation instrumentation troubleshooting
on November 21, 2022
(3)
work order 52948976, drain, flush, and replenish oil in standby liquid control
pump C41C001B on November 25, 2022
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated forced outage 24-04 activities from December 19, 2022,
through December 22, 2022. The inspectors completed inspection procedure
sections 03.01.b and 03.01.d. on December 22, 2022.
7
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability
and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (1 Sample)
(1)
work order 00575709, diesel-driven fire pump B low pressure start test on
December 29, 2023
RADIATION SAFETY
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (9 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant
walkdowns:
(1)
gamma exit monitor located at the Unit 2 133-foot elevation exit
(2)
gamma exit monitor located at the security island
(3)
gamma exit monitor located at dosimetry
(4)
personal contamination monitor located at the radwaste control room
(5)
personal contamination monitor located at the Unit 2 radiological controlled area exit
(6)
portable frisker staged for use at the radiologically controlled area exit
(7)
portable ion chamber staged for use within the radiologically controlled area
(8)
TelePole instrument staged for use within the radiologically controlled area
(9)
area radiation monitors located within the fuel handling building
Calibration and Testing Program (IP Section 03.02) (14 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection
instruments:
(1)
GEM-5, plant I.D: GEM-008
(2)
GEM-5, plant I.D: GEM-005
(3)
GEM-5, plant I.D: GEM-009
(4)
ARGOS, plant I.D: Zeus-002
(5)
ARGOS, plant I.D: Argos-015
(6)
Model 9-3, plant I.D: CHP-DR-656
(7)
TelePole II, plant I.D: CHP-TEL086
(8)
Ludlum-177 frisker, plant I.D: CHP-CR-224
(9)
main steam line 'A' area radiation monitor, plant I.D: 1D17K610A
(10)
Ludlum-177 frisker, plant I.D: CHP-CR-162
(11)
drywell high range area monitor, plant I.D: 1D21K648A
(12)
drywell high range area monitor, plant I.D: 1D21K648D
(13)
containment high range area monitor, plant I.D: 1D21K648B
(14)
containment high range area monitor, plant I.D: 1D21K648C
8
Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive
effluent monitoring and measurement instrumentation:
(1)
component cooling water radiation monitor, plant I.D: 1D17-RITS-K607
(2)
service water radiation monitor 'A', plant I.D: 1D17K604
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensees performance in controlling, labeling, and securing
the following radioactive materials:
(1)
Source 92-588, Cs-137
(2)
Source 93-088, Cs-137
(3)
The inspectors walked down areas of the 136-foot elevation radwaste yard, the Unit 2
turbine building, the warehouse, and the north laydown yard.
Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)
The inspectors walked down the following accessible portions of the solid radioactive waste
systems and evaluated system configuration and functionality:
(1)
the waste compactor, the mobile solidification system, and the resin drying
processing system
(2)
the radwaste control room to assess the operability of the radwaste system
equipment and to verify configuration
Waste Characterization and Classification (IP Section 03.03) (3 Samples)
The inspectors evaluated the following characterization and classification of radioactive
waste:
(1)
2022 - 2023 10 CFR 61 waste stream analysis for dry active waste
(2)
2022 - 2023 10 CFR 61 waste stream analysis for mechanical filters
(3)
2022 - 2023 10 CFR 61 waste stream analysis for reactor water cleanup system
Shipment Preparation (IP Section 03.04)
During an inspection on March 7, 2022, inspectors observed the preparation of LSA-II
radioactive shipment GGN-2022-0212.
Shipping Records (IP Section 03.05) (5 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through
a record review:
(1)
GGN-2018-0906; UN2916, radioactive material, type B(U), fissile-excepted, RQ;
irradiated hardware; October 9, 2018
9
(2)
GGN-2021-0113; UN3321, radioactive material, low specific activity (LSA-II), 7; one
metal cask of bead resin; January 28, 2021
(3)
GGN-2022-0107; UN2916, radioactive material, type B(U), fissile-excepted, RQ; one
metal cask of dewatered resin; January 19, 2022
(4)
GGN-2022-0201; UN2916, radioactive material, type B(U), fissile-excepted, RQ; one
metal cask of dewatered resin (RWCU); February 9, 2022
(5)
GGN-2022-1007; UN3321, radioactive material, low specific activity (LSA-II), 7; one
metal cask of resin/sludge; October 27, 2022
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
(1)
October 1, 2021, through September 30, 2022
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
(1)
October 1, 2021, through September 30, 2022
71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1)
condition report CR-GGN-2022-07617, lifted water rod on fuel assembly on
November 4, 2022
(2)
condition report CR-GGN-2022-08534, corrective actions in response to
NCV 05000416/2022002-01, "Failure to Secure Loose Items Prior to Impending
Severe Weather," on December 22, 2022
71152S - Semiannual Trend Problem Identification and Resolution
Semiannual Trend Review (Section 03.02) (1 Sample)
(1)
The inspectors reviewed the licensees corrective action program for potential
adverse trends in reactor core isolation cooling room temperatures that might be
indicative of a more significant safety issue.
71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Follow Up (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated the licensee's response to a manual scram due to loss of
feedwater on December 20, 2022.
10
OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
92702 - Follow-Up on Traditional Enforcement Actions Including Violations, Deviations,
Confirmatory Action Letters, and Orders
The inspectors reviewed the licensees response to the NOVs listed below and determined that
the reason, corrective actions taken and planned to address recurrence, and the date when full
compliance will be achieved for these violations is adequately addressed and captured on the
docket.
Follow-Up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory
Action Letters, and Orders (3 Samples)
(1)
NOV 05000416/2021092-01, Failure to Use the Work Control Process to Adjust Hand
Geometry Unit
(2)
NOV 05000416/2021092-02, Falsified Information Regarding a Condition Adverse to
Quality
(3)
NOV 05000416/2020016-01, Exam Proctor Provided Inappropriate Assistance During
Engineering Qualification Exams
INSPECTION RESULTS
Failure to Control Transient Combustibles in Accordance with Site Procedures
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
[H.5] - Work
Management
The inspectors identified a finding of very low safety significance (Green) and an associated
non-cited violation (NCV) of Facility Operating License Condition 2.C(41), Fire Protection
Program, for the failure to implement all provisions of the approved fire protection program.
Specifically, the licensee failed to control transient combustible materials per
procedure EN-DC-161, section 7.5, in a Level 1 combustible control zone.
Description: On September 28, 2022, the inspectors toured fire zone 1A222, which contains a
risk-significant combustible materials exclusion zone separating division 1 and division 2 safe
shutdown components. The inspectors observed a temporary cable installed between load
bus 21BD4 and motor control center 11B41 extending through the Level 1 combustible
control zone in fire zone 1A222 as described in the Updated Final Safety Analysis Report
(UFSAR), section 9A.5.6.3.e. The inspectors reported the transient combustible material to
work control. The licensee documented the condition in the corrective action program in
condition report CR-GGN-2022-09361.
The licensee evaluated the temporary cable as a transient combustible using station
procedure EN-DC-161, Control of Combustibles, revision 25, and determined that a
continuous fire watch was required to be stationed until the cable was removed. The
licensee removed the cable on October 7, 2022, per work order (WO) 580235-01.
The cable was installed as part of temporary modification (EC 92348) to provide temporary
power during a bus 11HD outage during refueling outage 23. The licensee's work control
process indicated that the cable was installed on March 30, 2022, and removed on
April 20, 2022, under WO 560299.
11
UFSAR, section 9A.5.6.3.(e), states the following:
Fire zone 1A222 contains both division 1 and 2 safe shutdown components. All
division 1 safe shutdown components are located south of column line 9.5. In addition,
all division 2 safe shutdown components are located north of column line 11.4.
Therefore, division 1 and 2 safe shutdown components in fire zone 1A222 are
separated horizontally by more than 28 feet. This separation distance does not
contain any intervening combustibles and an automatic sprinkler system is installed
not only within this separation distance but extending north to column line 12.2 and
south to column line 8.4. Therefore, a fire originating in fire zone 1A222 will not affect,
or propagate to affect, more than one train of safe shutdown in this fire zone.
Procedure EN-DC-161, a procedure that implements provisions of the approved fire
protection program, states the following:
fire zone 1A222 is designated as a Level 1 combustible control zone in attachment 2
step 7.1.3 requires, in part, that prior to placing non-exempt transient combustible
materials in the plant, the fire marshal shall be consulted for aggregate impacts and
the completion of a transient combustible evaluation and posting of a transient
combustible permit shall be conducted first
step 7.5.2.c.(3), Level 1, states, The aggregate threshold limit for Transient
Combustibles in Level 1 areas is (0) Zero.
step 7.5.2.e.(2), requires, IF the aggregate (total) of ALL transient combustibles in the
plant area exceeds the limits determined in section 7.5.2.c, THEN the aggregate
transient combustible threshold limits have been exceeded; the following applies:
A TCP (transient combustibles permit) shall be completed utilizing section 7.6 of this
procedure.
step 7.5.2.f.(1), states, determine IF completion of a Transient Combustible Evaluation
(TCE), AND additional compensatory measures are required as follows:
[Appendix R Plants - GGNS and RBS] A TCE shall be processed prior to the
introduction of any (non-exempt) transient combustible materials into plant areas
designated as a LEVEL 1 area AND / OR compensatory actions shall be established.
Based on the above information the inspectors determined that since the cable remained
installed after the temporary modification was closed, the cable remained installed without
adequate combustible material controls in place as required by procedure EN-DC-161.
Specifically, no transient combustible permit was processed and posted, no transient
combustible evaluation was performed, and the cable was neither continuously monitored nor
had compensatory actions been established prior to September 28, 2022.
Corrective Actions: Operations stationed a continuous fire watch until the cable was removed
on October 7, 2022, per WO 580235-01.
12
Corrective Action References: condition report CR-GGN-2022-09370 and
WO-GGN-00580235-01, CR-GGN-2022-09370, and CR-GGN-2022-09372.
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to implement all
provisions of the approved fire protection program was a performance deficiency.
Specifically, the licensee failed to control transient combustible materials in accordance
with procedure EN-DC-161.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the protection against external factors 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. Specifically, the performance deficiency resulted in a potential
fire path connecting division 1 and division 2 safe shutdown components separated by the
combustible material exclusion zone in fire zone 1A222 of the auxiliary building.
Significance: The inspectors assessed the significance of the finding using IMC 0609,
Appendix F, Fire Protection Significance Determination Process, The finding was
determined to be within the Fire Prevention and Administrative Controls area using
attachment 1 and attachment 2 as having a high degradation rating for failing to ensure the
location was free of combustibles. The inspectors assessed the significance of the finding
using IMC 0609.04, Initial Characterization of Findings, and IMC 0609, appendix F,
attachment 1, and determined the finding to be of very low safety significance (Green)
because the fire adversely affected an area with adequate automatic detection and
suppression.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of
planning, controlling, and executing work activities such that nuclear safety is the overriding
priority. The work process includes the identification and management of risk commensurate
to the work and the need for coordination with different groups or job activities. Specifically,
the licensee's work control process failed to identify the need for a combustible materials
evaluation, combustible materials permit, or establish a fire watch. In addition, the licensee
work control process that installed this temporary modification failed to properly remove this
temporary modification when the work was closed.
Enforcement:
Violation: 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 the
UFSAR as approved in the Safety Evaluations dated August 23, 1991, and
September 29, 2006.
Grand Gulf UFSAR, section 9B.1, states, in part, that the GGNS fire protection program is
described in appendix 9B of the UFSAR.
Grand Gulf UFSAR, section 9B.6, states, in part, that Administrative controls have been
establishedand include procedures togovern the handling of and limit transient fire loads
in buildings containing safety-related systems or equipment during all phases of operation
and especially during maintenance, modification, or refueling operations.
The licensee established Procedure EN-DC-161, Control of Combustibles, revision 25, in
part, to govern the handling of and limit transient fire loads in fire zone 1A222.
13
Contrary to the above, from April 20 to September 28, 2022, the licensee failed to maintain in
effect all provisions of the approved fire protection program. Specifically, no transient
combustible permit was processed and posted, no transient combustible evaluation was
performed, the cables were not continuously monitored, and no compensatory actions were
established for the temporary cables associated with EC 92348 in fire zone 1A222.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
section 2.3.2 of the Enforcement Policy.
Failure to Obtain a License Amendment for Changes Associated with Auxiliary Building
Railroad Bay Door 1A319A
Cornerstone
Severity
Cross-Cutting
Aspect
Report
Section
Not
Applicable
Open/Closed
Not
Applicable
The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes,
Tests and Experiments, section (c)(2) when the licensee failed to submit and obtain NRC
authorization for a change to the facility that would have required a license amendment.
Specifically, the change to door 1A319A resulted in a more than minimal increase in the
likelihood of occurrence of a malfunction of the auxiliary building during a tornado and
constituted a departure from a method of evaluation as described in the Updated Final Safety
Analysis Report.
Description: On October 20, 2022, the licensee was performing surveillance
Procedure 06-OT-1T48-R-0002, Standby Gas Treatment A Logic and Vacuum Test,
revision 119, on the alternate secondary containment boundary with external railroad bay
door 1A319A opened. During performance of the test, operators were unable to maintain
secondary containment pressure requiring them to declare secondary containment
inoperable. The surveillance test was secured, and secondary containment was restored to
operable by shutting external railroad bay door 1A319A. This configuration of secondary
containment, with the external railroad door closed, previously passed all surveillance
requirements on April 29, 2022, as documented in work order 52931041. The licensee
documented the failed surveillance test in the corrective action program as condition
report CR-GGN-2022-10468. Additionally, the licensee reported the loss of secondary
containment safety function to the NRC as required by 10 CFR 50.72.
In February 2004, the licensee implemented design change ER 2000-0072-001 which
installed a new external railroad bay door 1A319A as part of extending the secondary
containment boundary to include a railroad bay. Design change ER-2000-0072-001,
attachment 9.1, 50.59 review form, section B, to this design change states the door is not
designed for tornado depressurization.
UFSAR, section 1.2.2.2 states, in part, that the auxiliary building shown in figures 1.2-2
through 1.2-8 is a seismic category 1 structure. The railroad bay, including door 1A319A, is
shown on UFSAR, figure 1.2-4, and is therefore a seismic category 1 structure.
UFSAR, section 3.3.2, states that the effects of tornado loadings on seismic category 1
structures are evaluated per section 3.0 of Bechtel Topical Report BC-TOP-3A and that the
auxiliary building is designed for a 3-psig pressure drop due to tornado depressurization.
14
The new external door 1A319A formed a portion of the auxiliary building, requiring the door to
be designed and evaluated for tornado depressurization. The method of analysis that the
licensee used to approve the design change for door 1A319A did not apply the
depressurization condition as outlined in Bechtel Topical Report BC-TOP-3A. The licensees
evaluation of door 1A319A used a 0.25 psig pressure differential based on operating
parameters of the standby gas treatment system; therefore, the evaluated pressure
differential was twelve times lower than required by the UFSAR.
The inspectors concluded that the licensees depressurization analysis in design
change ER 2000-0072-001 changed the elements of the method described in the UFSAR
and the results of that analysis was neither conservative nor essentially the same.
Additionally, the licensee did not utilize a method of evaluation that had been approved by
the NRC for the intended application. Door 1A319A was neither designed nor evaluated for
tornado depressurization and the inspectors concluded that the change would result in more
than a minimal increase in the likelihood of occurrence of a malfunction of the auxiliary
building as previously evaluated in the UFSAR.
Additionally, 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that
design changes, including field changes, be subject to design control measures
commensurate with those applied to the original design.
The inspectors concluded that since the licensee did not design the new door to include
tornado depressurization as required by the UFSAR, the licensee failed to apply design
control measures commensurate with those applied to the original design.
Corrective Actions: The licensee entered this issue into their corrective action program and
performed an operability evaluation to provide reasonable assurance that the secondary
containment was operable.
Corrective Action References: condition report CR-GGN-2022-10468
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to subject a
design change to design control measures commensurate with those applied to the original
design as required by 10 CFR Part 50, Appendix B, Criterion III, Design Control, was a
performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it adversely affected the SSC and barrier performance attribute of the Barrier
Integrity Cornerstone to provide reasonable assurance that physical design barriers (fuel
cladding, reactor coolant system, and containment) protect the public from radionuclide
releases caused by accidents or events. Specifically, evaluating the modification without
considering the tornado depressurization requirement challenged the physical design of
secondary containment without adequate justification for not meeting the requirement.
Significance: The inspectors assessed the significance of the finding using IMC 0609,
Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The
inspectors determined that the finding was of very low safety significance (Green) because
the finding did not represent an actual open pathway in the structural integrity of secondary
15
containment, nor did it involve an actual reduction in function of the hydrogen ignitors in
reactor containment.
Cross-cutting Aspect: The finding was not assigned a cross-cutting aspect because the
finding was not indicative of present performance.
Enforcement: The ROPs significance determination process does not specifically consider
the regulatory process impact in its assessment of licensee performance. Therefore, it is
necessary to address this violation which impedes the NRCs ability to regulate using
traditional enforcement to adequately deter non-compliance.
The inspectors assessed the severity level using the NRC Enforcement Policy, dated
January 13, 2023, section 6.1.d.2, and determined that the violation was Severity Level IV
because it was a violation of 10 CFR 50.59 that resulted in conditions evaluated as having
very low safety significance (Green) by the significance determination process.
Violation: Title 10 CFR 50.59(c)(2) requires, in part, that a licensee shall obtain a license
amendment prior to implementing a proposed change if the change would: (ii) result in more
than a minimal increase in the likelihood of occurrence of a malfunction of a structure
important to safety previously evaluated in the UFSAR; and (viii) result in a departure from a
method of evaluation described in the UFSAR used in establishing the design bases or in the
safety analyses.
Title 10 CFR Part 50, Appendix B, Criterion III, requires, in part, that design changes,
including field changes, be subject to design control measures commensurate with those
applied to the original design.
Contrary to the above, in February 2004, the licensee failed to obtain a license amendment
prior to implementing a proposed change that resulted in a more than a minimal increase in
the likelihood of occurrence of a malfunction of a structure important to safety previously
evaluated in the UFSAR and departed from a method of evaluation described in the UFSAR,
and the licensee performed the design change and failed to subject it to design control
measures commensurate with those applied to the original design. Specifically, design
change ER 2000-0072-001 modified door 1A319A using a different method than described in
UFSAR, section 3.3.2, and the requirement for tornado depressurization was not applied and
evaluated.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
section 2.3.2 of the Enforcement Policy.
Failure to Periodically Calibrate Radiation Monitors as Required by 10 CFR 20.1501(c)
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Occupational
Radiation Safety
Green
Open/Closed
[P.5] -
Operating
Experience
The inspectors identified a Green, non-cited violation of 10 CFR 20.1501(c) for failure to
periodically calibrate area radiation monitor equipment used to perform dose rate
measurements. Specifically, since at least April 2018, the licensee discontinued periodic
calibration of 34 area radiation monitors distributed throughout the plant. The calibration
frequency of these monitors was changed to as required.
16
Description: During a review of licensee calibration records and self-assessment reports, the
inspectors determined that calibration frequencies for a total of 34 area radiation monitors
(ARMs) were no longer periodic. Upon further review, the inspectors determined that these
detectors were being calibrated at an as required frequency. The licensee implemented an
as required frequency such that the ARMs would not be calibrated unless the monitor had
failed. A calibration frequency of as required does not meet the requirement of calibrating
periodically. Calibration as required is an inappropriate maintenance strategy applied to
these radiation monitors.
The affected ARMs functions are described in the Grand Gulf UFSAR, chapter 12.3.4.1. This
chapter describes one of the roles of these ARMs is to immediately alert plant personnel
entering or working in non-radiation or low radiation areas of increasing or abnormally high
radiation levels which, if unnoticed, could possibly result in inadvertent over exposures.
Additionally, chapter 12.3.4.1.4 describes that the ARM system serves to warn plant personal
of high radiation levels in various plant areas and is designed to operate unattended detecting
and measuring ambient gamma radiation. These are functions that require the detectors to
accurately measure the radiological dose rates around them.
The method to perform ARM calibrations as required was questioned by the licensees
radiation protection staff in a pre-inspection self-assessment and documented in condition
report (CR) CR-GGN-2022-07549. This CR was initiated and assigned to the engineering
electrical/instrument and control department. The CR discusses how there is industry
operating experience with calibration frequencies for ARMs and that they need to be
calibrated in accordance with 10 CFR 20.1501(c). The CR resulted in no actions taken due to
the licensees conclusion that 10 CFR 20.1501(c) was not applicable to these ARMs.
Another CR was created 2 months later by radiation protection management, CR
CR-GGN-2022-09269, which addresses the previous CRs conclusion, in which radiation
protection questioned the conclusion that the as required calibration frequency for these
ARMs was acceptable. This CR stated that the previous CR did not involve regulatory
assurance or look at 10 CFR 20.1501(c) applicability. The licensee conducted another
evaluation of the calibration frequency for the ARMs. Once again, the licensee evaluated and
concluded that the current method is in accordance with their (the licensees) requirements.
As described in Grand Gulfs UFSAR, the function and description of these detectors show
that these detectors measure dose rate in the area they monitor, and that this information will
be used to alert staff in the area during certain radiological conditions.
Corrective Actions: The licensee entered the issue into the corrective action program to
determine appropriate actions.
Corrective Action References: condition reports CR-GGN-2022-07549,
CR-GGN-2022-09269, CR-GGN-2022-10692
Performance Assessment:
Performance Deficiency: Failure to periodically calibrate radiation monitors as required by
10 CFR 20.1501(c) is a performance deficiency.
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
17
adequate protection of the worker health and safety from exposure to radiation from
radioactive material during routine civilian nuclear reactor operation. Specifically, the
licensees program for calibration of 34 ARMs stated they would be conducted as required.
NRC characterizes this as a maintenance strategy, not a calibration frequency, which does
not comply with regulatory requirements. Therefore, the licensee does not have a calibration
frequency for these ARMs, and they calibrate them as required when parameters of the
monitor are out of tolerance, or as the monitor fails.
Significance: The inspectors assessed the significance of the finding using IMC 0609,
Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding had
very low safety significance (Green) because: (1) it was not associated with ALARA planning
and work controls; (2) it was not an overexposure; (3) there was no substantial potential for
overexposure; and (4) the ability to assess dose was not compromised.
Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and
effectively collects, evaluates, and implements relevant internal and external operating
experience in a timely manner. Specifically, the licensee had multiple opportunities to
properly evaluate the external operating experience provided to them. In addition, when an
incorrect conclusion was made during the initial evaluation, the licensees internal staff tried
to provide additional information for a more thorough and appropriate conclusion; but the
licensee still failed to properly evaluate the relative operating experience.
Enforcement:
Violation: Title 10 CFR 20.1501(c) requires, in part; the licensee ensure that instruments and
equipment used for quantitative radiation measurements (e.g., dose rate and effluents) are
calibrated periodically for the radiation measured.
Contrary to the above, since at least April 2018, the licensee failed to ensure radiation
monitors were calibrated periodically for the radiation measured. Specifically, the licensee
discontinued the periodic calibrations of 34 ARMs when the calibration of these monitors was
changed to as required.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
section 2.3.2 of the Enforcement Policy.
Failure to Comply with the Terms of the Certificate of Compliance for a Package Delivered to
a Carrier for Transport
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Public Radiation
Safety
Green
Open/Closed
[H.7] -
Documentation
The inspectors reviewed a self-revealed, Green, non-cited violation of 10 CFR 71.17 for the
licensee's failure to comply with the terms of the Certificate of Compliance (CoC) for a
package delivered to a carrier for transport. On October 9, 2018, the licensee delivered to a
carrier for transport licensed material that failed to comply with terms of the certificate for the
packaging of the shipment. Specifically, the licensee failed to use adequate load plans during
the 2018 spent fuel pool cleanup campaign, resulting in sending six shipments of irradiated
hardware offsite to a waste processing facility with inaccurate shipping paperwork. One of the
18
six shipments was later confirmed, on October 17, 2022, to contain greater than 10.0 curies
per kilogram of cobalt-60 (Co-60), which exceeded the CoC limit for the package.
Description: During the 2018 spent fuel pool cleanup campaign, the licensee failed to
accurately identify all irradiated hardware (control rod blades, velocity limiters, and fuel
channels) that was loaded into six of their shipments. These shipping errors occurred
because the licensee had inaccurate load plans, which resulted in all control rod blades on
the west wall of the spent fuel pool during the 2018 cleanup campaign to be off by one
hanger location. Thus, control rod blades that were not planned for shipment were included in
these shipments, and others that were planned for shipment remained in the spent fuel pool.
The packages of irradiate hardware were then delivered to a carrier for transport with errors
in the shipping paperwork.
On October 9, 2018, the licensee delivered to a carrier for transport licensed material (in
shipment 2018-0906) that failed to comply with terms of the certificate for the packaging of
the shipment. This was revealed during the licensee's preparation for the 2022 spent fuel
pool cleanup campaign when discrepancies in the control rod blade serial numbers were
found. It was determined that an additional 1300 curies of Co-60 was placed in
shipment 2018-0906. Based on the mass of the contents, this additional activity of Co-60
resulted in the package exceeding the CoC limit for the shipment. It was not confirmed that
shipment 2018-0906 exceeded its CoC limit until October 17, 2022, when the licensee
contracted a vendor to re-characterize the 2018 shipments.
As the licensee reviewed their 2022 load plans, they confirmed that the errors did not impact
their loading of control rod blades for the 2022 spent fuel pool cleanup campaign.
Additionally, the errors did not result in a failure to properly survey the cask, placard the cask,
or exceed any dose limits to the public. Nor did the errors change the characterization or
classification of the shipments.
The licensee was also required to submit a written report to the NRC for not following the
conditions of the CoC during a shipment. The inspectors confirmed that the licensee
submitted this written report to the NRC on November 30, 2022.
Corrective Actions: The licensee documented this issue into their corrective action program in
two condition reports. The licensee also contracted a vendor to re-characterize their 2018
shipments and confirmed that their 2022 load plan was accurate prior to completing loading
of all shipments.
Corrective Action References: condition reports CR-GGN-2022-09835 and
Performance Assessment:
Performance Deficiency: The licensee's failure to comply with the terms of the CoC for a
package delivered to a carrier for transport is a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the program and process attribute of the Public Radiation
Safety Cornerstone and adversely affected the cornerstone objective to ensure adequate
protection of public health and safety from exposure to radioactive materials released into the
public domain as a result of routine civilian nuclear reactor operation. Additionally, per
IMC 0612, appendix E, example 7(l), the performance deficiency is more than minor based
on the error exceeding 20 percent of the activity within the shipment.
19
Significance: The inspectors assessed the significance of the finding using IMC 0609,
Appendix D, Public Radiation Safety SDP. In accordance with IMC 0609, appendix D, the
finding is Green if it involves a documentation deficiency related to maintenance or use of an
NRC-approved package and does not involve the failure to perform a required action. It
states the finding is Green if it involved a failure to meet a CoC criteria for cask contents that
did not adversely impact the following: temperature, pressure, geometry, weight, burn-up,
enrichment, or moderator specification nonconformance. Specifically, the six shipments
involved had inaccurate shipping paperwork based on the incorrect irradiate hardware
contents, but only one of the six shipments exceeded the CoC limits for a non-fissile material
curie content (Co-60), as specified in the CoC.
Cross-Cutting Aspect: H.7 - Documentation: The organization creates and maintains
complete, accurate, and up-to-date documentation. Specifically, the licensee had inaccurate
load plans for their 2018 spent fuel pool cleanup campaign, which resulted in inaccurate
shipping paperwork, and one shipment exceeding its package specifications for its Co-60
activity per mass limit, as certified by the CoC. The inaccurate load plans remained in place
until 2022 when discrepancies were identified with their control rod blade serial numbers
during the 2022 spent fuel pool cleanup campaign.
Enforcement:
Violation: Title 10 CFR 71.17(c) requires, in part, that each licensee who delivers licensed
material to a carrier for transport shall comply with the terms and conditions of the license,
certificate, or other approval, as applicable, and the applicable requirements of subparts A, G,
and H.
Subpart A in 10 CFR Part 71, specifically 10 CFR 71.0(b), states, in part, that the packaging
and transport of licensed material are also subject to the regulations of other agencies (e.g.,
the U.S. Department of Transportation (DOT)).
Title 49 CFR 172.203(d)(3) requires, in part, that a radioactive material shipment must include
the maximum activity of the radioactive contents contained in each package during transport
in terms of the appropriate SI units (e.g., Becquerels (Bq), Terabecquerels (TBq)). The
activity may also be stated in appropriate customary units (e.g., Curies (Ci), milliCuries (mCi),
microCuries (uCi)) in parentheses following the SI units.
Contrary to the above, on October 9, 2018, the licensee delivered to a carrier for transport
licensed material that failed to comply with terms of the certificate for the packaging of the
shipment. This issue was not identified until October 17, 2022. Additionally, the licensee
failed to provide accurate shipping paperwork with the correct maximum radioactivity in the
package, which included an additional 1300 Curies of Co-60 in a shipment (2018-0906),
which based on its mass, exceeded the CoC limit for the shipment. Specifically, the licensee
failed to accurately identify all irradiated hardware (control rod blades, velocity limiters, and
fuel channels) that was loaded into six packages during the spent fuel pool cleanup in 2018.
The packages were then delivered to a carrier for transport with errors in the shipping
paperwork. However, the errors did not result in a failure to properly survey the cask, placard
the cask, or exceed any dose limits to the public. Nor did the errors change the
characterization or classification of the shipments.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
section 2.3.2 of the Enforcement Policy.
20
Enforcement
Discretion
Enforcement Action EA-22-131: Enforcement Discretion for a
Minor Violation of 10 CFR 37.11(c) for Failure to Comply with
Exemptions for the Monitoring, Detecting, and Assessment of a
Robust Structure
Description: During the licensees refueling outage in 2012, the licensee removed the large
steam dryer from the containment building. The steam dryer was heavy, so it was cut up and
stored in three separate shielded boxes with other dryer parts. Each shielded and secured
box weighed more than 10,000 lbs. The three boxes were then transferred to a large concrete
storage building outside of the protected area, named the North Laydown Yard Mausoleum.
Although this waste material exceeded the threshold for a category 2 quantity of radioactivity,
it did not contain discrete radioactive sources, ion-exchange resins, or activated material that
weighed less than 2,000 kg. Therefore, the steam dryer boxes are considered waste material
that is exempt from 10 CFR Part 37, subparts B, C, and D, but must comply with the
requirements of 10 CFR 37.11(c). The inspectors observed that some of these requirements
were not met.
Corrective Actions: The licensee entered this issue into their corrective action program.
Corrective Action References: condition report CR-GGN-2022-11272
Enforcement:
Violation: Title 10 CFR 37.11 requires, in part, minimal security requirements for a category 2
quantity of radioactive waste that is exempt from 10 CFR Part 37, subparts B, C, and D.
Contrary to the above, from March 19, 2014 (initial compliance date with 10 CFR Part 37) to
the present, the licensee has stored a category 2 quantity of exempt waste in a large
concrete storage module without meeting all of the security requirements of 10 CFR 37.11(c).
Basis for Discretion: This violation met the criteria for Enforcement Discretion as described in
Enforcement Guidance Memorandum (EGM) 14-001, Interim Guidance for Dispositioning
10 CFR Part 37 Violations with Respect to Large Components or Robust Structures
Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities
Licensed Under 10 CFR Parts 50 and 52.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On October 20, 2022, the inspectors presented the IP 92702 inspection results to
Russell Williams, General Manager Plant Operations, and other members of the
licensee staff.
On December 16, 2022, the inspectors presented the public radiation safety inspection
results to Brad Kapellas, Site Vice President, and other members of the licensee staff.
On December 22, 2022, the inspectors presented the debrief of Grand Gulfs annual
operations requalification exam inspection results to Anthony Watson, Exam Supervisor,
and other members of the licensee staff.
On January 5, 2023, the inspectors presented the integrated inspection results to Brad
Kapellas, Site Vice President, and other members of the licensee staff.
21
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-GGN-
2019-09017, 2020-08196, 2020-10279, 2021-00242, 2021-
05925, 2022-02858, 2022-06470, 2022-08860, 2022-08882,
2022-09921, 2022-10294
Drawings
E1022
One Line Meter & Relay Diagram 125V DC Bus 11CC 11DE
UFSAR Figure 08.3-10B
36
Drawings
E1023
One Line Meter & Relay Diagram 125V DC Bus 11DA,
11DB, & 11DC UFSAR Figure 08.3-010
39
Drawings
M-0049
P&ID Control Room Heating Ventilation @ Air Conditioning
System UFSAR Figure 09.4-001
47
Drawings
M-1061A
P&ID Standby Service Water System UFSAR Figure 09.2-
001
69
Drawings
M-1061B
P&ID Standby Service Water System UFSAR Figure 09.2-
002
53
Drawings
M-1061C
P&ID Standby Service Water System
38
Drawings
M-1061D
P&ID Standby Service Water System
40
Procedures
04-1-01-L11-1
Plant DC Systems
Procedures
04-1-01-P41-1
Standby Service Water System
Corrective Action
Documents
CR-GGN-
2022-09347
Fire Plans
Fire Pre-Plan SSW-01
30
Procedures
Control of Combustibles
25
Miscellaneous
Grand Gulf 2022 Annual Ops Test Results
12/21/2022
Corrective Action
Documents
CR-GGN-
2022-04073, 2022-04109, 2022-04731, 2022-04832, 2022-
07146, 2022-09773, 2022-10628
Miscellaneous
Commercial Grade Dedication for UTC 639566
Miscellaneous
Commercial Grade Dedication for UTC 668980
Miscellaneous
10538448
Purchase Order
Miscellaneous
10552345
Purchase Order
Miscellaneous
10608490
Purchase Order
Miscellaneous
55899
Receiving Document
Miscellaneous
56634
Receiving Document
Miscellaneous
64413
Receiving Document
22
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Self-Assessments Fuel Cycle 21
Periodic
Assessment #2
0
Work Orders
Calculations
C-H015.3
3
Corrective Action
Documents
CR-GGN-
2002-02594, 2021-02394, 2022-09363, 2022-09584, 2022-
09679, 2022-09683, 2022-09844, 2022-10327, 2022-10468,
2022-10474, 2022-10628, 2022-10687
Drawings
A-1162
4
Drawings
A-1165
2
Engineering
Changes
FCN-A-377
Miscellaneous
Reactor Plant Event Notification Worksheet #56171
10/20/2022
Procedures
06-OP-1T48-M-
0003
Secondary Containment Integrity Check
115
Miscellaneous
Plant Operations
Manual 05-S-01-
TSTG1
Plant Specific Technical Guidelines Volume 1
0
Corrective Action
Documents
CR-GGN-
2021-05709
Procedures
06-IC-1B21-Q-
2006
Main Condenser Low Vacuum (MSLIS) Functional Test,
Safety Related
Work Orders
WO 565822, 587571, 52948976, 53014939
Procedures
06-OP-SP64-A-
0046
Fire Pumps Low Pressure Start Functional Test
106
Work Orders
Calibration
Records
ARGOS-015
Calibration data for ARGOS monitor
06/13/2022
Calibration
Records
CHP-AMSD-025
Calibration data for AMS-4 detector
11/01/2021
Calibration
Records
CHP-CR-162
Calibration data for Ludlum-177 frisker
12/14/2021
Calibration
Records
CHP-CR-224
Calibration data for Ludlum-177 frisker
12/07/2021
23
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calibration
Records
CHP-DR-589
Calibration data for model 9-3 detector
12/06/2021
Calibration
Records
CHP-DR-656
Calibration data for model 9-3 detector
11/16/2022
Calibration
Records
GEM-005
Calibration data for GEM-5 passive monitor
09/27/2022
Calibration
Records
GEM-008
Calibration data for GEM-5 passive monitor
06/22/2022
Calibration
Records
GEM-009
Calibration data for GEM-5 passive monitor
06/10/2022
Calibration
Records
ZEUS-002
Calibration data for ZEUS monitor
10/18/2022
Corrective Action
Documents
CR-GGN-
2017-00612, 2020-11288, 2020-11394, 2021-04225, 2021-
04904, 2021-05260, 2021-08760, 2022-00186, 2022-01096,
2022-03094, 2022-07549, 2022-09269, 2022-10690, 2022-
10709
Procedures
06-IC-01D17-A-
0013
GE Radioactive Gaseous Effluent Monitor Calibration
107
Procedures
06-IC-1D21-R-
1002
Containment/Drywell High Range Area Radiation Monitor
Calibration
107, 108,
113
Procedures
07-S-53-D21-1
Area Radiation Monitors
22
Procedures
08-S-07-100
Canberra Fastscan Whole Body Counter System Operation
and Calibration
0
Procedures
08-S-07-99
Operation and Calibration of the ZEUS Personnel
Contamination Monitor
2
Procedures
10-S-01-1
Emergency Plan Procedure
126
Procedures
10-S-01-39
Grand Gulf Equipment important to Emergency Response
7
Procedures
Operation and Calibration of the CRONOS Contamination
Monitor
3
Procedures
EN-RP-317-05
Calibration of Extendable Dose Rate Instruments
1
Procedures
EN-RP-317-07
Calibration of Portable Count Rate Instruments
3
Procedures
EN-RP-317-10
Calibration of Portable Dose Rate Instruments
3
Self-Assessments LO-GLO-2021-
00090
Self-assessment for pre-NRC inspection: radiation
monitoring instrumentation assessment (71124.05)
08/30/2022
24
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
WO 531503, 542468, 542472, 52802197, 52842051, 52842512,
52897026, 52917458, 52934418, 52941573, 52946030,
52956678, 52959927, 52978368, 52981922, 52986782
Corrective Action
Documents
CR-GGN-
2021-00059, 2021-01916, 2021-05603, 2021-05747, 2021-
06664, 2022-00481, 2022-01698, 2022-02749, 2022-03617,
2022-07481, 2022-07483, 2022-08059, 2022-08582, 2022-
09835, 2022-10103
Corrective Action
Documents
Resulting from
Inspection
CR-GGN-
2022-10627, 2022-10629, 2022-10662, 2022-10698
Miscellaneous
Grand Gulf Nuclear Generating Station Updated Final Safety
Analysis Report (UFSAR), Chapter 11.4 - Solid Radwaste
System
4
Miscellaneous
21-107F
WMG Report: 2018 Fuel Pool Shipments Re-
Characterization
10/20/2022
Miscellaneous
GIN-2022-00001
2022 - 2023 10 CFR 61 Waste Stream Analysis for CFFF
Mechanical Filters
01/04/2022
Miscellaneous
GIN-2022-00025
2022 - 2023 10 CFR 61 Waste Stream Analysis for RWCU-
A_2-2022
02/03/2022
Miscellaneous
GIN-2022-00136
2022 - 2023 10 CFR 61 Waste Stream Analysis for Dry
Active Waste
07/12/2022
Miscellaneous
GNRO-
2019/00024
Grand Gulf Nuclear Station Annual Radioactive Effluent
Release Report (ARERR) - 2018
04/30/2019
Miscellaneous
GNRO-
2021/00015
Grand Gulf Nuclear Station Annual Radioactive Effluent
Release Report (ARERR) - 2020
04/28/2021
Miscellaneous
GNRO-2022-
00018
Grand Gulf Nuclear Station Annual Radioactive Effluent
Release Report (ARERR) - 2021
04/28/2022
Miscellaneous
GNRO-2022-
00034
Grand Gulf Nuclear Station Report Pursuant to
10CFR71.95(b) to report a failure to comply with conditions
of Certificate of Compliance during a shipment
11/30/2022
Miscellaneous
WMG Project 10-
075E
Preliminary Characterization and Classification of the Grand
Gulf Steam Dryer
08/23/2010
Procedures
Radiation Protection Posting
23
25
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Radioactive Material Control
18
Procedures
Source Control
14
Procedures
Radioactive Waste Management
3
Procedures
Radioactive Shipping Procedure
20
Procedures
Scaling Factors
14
Procedures
5
Procedures
Integrated Transportation Security Plan
7
Radiation
Surveys
GG-1205-0988
Mausoleum
05/16/2012
Radiation
Surveys
133-foot Onsite RAM Storage Area North West
08/07/2022
Radiation
Surveys
Northwest Laydown Area
09/29/2022
Radiation
Surveys
133-foot Turbine Building Truck Bay
10/02/2022
Radiation
Surveys
133-foot Aux Truck Bay
11/01/2022
Radiation
Surveys
93-foot Radwaste Hallway
11/07/2022
Self-Assessments LO-GLO-2021-
0091
Pre-NRC Inspection Module 71124.08, Radioactive Solid
Waste Processing and Radioactive Material Handling,
Storage, and Transportation
08/11/2022
Self-Assessments LO-GLO-2022-
0079
GGNS Self-Assessment: Source Control
09/14/2022
Self-Assessments QA-14-15-2021-
GGNS-1
Combined Radiation Protection and Radwaste
10/25/2021
Shipping Records
UN2916, radioactive material, type B(U), fissile-excepted,
RQ; irradiated hardware
10/09/2018
Shipping Records
UN3321, radioactive material, low specific activity (LSA-II), 7;
one metal cask of bead resin
01/28/2021
Shipping Records
UN2916, radioactive material, type B(U), fissile-excepted,
RQ; one metal cask of dewatered resin
01/19/2022
Shipping Records
UN2916, radioactive material, type B(U), fissile-excepted,
RQ; one metal cask of dewatered resin (RWCU)
02/09/2022
26
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Shipping Records
UN3321, radioactive material, low specific activity (LSA-II), 7;
one metal cask of resin/sludge
10/27/2022
Work Orders
Leak Test of Sealed Sources
05/13/2022
Corrective Action
Documents
CR-GGN-
2022-03776, 2022-07617, 2022-07719, 2022-08534
Miscellaneous
Grand Gulf Cycle 24 Raised Water Rod Evaluation
Miscellaneous
Responses to Grand Gulf NRC Resident PRC 22-04
Miscellaneous
Engineering
Report ECH-NE-
22-00019
Lifted Water Rod on Fuel Assembly
Corrective Action
Documents
CR-GGN-
2019-01757, 2019-01833, 2021-01451, 2021-01536, 2021-
02950, 2022-07146, 2022-09773, 2022-10127
Miscellaneous
10462339
Purchase Order
02/04/2016
Miscellaneous
10472129
Purchase Order
02/17/2016
Miscellaneous
10537921
Purchase Order
02/07/2018
Miscellaneous
10619352
Purchase Order
08/25/2020
Miscellaneous
2021-001-00
Licensee Event Report
05/14/2021
Miscellaneous
55636
Receiving Inspection Report
05/22/2018
Procedures
EN-LI-108-01
10 CFR 21 Evaluations and Reporting
13
Procedures
EN-LI-108-01
10 CFR 21 Evaluations and Reporting
14
Work Orders
WO 558041, 52782092, 52839101, 52884887
92702
Corrective Action
Documents
CR-GGN-
2020-08268,
92702
Corrective Action
Documents
Adverse
Condition
Analysis -
Confidential - CR-
Inappropriate Proctoring Behaviors
0
92702
Corrective Action
Documents
Adverse
Condition
Analysis -
Confidential - CR-
Nantel Exam Compromise
0
92702
Corrective Action
CR-GGN-2019-
Address event in CR-GGN-2019-06440 which was
09/06/2019
27
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
07343
improperly closed
92702
Corrective Action
Documents
CR-GGN-2020-
05448
While working on a flange, workers did not use proper
verification behaviors
04/22/2020
92702
Corrective Action
Documents
CR-GGN-2020-
05564
MSIV 1B21F022B will not open when the hand switch is
placed in Auto
04/25/2020
92702
Corrective Action
Documents
CR-GGN-2020-
05570
Material found blocking flow upstream flange
04/26/2020
92702
Corrective Action
Documents
CR-GGN-2020-
08108
Drive fleet of extent of condition from CR-GGN-2020-05564
and 05570
07/13/2020
92702
Corrective Action
Documents
CR-HQN-2019-
02641
Drive evaluation of extent of condition/cause and
organizational and programmatic factors related to
11/14/2019
92702
Corrective Action
Documents
CR-HQN-2019-
02904
Drive evaluation of fleet extent of condition, fleet
organizational and programmatic and if needed fleet extent
of cause related to CR-GGN-2019-07343
12/19/2019
92702
Corrective Action
Documents
CR-HQN-2020-
00033
Trend in exam administration related issues
01/09/2020
92702
Corrective Action
Documents
CR-HQN-2020-
00269
Trend in willful misconduct in the fleet
02/06/2020
92702
Corrective Action
Documents
LO-HQNLO-2020-
00020
Effectiveness reviews for CR-HQN-2020-00269
03/13/2020
92702
Corrective Action
Documents
Resulting from
Inspection
CR-GGN-
2022-09938
10/20/2022
92702
Corrective Action
Documents
Resulting from
Inspection
CR-GGN-2019-
06074
Rewrite of CR-GGN-2019-05674
07/26/2019
92702
Corrective Action
Documents
Resulting from
Inspection
CR-GGN-2022-
09940
NRC inspector identified that maintenance did not follow EN-
MA-125 Troubleshooting Control of Maintenance Activities
10/22/2022
92702
Miscellaneous
2020-01083
Internal Investigation
09/17/2020
28
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
92702
Miscellaneous
ICI-2020-00969
Fact Finding Summary
05/05/2020
92702
Miscellaneous
Internal
Investigation
2019-01079
Exam proctor integrity was called into question
07/29/2019
92702
Miscellaneous
LM-0311
Qualification
Matrix
October
2022
92702
Procedures
Configuration and
Change
Management
EN-IT-103-12
3
92702
Procedures
Troubleshooting Control of Maintenance Activities
25
92702
Procedures
Nuclear Excellence Model
0
92702
Procedures
EN-TQ-201-04
SAT - Implementation Phase
10
92702
Procedures
Training and Qualification Curriculum
7
92702
Procedures
Examination Security
10
92702
Procedures
FFAM-TRNI-
NONCBTPROC
Proctor Familiarization Guide (Non-CBT)
0
92702
Procedures
TQF-217-
EXAMPROCT
Exam Proctor Checklist
5
92702
Procedures
TQF-217-INBR
Exam Integrity Briefing
6
92702
Procedures
TQF-217-PRAP
NANTel Proctor Qualification Approval
3
92702
Procedures
TQF-217-PROBS
NANTeL Proctor Observation Form
5
92702
Procedures
TQF-217-
PROBS-NONCBT
Non-CBT Proctor Observation Form
2
92702
Procedures
Work Request Generation, Screening and Classification
18