ML23110A800
ML23110A800 | |
Person / Time | |
---|---|
Site: | Grand Gulf ![]() |
Issue date: | 05/10/2023 |
From: | Jeffrey Josey NRC/RGN-IV/DORS/PBC |
To: | Kapellas B Entergy Operations |
Rollins J | |
References | |
EA-22-104, EA-22-115, 4-2022-004 4-2022-004 | |
Download: ML23110A800 (40) | |
See also: IR 05000416/2023001
Text
May 10, 2023
EA-22-115
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 - NOTICE OF VIOLATION; INTEGRATED
INSPECTION REPORT 05000416/2023001 AND NRC INVESTIGATION
REPORT 4-2022-004
Dear Brad Kapellas:
This letter refers to an investigation completed on November 8, 2022, and an inspection
completed on March 31, 2023, by the U.S. Nuclear Regulatory Commission (NRC) at the Grand
Gulf Nuclear Station. The purpose of the investigation was to determine whether a willful
violation of NRC requirements occurred for the failure to write a condition report after it was
discovered that a required fire watch had not been established. On April 6, 2023, the NRC
inspectors discussed the results of the investigation and the inspection with you and other
members of your staff. A factual summary of the investigation is documented in Enclosure 2 and
the results of the inspection are documented in Enclosure 3.
The enclosed report documents a Severity Level IV violation of Title 10 of the Code of Federal
Regulations (10 CFR) Part 50, appendix B, criterion V, for the failure to initiate a condition report
after it was discovered that a required fire watch had not been established. The NRC evaluated
this violation in accordance with section 2.3.2 of the NRC Enforcement Policy, which can be
found at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is
cited in Enclosure 1, Notice of Violation (Notice), and the circumstances surrounding it are
described in detail in the enclosed report. The violation did not meet the criteria to be treated as
a non-cited violation (NCV) because it involved willfulness.
The enclosed report also documents a Severity Level IV violation of 10 CFR 21.21(d) for the
failure to notify the Commission after the discovery of a defect associated with a substantial
safety hazard evaluation. The NRC evaluated this violation in accordance with section 2.3.2 of
the NRC Enforcement Policy. The violation is cited in Enclosure 1 and the circumstances
surrounding it are described in detail in the enclosed report. This violation did not meet the
criteria to be treated as an NCV because we determined that your staff failed to restore
compliance within a reasonable period after the violation was identified.
B. Kapellas 2
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. The NRCs review of your response will also
determine whether further enforcement action is necessary to ensure your compliance with
regulatory requirements.
Based on the results of this inspection, the NRC has also determined that a violation of
10 CFR 21.21(a)(1) occurred. The violation involved the failure to evaluate deviations and
failures to identify defects associated with substantial safety hazards as soon as practicable and
in all cases within 60 days of discovery, in order to identify a reportable defect that could create
a substantial safety hazard. This violation was considered for escalated enforcement at Severity
Level III per the NRC Enforcement Policy. .However, in reviewing the specific circumstances of
this violation (i.e., the NRC resident staff was aware of the issue, and there was little to no
impact to the inspection process/regulatory process; the impact to overall containment leakage
is mitigated by the size of the valves; your staff entered the issue into the corrective action
program and issued a licensee event report after they concluded it was reportable under
10 CFR 50.73; and the valves were only supplied to the Grand Gulf Nuclear Station and no
other licensees) the NRC determined that it is more appropriately categorized as a Severity
Level IV violation. In addition, because the violation was entered into the corrective action
program, corrected by your staff, not repetitive, and not willful, it is being treated as an NCV,
consistent with section 2.3.2 of the NRC Enforcement Policy.
Additionally, two findings of very low safety significance (Green) are documented in this report.
One of these findings involved a violation of NRC requirements. Two Severity Level IV violations
without an associated finding are also documented in this report. We are treating these
violations as NCVs consistent with section 2.3.2 of the NRC Enforcement Policy.
Licensee-identified violations which were determined to be of very low safety significance are
documented in this report. We are treating these violations as NCVs consistent with
section 2.3.2 of the NRC Enforcement Policy.
In the preceding 12 months, the NRC issued five Severity Level IV traditional enforcement
violations as described in NRC Inspection Report 05000416/2022002, dated August 9, 2022,
and in this report. One violation was associated with willfulness and the other four violations
were associated with impeding the regulatory process. The NRC noted that the four violations
associated with impeding the regulatory process appear to show a gap in your process for
making required reports to the NRC. The NRC determined that one of the examples was not
representative of current plant performance. However, the NRC has determined that the other
three violations were indicative of current performance, and the NRC is evaluating whether
performance of Inspection Procedure 92723, Follow up Inspection for Three or More Severity
Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period, is
warranted. This decision will be documented in future correspondence.
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 3
If you disagree with a cross-cutting aspect assignment or a finding not associated with a
regulatory requirement in this report, you should provide a response within 30 days of the date
of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the
Regional Administrator, Region IV; and the NRC Resident Inspector at Grand Gulf Nuclear
Station.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a
copy of this letter, its enclosures, and your response, will be made available electronically for
public inspection in the NRC Public Document Room and from the NRCs ADAMS, accessible
from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible,
your response should not include any personal privacy or proprietary information so that it can
be made available to the public without redaction.
Sincerely,
Signed by Josey, Jeffrey
on 05/10/23
Jeffrey E. Josey, Chief
Projects Branch C
Division of Operating Reactor Safety
Docket No. 05000416
License No. NPF-29
Enclosures:
1. Notice of Violation
2. Factual Summary
3. Inspection Report 05000416/2023001
cc w/ encl: Distribution via LISTSERV
x Non-Sensitive x Publicly Available
x SUNSI Review
Sensitive Non-Publicly Available
OFFICE SES:ACES SRI:DORS/C ATL:ACES RC ASPE:DORS/C
NAME JKramer TSteadham RKumano DCylkowski JRollins
SIGNATURE /RA/ E /RA/ E /RA/ E /RA/ E /RA/ E
DATE 04/26/23 04/26/23 04/26/23 04/25/23 04/26/23
OFFICE ATL:DORS/IPAT RI:DORS/C OGC OE D:DORS
NAME WSchaup ASmallwood RCarpenter GGulla RLantz
SIGNATURE /RA/ E /RA/ E /NLO/ E /RA/ E /RA/ E
DATE 04/25/23 04/21/23 05/04/23 05/01/23 05/10/23
OFFICE BC:DORS/C
NAME JJosey
SIGNATURE /RA/ E
DATE 05/10/23
NOTICE OF VIOLATION
Entergy Operations, Inc. Docket No. 05000416
Grand Gulf Nuclear Station License No. NPF-29
During an NRC investigation completed on November 8, 2022, and an NRC inspection
completed on March 31, 2023, two violations of NRC requirements were identified. In
accordance with the NRC Enforcement Policy, the violations are listed below:
A. 10 CFR 21.21(a)(3) requires, in part, that entities subject to the regulations in
10 CFR Part 21 shall ensure that a director or responsible officer is informed as soon
as practicable, and, in all cases, within the 5 working days after completion of the
evaluation described in 10 CFR 21.21(a)(1).
10 CFR 21.21(d) requires, in part, that a director or responsible officer must notify the
Commission when he or she obtains information reasonably indicating a failure to
comply or a defect within 2 days following receipt of the information.
Contrary to the above, from August 13 to October 31, 2022, the licensee failed to notify
the Commission after the discovery of a defect associated with a substantial safety
hazard evaluation described in 10 CFR 21.21(a)(1). Specifically, the licensee identified
that the lack of lubrication on the containment personnel airlock equalizing valves
caused the excessive leakage and evaluated the condition as a substantial safety
hazard on August 3, 2022, but failed to make the timeliness requirements to notify the
Commission.
This is a Severity Level IV violation (NRC Enforcement Policy, section 6.9(d)(13). (EA-22-104)
B. 10 CFR Part 50, appendix B, criterion V requires, in part, that activities affecting quality
shall be accomplished in accordance with documented instructions, procedures, or
drawings, of a type appropriate to the circumstances.
Procedure EN-LI-102, Corrective Action Program, revision 45, a quality-related
procedure, attachment 1, step 21 states, in part, that any condition which materially
impacts the ability to implement the fire protection program including degraded fire
barriers and their subcomponents (penetration seals, fire doors and dampers), and fire
detection and suppression systems, be screened as an adverse condition in the
corrective action program.
Procedure EN-LI-102, step 5.2.4 requires, in part, that employees and contractors are
required to initiate condition reports for adverse conditions.
Contrary to the above, from September 15, 2021, to April 20, 2022, licensed personnel
failed to initiate a condition report for adverse conditions. Specifically, a licensed
operator deliberately failed to write a condition report for a condition which materially
impacted the ability to implement the fire protection program when a continuous fire
watch was not established.
Enclosure 1
This is a Severity Level IV violation (NRC Enforcement Policy, section 2.2.1.d). (EA-22-115)
Pursuant to 10 CFR 2.201, Entergy Operations, Inc. is hereby required to submit a written
statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control
Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear
Regulatory Commission, Region IV, 1600 East Lamar Blvd., Arlington, Texas 76011-4511,
and the NRC Resident Inspector at the Grand Gulf Nuclear Station, and email it to
R4Enforcement@nrc.gov within 30 days of the date of the letter transmitting this Notice. This
reply should be clearly marked as a Reply to a Notice of Violation, EA-22-104 and EA-22-115,
and should include for each violation: (1) the reason for the violation, or, if contested, the basis
for disputing the violation or severity level; (2) the corrective steps that have been taken and the
results achieved; (3) the corrective steps that will be taken; and (4) the date when full
compliance will be achieved.
Your response may reference or include previous docketed correspondence if the
correspondence adequately addresses the required response. If an adequate reply is not
received within the time specified in this Notice, the NRC may issue an order or a demand for
information requiring you to explain why your license should not be modified, suspended, or
revoked, or why such other action as may be proper should not be taken. Where good cause is
shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001.
Your response will be made available electronically for public inspection in the NRC Public
Document Room and from the NRCs ADAMS, accessible from the NRC website at
http://www.nrc.gov/reading-rm/adams.html. Therefore, to the extent possible, your response
should not include any personal privacy or proprietary information so that it can be made
available to the public without redaction.
If personal privacy or proprietary information is necessary to provide an acceptable response,
then please provide a bracketed copy of your response that identifies the information that
should be protected and a redacted copy of your response that deletes such information. If you
request that such material is withheld from public disclosure, you must specifically identify the
portions of your response that you seek to have withheld and provide in detail the bases for your
claim (e.g., explain why the disclosure of information will create an unwarranted invasion of
personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for
withholding confidential commercial or financial information).
Dated this 10th day of May 2023
2
FACTUAL SUMMARY
OFFICE OF INVESTIGATIONS REPORT 4-2022-004
On December 8, 2021, the U.S. Nuclear Regulatory Commission (NRC) Office of Investigations
Region IV initiated an investigation to determine if a licensed operator, employed by Entergy
Operations Inc. (licensee) at the Grand Gulf Nuclear Station (GGNS), deliberately failed to write
a condition report after licensee personnel discovered that a required fire watch had not been
established. The investigation was completed on November 8, 2022.
Licensee document 1-FTR-0406 required a continuous fire watch be established for the
division 1 and division 2 switchgear rooms beginning on September 14, 2021. On
September 15, 2021, a licensed operator identified that the required fire watch had not been
established. Following the discovery, the control room staff dispatched two non-licensed
operators to perform the fire watch duties until they were relieved by mechanical maintenance
personnel.
Procedure EN-LI-102, Corrective Action Program, revision 45, a quality-related procedure,
attachment 1, step 21, states, in part, that any condition which materially impacts the ability
to implement the fire protection program including degraded fire barriers and their
subcomponents (penetration seals, fire doors and dampers), and fire detection and
suppression systems, be screened as an adverse condition in the corrective action program.
Procedure EN-LI-102, step 5.2.4 requires, in part, that employees and contractors are required
to initiate condition reports for adverse conditions.
Based on the evidence obtained during the investigation, there was sufficient information to
demonstrate that a licensed operator deliberately failed to write a condition report for not
establishing a required fire watch. The licensed operator knew that no condition report had been
written by any other licensee employee, and the licensed operator knew that the failure to write
a condition report was contrary to licensee policy and NRC regulations.
Enclosure 2
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number: 05000416
License Number: NPF-29
Report Number: 05000416/2023001
Enterprise Identifier: I-2023-001-0011
Licensee: Entergy Operations, Inc.
Facility: Grand Gulf Nuclear Station
Location: Port Gibson, MS
Inspection Dates: January 1 to March 31, 2023
Inspectors: N. Greene, Senior Health Physicist
S. Hedger, Senior Emergency Preparedness Inspector
W. Schaup, Senior Project Engineer
E. Simpson, Health Physicist
A. Smallwood, Resident Inspector
T. Steadham, Senior Resident Inspector
Approved By: Jeffrey E. Josey, Chief
Projects Branch C
Division of Operating Reactor Safety
Enclosure 3
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. Licensee-identified
non-cited violations are documented in report sections: 71111.24 and 71153.
List of Findings and Violations
Failure to Initiate a Condition Report for a Condition Adverse to Quality
Cornerstone Significance/Severity Cross-Cutting Report
Aspect Section
Mitigating Severity Level IV None 71111.05
Systems NOV 05000416/2023001-01
Open
The inspectors identified a Severity Level IV violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, for the failure to follow station
Procedure EN-LI-102, Corrective Action Program, that requires all employees and
contractors to initiate condition reports for adverse conditions. Specifically, after determining
a required fire watch was not posted, an adverse condition, a licensed operator failed
to promptly document the condition in a condition report.
Failure to Control Transient Combustibles in the Auxiliary Building
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.1] - 71111.18
Systems NCV 05000416/2023001-02 Resources
Open/Closed
The inspectors identified four examples of a Green finding and non-cited violation of License
Condition 2.C(41), Fire Protection Program, for the licensees failure to implement all
provisions of the approved fire protection program described in the NRC Safety Evaluation
dated September 29, 2006, related to License Amendment 170 to operating license NPF-29.
Specifically, the licensee failed to store transient combustible materials in the auxiliary building
as required by the safety evaluation.
2
Failure to Adequately Verify Design Change
Cornerstone Significance Cross-Cutting Report
Aspect Section
Initiating Events Green None 71153
Open/Closed
A self-revealed Green finding was identified for the licensees failure to perform appropriate
design verifications of an engineering change associated with the feedwater heater level
control valves. As a result, the system response of a condensate booster pump trip was not
adequately analyzed which contributed to a loss of feedwater event and plant scram when a
condensate booster pump tripped on December 19, 2022. This event was reported as
Licensee Event Report 05000416/2022-003-00.
Failure to Submit a Licensee Event Report Within 60 Days
Cornerstone Severity Cross-Cutting Report
Aspect Section
Not Applicable Severity Level IV Not Applicable 71153
Open/Closed
The inspectors identified two examples of a Severity Level IV non-cited violation of
10 CFR 50.73(a), Licensee Event Report System, for the licensees failure to submit two
licensee event reports within 60 days after discovery of the event. Specifically, the licensee
determined on November 4, 2021, that an issue associated with jet pump summer
miscalibration resulted in multiple cases of operation in a condition prohibited by technical specification 3.2.2 and the licensee event report was submitted 76 days later, on
January 19, 2022. Additionally, the licensee determined on December 2, 2021, that an issue
associated with oscillation power range monitors was a reportable event and the licensee
event report was submitted 62 days later on February 2, 2022.
Failure to Evaluate a Deviation for 10 CFR Part 21 Applicability
Cornerstone Severity Cross-Cutting Report
Aspect Section
Not Applicable Severity Level IV Not Applicable 71153
Open/Closed
The inspectors identified a Severity Level IV non-cited violation of 10 CFR 21.21(a)(1) for the
licensees failure to evaluate a deviation in a basic component within 60 days of discovery. As
a result, the licensee failed to evaluate a deviation identified on April 21, 2021, that was
associated with a reportable defect that could have created a substantial safety hazard were it
to have remained uncorrected within 60 days of discovery. The licensee completed the
evaluation on August 10, 2022, and determined that the deviation was associated with a
substantial safety hazard and was required to be reported under 10 CFR Part 21.
3
Failure to Make a Timely 10 CFR Part 21 Report
Cornerstone Severity Cross-Cutting Report
Aspect Section
Not Applicable Severity Level IV Not Applicable 71153
Open
The inspectors identified a Severity Level IV violation of 10 CFR 21.21(a)(3) and
10 CFR 21.21(d) for the licensees failure to make a 10 CFR Part 21 report within the required
time limits specified in 10 CFR Part 21. Specifically, the licensee notified the responsible
officer 55 working days after making the determination that a substantial safety hazard existed
(50 working days late) and the report was made three calendar days after the responsible
officer was notified (one day late).
Additional Tracking Items
Type Issue Number Title Report Section Status
LER 05000416/2021-001-01 Primary Containment Outer 71153 Closed
Airlock Door Inoperable Due
to Unacceptable Leak Rate
LER 05000416/2021-004-00 Procedure Inadequacy 71153 Closed
Resulted in Core Monitoring
System Miscalibration and
Violation of Technical
Specification
LER 05000416/2021-005-00 Oscillation Power Range 71153 Closed
Monitors (OPRMs) Setpoint
Error Causes Technical
Specification Noncompliance
LER 05000416/2022-001-00 Manual Reactor Trip Due to 71153 Closed
the Loss of Balance of Plant
Transformer 23
LER 05000416/2022-003-00 Manual Reactor SCRAM due 71153 Closed
to a Loss of the Condensate
and Feed Water System
4
PLANT STATUS
Grand Gulf Nuclear Station, Unit 1, began the inspection period at 100 percent rated thermal
power (RTP). On March 31, 2023, operators reduced power to 67 percent RTP for a control rod
sequence exchange 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) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) residual heat removal train B on January 12, 2023
(2) low pressure core spray while residual heat removal B was out of service on
January 18, 2023
(3) division 1 standby service water on March 1, 2023
(4) residual heat removal train A on March 17, 2023
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated system configurations during a complete walkdown of the
division 2 standby diesel generator system on March 29, 2023.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1) low pressure core spray pump room on January 10, 2023
(2) auxiliary building, 139-foot elevation, fire area 1A316, on January 12, 2023
(3) containment, all elevations, on January 19, 2023
(4) division 1 control room ventilation room on February 2, 2023
5
(5) switchgear rooms 1A208 and 1A207 auxiliary building, 119-foot elevation, on
February 9, 2023
(6) auxiliary building hallways, 93-foot, 103-foot, 139-foot, and 166-foot elevations, on
February 10, 2023
(7) residual heat removal A pump room on March 9, 2023
(8) division 2 standby diesel generator on March 16, 2023
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated the onsite fire brigade training and performance during an
unannounced fire brigade drill response to a simulated fire in the control building,
189-foot elevation, on January 25, 2023.
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated internal flooding mitigation protections in the auxiliary
building, 93-foot elevation, high pressure core spray, low pressure core spray, and
residual heat removal C pump rooms on January 10, 2023.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(1 Sample)
(1) The inspectors observed and evaluated licensed operator performance in the control
room during a downpower for rod sequence exchange on March 31, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1) The inspectors observed and evaluated a licensed operator training evolution in the
simulator on February 6, 2023.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components (SSCs) remain capable of performing their intended
function:
(1) work order 593088, engineered safety feature transformer 11 relay replacement on
March 27, 2023
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) work order 590923, replace two cards for the division 2 load shedder and sequencing
panel on February 9, 2023
6
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed:
(1) protected system lineup while residual heat removal B was out of service on
January 10, 2023
(2) protected system lineup while residual heat removal A was out of service on
January 20, 2023
(3) emergent work control due to reactor core isolation cooling system unavailability on
January 27, 2023
(4) maintenance risk assessment during division 2 work week on February 2, 2023
(5) risk management actions for transformer 23 underground power cable connections
on March 27, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1) condition report CR-GGN-2022-00296, potential moisture intrusion in reactor core
isolation cooling oil system on January 26, 2023
(2) condition report CR-GGN-2023-00633, reactor core isolation cooling trip throttle valve
failure to open on February 3, 2023
(3) condition report CR-GGN-2023-00721, material nonconformance for control rod drive
mechanism cap screws on February 7, 2023
(4) condition report CR-GGN-2023-00478, division 2 load shedding and sequencer
failure on February 9, 2023
(5) condition report CR-GGN-2023-00562, non-conservative moment of inertia for
recirculation pump on March 13, 2023
(6) condition report CR-GGN-2023-01532, snubber misaligned on March 14, 2023
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1) revision to Procedure EN-DC-161, "Control of Combustibles," on March 14, 2023
7
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system
operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (5 Samples)
(1) work order 590923, division 2 load shedding and sequencer panel functional test on
January 25, 2023
(2) work order 591227, failed light socket for reactor core isolation cooling trip/throttle
valve position indicating lamp on February 10, 2023
(3) work order 559947-01, disassemble and inspect actuator on March 8, 2023
(4) work order 591510, control room air-conditioner train B power supply replacement on
March 24, 2023
(5) work order 52916166, clean, inspect, and lubricate air handling equipment on
March 31, 2023
Surveillance Testing (IP Section 03.01) (3 Samples)
(1) work order 53022722, anticipated transient without scram reactor vessel high
pressure channel A on February 15, 2023
(2) work order 53022735, reactor vessel water level 3 and level 8 functional test on
March 8, 2023
(3) work order 423277, remove and inspect snubber 1E12G013R11 on March 13, 2023
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1) work order 52931269, motor operated valve periodic diagnostic test of
valve 1E51F010 on February 10, 2023
Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)
(1) work order 52995885 and 5295886, FLEX building 2 equipment testing on
February 8, 2023
71114.01 - Exercise Evaluation
Inspection Review (IP Section 02.01-02.11) (1 Partial)
(1) The inspectors evaluated the biennial emergency plan exercise conducted on
March 22, 2023. However, as of the end of the 1st Quarter 2023, the licensee had not
completed its critique process for the exercise. As such, the inspectors had not
completed the full evaluation of the exercise and the critique process. The inspectors
will complete the inspection in the 2nd Quarter, and the results of the inspection will
be documented in NRC Inspection Report 05000416/2023002.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
(1) The inspectors evaluated changes to the Emergency Action Level (EAL) Technical
Bases Document, revisions 2 and 3 (effective August 2022, and January 2023,
8
respectively). This involved review of a selection of additional licensee screening and
evaluation documentation. These evaluations and reviews do not constitute NRC
approval.
71114.08 - Exercise Evaluation - Scenario Review
Inspection Review (IP Section 02.01 - 02.04) (1 Sample)
(1) The inspectors reviewed the licensees preliminary exercise scenario that was
submitted to the NRC on January 19, 2023 (ML23019A183), for the exercise
scheduled to occur on March 22, 2023. The inspectors discussed the preliminary
scenario with Mike Lewis, Manager, Emergency Preparedness, and other members
of the emergency preparedness staff on February 15, 2023. The inspectors' review
does not constitute NRC approval of the scenario.
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated how the licensee identifies the magnitude and extent of
radiation levels and the concentrations and quantities of radioactive materials, and
how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated how the licensee instructs workers on plant-related
radiological hazards and the radiation protection requirements intended to protect
workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed and evaluated the following licensee processes for monitoring and
controlling contamination and radioactive material:
(1) observed the licensee conduct surveys of potentially contaminated packages and
equipment from the radiologically controlled area for release offsite and workers
exiting potential contaminated areas
(2) evaluated the licensee's physical and programmatic controls for the unconditional
release of non-contaminated and non-radioactive equipment from inside the
radiologically controlled area
Radiological Hazards Control and Work Coverage (IP Section 03.04) (2 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following
radiological work:
(1) high risk radiological work and job coverage for floor drain centrifugal disc filter
maintenance (RWP 2023-1070, Task 2 for work order 590804)
9
(2) high risk radiological work and job coverage to support the spent fuel pool cleanout
project (RWP 2022-1313, Task 1 for work order 583982)
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (4 Samples)
The inspectors evaluated licensee controls of the following high radiation areas and very
(1) Grand Gulf Nuclear Station turbine building, 113-foot elevation, door 1T204
(2) Grand Gulf Nuclear Station turbine building, 110-foot elevation, door 1T207
(3) Grand Gulf Nuclear Station radwaste building, 118-foot elevation, door OR208
(4) Grand Gulf Nuclear Station radwaste building, 136-foot elevation, door OR317
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP
Section 03.06) (1 Sample)
(1) The inspectors evaluated radiation worker and radiation protection technician
performance as it pertains to radiation protection requirements.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated licensee performance as it pertains to radioactive source
term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated how the licensee processes, stores, and uses external
dosimetry.
Internal Dosimetry (IP Section 03.03) (3 Samples)
The inspectors evaluated the following internal dose assessments:
(1) a potential intake that occurred on March 8, 2022, while cutting out piping
(2) a potential intake that occurred on March 19, 2022, while removing insulation from
auxiliary room steam tunnel piping
(3) a potential intake that occurred on March 24, 2022, while performing nondestructive
examination testing
Special Dosimetric Situations (IP Section 03.04) (3 Samples)
The inspectors evaluated the following special dosimetric situations:
(1) three examples of declared pregnant worker's dose assessment
(2) effective dose equivalent for external exposure (EDEx) assessments for three
workers working as divers in non-uniformed radiation fields in 2022 under
RWP 2022-1531
(3) neutron dose tracking for work near the independent spent fuel storage installation
pad
10
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (1 Sample)
(1) January 1, 2022, through December 31, 2022
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)
(1) January 1, 2022, through December 31, 2022
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
(1) January 1, 2022, through December 31, 2022
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
(1) January 1, 2022, through December 31, 2022
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual
Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample
(IP Section 02.16) (1 Sample)
(1) January 1, 2022, through December 31, 2022
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
(1) April 1, 2022, through December 31, 2022
EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13)
(1 Sample)
(1) April 1, 2022, through December 31, 2022
EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
(1) April 1, 2022, through December 31, 2022
71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02) (5 Samples)
The inspectors evaluated the following licensee event reports (LERs):
(1) LER 05000416/2021-001-00, Primary Containment Outer Airlock Door Inoperable
Due to Unacceptable Leak Rate (ML21137A090). The circumstances surrounding
this LER and a Severity Level IV non-cited violation is documented in the Inspection
Results section of this report. This LER is closed.
11
(2) LER 05000416/2021-004-00, Procedure Inadequacy Resulted in Core Monitoring
System Miscalibration and Violation of Technical Specification (ML22019A270). The
circumstances surrounding this LER and a Severity Level IV non-cited violation is
documented in the Inspection Results section of this report. This LER is closed.
(3) LER 05000416/2021-005-00, Oscillation Power Range Monitors (OPRMs) Setpoint
Error Causes Technical Specification Noncompliance (ML22033A065). The
circumstances surrounding this LER,a Severity Level IV non-cited violation, and a
licensee identified violation are documented in the Inspection Results section of this
report. This LER is closed.
(4) LER 05000416/2022-001-00, Manual Reactor Trip Due to the Loss of Balance of
Plant Transformer 23 (ML22241A113). The inspectors determined that it was not
reasonable to foresee or correct the cause discussed in the LER, therefore, no
performance deficiency was identified. The inspectors did not identify a violation of
NRC requirements. This LER is Closed.
(5) LER 05000416/2022-003-00, Manual Reactor SCRAM due to a Loss of the
Condensate and Feed Water System (ML23047A547). The circumstances
surrounding this LER and a Green finding is documented in the Inspection Results
section of this report. This LER is Closed.
INSPECTION RESULTS
Failure to Initiate a Condition Report for a Condition Adverse to Quality
Cornerstone Significance/Severity Cross-Cutting Report
Aspect Section
Mitigating Severity Level IV None 71111.05
Systems NOV 05000416/2023001-01
Open
The inspectors identified a Severity Level IV violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, for the failure to follow station
Procedure EN-LI-102, Corrective Action Program, that requires all employees and
contractors to initiate condition reports for adverse conditions. Specifically, after determining
a required fire watch was not posted, an adverse condition, a licensed operator failed
to promptly document the condition in a condition report.
Description: On September 15, 2021, a licensed operator serving as the work control
supervisor, was asked to go to the maintenance department and locate a fire watch for the
division 1 and division 2 switchgear rooms because it had been determined that a required
continuous fire watch had not been posted. The control room sent two non-licensed operators
(NLOs) to perform fire watch duties until personnel from the maintenance department could
get to the division 1 and division 2 switchgear rooms to perform the continuous fire watch
duties and relieve the NLOs.
Licensee document limiting condition for operation (LCO) 1 FTR-21-0406 indicated on the
tagout instructions that a continuous fire watch was required because, once the tagout was
hung, it disabled portions of the fire protection system. When those portions of the fire
protection system are disabled, station procedures require establishing a continuous fire
watch in that area.
Along with the work control supervisor, several control room personnel including the shift
manager, control room supervisor, and the shift technical supervisor were aware that the
continuous fire watch had not be established.
12
On December 8, 2021, the NRCs Office of Investigations (OI) initiated an investigation to
determine whether the licensees actions involved a willful violation of a regulatory
requirement. A factual summary of the investigation is contained in Enclosure 2.
As a result of the investigation, the NRC determined that a condition report had not been
initiated to document that the licensee had failed to establish a required fire watch in
accordance with station procedures until April 20, 2022, when the NRC informed the licensee
that the action had not been performed. This is based upon the following:
Procedure EN-LI-102, Corrective Action Program, revision 45, a quality-related procedure,
attachment 1, step 21 states, in part, that any condition which materially impacts the ability to
implement the fire protection program including degraded fire barriers and their
subcomponents (penetration seals, fire doors and dampers), and fire detection and
suppression systems, be screened as an adverse condition in the corrective action program.
Procedure EN-LI-102, step 5.2.4 requires, in part, that employees and contractors are
required to initiate condition reports for adverse conditions.
On April 20, 2022, the licensee documented the condition adverse to quality in the corrective
action program as condition report CR-GGN-2022-04646.
Additionally, based on the evidence obtained during the investigation, there was sufficient
information to demonstrate that a licensed operator deliberately failed to write a condition
report for not establishing a required fire watch. The licensed operator knew that no condition
report had been written by any other licensee employee, and the licensed operator knew that
the failure to write a condition report was contrary to licensee policy and NRC regulations.
Corrective Actions: Immediate corrective actions were to establish the required fire watch. No
additional corrective actions were generated after documenting the adverse condition in
condition report CR-GGN-2022-04646.
Corrective Action References: This issue was entered into the licensees corrective action
program as condition report CR-GGN-2022-04646
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Performance Assessment:
Performance Deficiency: The NRC determined that this violation was associated with a minor
performance deficiency. Licensee Procedure EN-LI-102, step 5.2.4c. requires, in part, that
employees and contractors are required to initiate condition reports for adverse conditions.
Specifically, after determining a required fire watch was not posted, an adverse condition, a
licensed operator failed to promptly document the condition in a condition report.
Cross-Cutting Aspect: None
Enforcement: The ROPs significance determination process does not specifically consider
willfulness in its assessment of licensee performance. Therefore, it is necessary to address
this violation which involves willfulness using traditional enforcement.-.
Severity: The NRC evaluated this violation in accordance with section 2.2.1.d. and
section 2.2.2 of the NRC Enforcement Policy. Because the issue involved willfulness, this
violation was determined to be Severity Level IV.
Violation: 10 CFR Part 50, appendix B, criterion V requires, in part, that activities affecting
quality shall be accomplished in accordance with documented instructions, procedures, or
drawings, of a type appropriate to the circumstances.
Procedure EN-LI-102, Corrective Action Program, revision 45, a quality-related procedure,
attachment 1, step 21 states, in part, that any condition which materially impacts the ability to
implement the fire protection program including degraded fire barriers and their
subcomponents (penetration seals, fire doors and dampers), and fire detection and
suppression systems, be screened as an adverse condition in the corrective action program.
Procedure EN-LI-102, step 5.2.4 requires, in part, that employees and contractors are
required to initiate condition reports for adverse conditions.
Contrary to the above, from September 15, 2021, to April 20, 2022, licensed personnel failed
to initiate a condition report for adverse conditions. Specifically, a licensed operator
deliberately failed to write a condition report for a condition which materially impacted the
ability to implement the fire protection program when a continuous fire watch was not
established.
Enforcement Action: This violation is being cited because the violation was willful.
Failure to Control Transient Combustibles in the Auxiliary Building
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.1] - 71111.18
Systems NCV 05000416/2023001-02 Resources
Open/Closed
The inspectors identified four examples of a Green finding and non-cited violation of License
Condition 2.C(41), Fire Protection Program, for the licensees failure to implement all
provisions of the approved fire protection program described in the NRC Safety Evaluation
dated September 29, 2006, related to License Amendment 170 to operating license NPF-29.
Specifically, the licensee failed to store transient combustible materials in the auxiliary
14
building as required by the Safety Evaluation (SE).
Description: On February 9th, 2023, the inspectors toured the auxiliary building 93-foot,
103-foot, 119-foot, 139-foot, and 166-foot elevations including several risk significant fire
areas and combustible material exclusion zones as described in the SE dated
September 29, 2006. Section 4.2.2.1.8 of the SE states, in part, that combustible storage
areas are designated locations where transient combustible materials may be stored or
staged, and that outside these designated storage areas transient combustibles may only be
stored in sealed metal drums. Section 3.1.5 of the SE prohibits storing combustible materials
on the 93-foot elevation. The inspectors observed the following examples of combustible
materials that were not stored in accordance with these sections of the SE:
(Example 1) A combustible material storage permit issued on the 93-foot elevation per
procedure EN-DC-161 for rubber hose contrary to section 3.1.5. The combustible
material was also not stored in a sealed metal drum contrary to section 4.2.2.1.8. In
addition, the combustible material storage permit had expired 9 days prior to the
observation on January 31, 2023.
(Example 2) Also stored on the 93-foot elevation not in a sealed metal container were
several fiberglass ladders, rubber hoses, and rolls of plastic pearl weave used for
netting in a scaffolding storage area contrary to both sections 3.1.5 and 4.2.2.1.8.
(Example 3) On the 139-foot elevation, miscellaneous transient combustibles such as
a cart with a wooden deck, a rubber hose, a dust mop, and plastic wet floor signs
were found near door 1A310 in a safe storage area contrary to section 4.2.2.1.8. Safe
storage areas are not designated combustible material storage areas per plant
maintenance standard MS53. These items were not in a transient combustible
material storage area, and they were not stored in sealed metal drums.
(Example 4) Additionally, sections 3.1 through 3.4 of the SE include restrictions to limit
the size and location of combustible storage areas in the auxiliary building; however,
the licensees transient combustible permit program did not track or otherwise restrict
the size of combustible storage areas in the auxiliary building to remain in
conformance with the SE.
The inspectors reported the transient combustible material to the licensee who determined
that the transient combustibles were not controlled as described in the SE. The inspectors
determined that the procedure used to control transient combustibles, Procedure EN-DC-161,
Control of Combustibles, revision 25, did not capture the specific requirements as detailed
in the SE. Specifically, none of the examples identified above were inconsistent with
procedure EN-DC-161, but all four were inconsistent with the SE.
Because the licensee was unable to produce any evaluations which approved these
deviations, the inspectors concluded that procedure EN-DC-161 was not appropriately
controlling transient combustibles in accordance with the applicable license condition.
Corrective Actions: The licensee entered this issue into their corrective action program to
review the discrepancies and revise the procedure as appropriate.
Corrective Action References: This issue was entered into the licensees corrective action
program as condition reports CR-GGN-2023-00933 and CR-GGN-2023-01003
Performance Assessment:
Performance Deficiency: The licensees failure to implement procedures for the control
15
of combustible materials in the auxiliary building in accordance with the SE dated
September 29, 2006, was a performance deficiency.
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 uncontrolled
combustible materials in multiple locations in the auxiliary building containing safe shutdown
components for both division 1 and division 2.
Significance: The inspectors assessed the significance of the finding using IMC 0609,
Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Because the finding involved the ability to confine a fire, the inspectors applied IMC 0609,
Appendix F, Fire Protection SDP, to determine the findings significance. The inspectors
determined that there were adequate fire suppression and detection systems in the auxiliary
building, and therefore, they concluded that the performance deficiency was of very low
safety significance (Green).
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment,
procedures, and other resources are available and adequate to support nuclear safety.
Enforcement:
Violation: License Condition 2.C(41), Fire Protection Program, states, in part, that the plant
shall implement and maintain in effect all provisions of the Fire Protection Program as
described in the Updated Final Safety Analysis Report (UFSAR), and as approved in the
Safety Evaluation dated September 29, 2006. The safety evaluation dated
September 29, 2006, states, in part, that transient combustibles may only be stored in sealed
metal containers outside designated combustible storage areas. Section 3.1.5 of the safety
evaluation dated September 29, 2006, prohibits combustible material storage areas on the
93-foot elevation of the auxiliary building. Section 4.2.2.1.8 of the safety evaluation dated
September 29, 2006, states, in part, that processes and procedures are in place at Grand
Gulf Nuclear Station to address the control of combustible loading throughout the plant.
Contrary to the above, on February 9, 2023, the licensee failed to implement and maintain in
effect all provisions of the Fire Protection Program as described in the Updated Final Safety
Analysis Report, and as approved in the Safety Evaluation dated September 29, 2006, as
evidenced by the following four examples:
(Example 1): A combustible material storage permit was issued on the 93-foot
elevation per procedure EN-DC-161 for rubber hose contrary to section 3.1.5. The
combustible material was also not stored in a sealed metal drum contrary to
section 4.2.2.1.8. In addition, the combustible material storage permit had expired
9 days prior to the observation on January 31, 2023.
(Example 2): Several fiberglass ladders, rubber hoses, and rolls of plastic pearl weave
used for netting in a scaffolding storage area were stored on the 93-foot elevation and
not in a sealed metal drum contrary to both sections 3.1.5 and 4.2.2.1.8.
(Example 3): On the 139-foot elevation, miscellaneous transient combustibles such as
a cart with a wooden deck, a rubber hose, a dust mop, and plastic wet floor signs
were found near door 1A310 in a safe storage area contrary to section 4.2.2.1.8. Safe
storage areas are not designated combustible material storage areas per plant
16
maintenance standard MS53. These items were not in a transient combustible
material storage area, and they were not stored in sealed metal drums.
(Example 4) Sections 3.1 through 3.4 of the SE include restrictions to limit the size
and location of combustible storage areas in the auxiliary building; however, the
licensees transient combustible permit program did not track or otherwise restrict the
size of combustible storage areas in the auxiliary building to remain in conformance
with the SE.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
section 2.3.2 of the Enforcement Policy.
Licensee-Identified Non-Cited Violation 71111.24
This violation of very low safety significance was identified by the licensee, has been entered
into the licensee corrective action program, and is being treated as a non-cited violation
consistent with Section 2.3.2 of the Enforcement Policy.
Violation: License Condition 2.C(41), Fire Protection Program, states, in part, that the plant
shall implement and maintain in effect all provisions of the fire protection program as
described in the UFSAR. UFSAR, section 9B.6, requires, in part, that the licensee govern the
operability requirements, required actions, and surveillance requirements specified in
Technical Requirements Manual, section 6.2. Technical Requirements Manual,
section 6.2.4.1, required that a continuous fire watch be established within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the
carbon dioxide system protecting the division 1, 2, or 3 switchgear rooms being declared
non-functional.
Contrary to the above, from 11:17 a.m. on September 14, 2021, until September 15, 2021,
the licensee failed to establish a continuous fire watch when the carbon dioxide system
protecting the division 1, 2, or 3 switchgear rooms was declared non-functional.
Significance/Severity: The inspectors assessed the significance of the finding using
Appendix F, Fire Protection Significance Determination Process. The finding represented a
high degradation of a fixed fire protection system. A regional senior reactor analyst performed
a Phase 2 screening using a bounding risk quantification which determined an increase in
core damage frequency of 4.4E-7/year, representing very low safety significance (Green).
The finding has very low safety significance (Green) because of the short time there was not
a fire watch and the low probability of a fire during that time.
Corrective Action References: This issue was entered into the licensees corrective action
program as condition report CR-GGN-2022-04646
Failure to Adequately Verify Design Change
Cornerstone Significance Cross-Cutting Report
Aspect Section
Initiating Events Green None 71153
Open/Closed
A self-revealed Green finding was identified for the licensees failure to perform appropriate
design verifications of an engineering change associated with the feedwater heater level
control valves. As a result, the system response of a condensate booster pump trip was not
adequately analyzed which contributed to a loss of feedwater event and plant scram when a
condensate booster pump tripped on December 19, 2022. This event was reported as
17
Licensee Event Report 05000416/2022-003-00.
Description: On December 19, 2022, with the plant operating at 100 percent power, an
electrical fault with the A condensate booster pump occurred which caused the pump to trip.
This trip caused an initial reduction in reactor water level because of an approximate
22 percent loss in total flow to the reactor feedwater pumps. In accordance with the reactor
feedwater malfunction offnormal event procedure 05-1-02-V-7, operators reduced reactor
recirculation flow to 70 Mlbm/hr using the fast detent option. This rapid reduction in
recirculation flow exacerbated the perturbation on the feedwater system and ultimately led to
the feedwater heater drain tank (HDT) level control valves closing to maintain level in the
HDT. However, the combination of a load reduction and the HDT level control valves closing
caused level in HDT to increase which created level oscillations that the HDT level control
valves were not able to recover from.
The response of the HDT level control valves caused a reduction in the flow from the HDT to
the reactor feedwater pumps because the valves were not sized appropriately to respond to a
loss of condensate booster pump. The valves responded too slowly to the transient to
maintain adequate suction pressure to the feedwater pumps which ultimately resulted in a trip
of the A reactor feedwater pump. Further complications in the feedwater system resulted in
continued lowering of feedwater flow to the reactor and a continuing lowering of reactor water
level. Prior to reaching the setpoint for an automatic scram, operators manually inserted a
scram and recovered from the transient without incident.
The licensee performed a root cause analysis of the cause of the feedwater transient and
determined that an inadequate engineering change performed in the 2011/2012 timeframe
was the root cause. Engineering change (EC) 23022 modified the HDT level control valves by
replacing the existing 8-inch valves with 12-inch valves. The inspectors reviewed the design
verification for this modification and determined that the licensee failed to identify that this
modification could affect the design, performance, or operation of the main feedwater pumps
and failed to identify valve stroke time as a critical parameter to the HDT level control valve
performance. Additionally, the licensee determined that the use of the fast detent reduction in
reactor recirculation flow in procedure 05-1-02-V-7 was not evaluated in design calculations
that evaluated HDT response to condensate booster pump transients. Performing such an
evaluation in conjunction with more thorough design verifications in EC 23022 likely would
have identified the design deficiency with the replacement HDT level control valves. The
inspectors concluded that this was not a procedure deficiency with procedure 05-1-02-V-7,
but rather another example of the inadequate modification to the HDT level control valves.
Licensee Procedure EN-DC-115, Engineering Change Process, revision 10, step 4.2,
required the design verifier to perform a thorough review of all information contained in the
engineering change to ensure that the document is technically adequate, procedurally
compliant, accurate, and of a quality to warrant approval and issuance. The mechanical
design engineering input for EC 23022 contained various screening criteria, one of which was
Affect the design, performance, or operation of pumps. Another screening criteria was
Affect hydraulic requirements such as pump net positive suction head, allowable pressure
drops, system curves, etc. Neither of these criteria were marked as being impacted. The
inspectors determined that, based on the demonstrable effects of the valve operation from
the condensate booster pump trip, the HDP level control valve modification affected both
criteria and was required to be evaluated by procedure EN-DC-115, but was not evaluated.
The licensee reported this event as Licensee Event Report 05000416/2022-003-00 on
18
February 16, 2023.
Corrective Actions: Licensee corrective actions included replacing the failed condensate
booster pump motor, implementing risk management actions to reduce the potential for
another condensate booster pump transient, and evaluating long term corrective actions
including modifications to the system.
Corrective Action References: This issue was entered into the licensees corrective action
program as condition report CR-GGN-2022-11392.
Performance Assessment:
Performance Deficiency: The failure to perform a thorough review of all information contained
in the engineering change to ensure that the document was technically adequate,
procedurally compliant, accurate, and of a quality to warrant approval and issuance was
contrary to licensee procedure EN-DC-115 and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Design Control attribute of the Initiating Events
cornerstone and adversely affected the cornerstone objective to limit the likelihood of events
that upset plant stability and challenge critical safety functions during shutdown as well as
power operations. Specifically, the performance deficiency caused a reactor scram.
Significance: The inspectors assessed the significance of the finding using IMC 0609,
Appendix A, The SDP for Findings At-Power, exhibit 1. Because operators were able to
recover feedwater, the inspectors determined that the finding did not cause the loss of
mitigation equipment relied upon to transition the plant from the onset of the trip to a stable
shutdown condition. Consequently, the inspectors answered no to the transient initiators
screening question and the finding screened to a Green significance.
Cross-Cutting Aspect: None. Because the finding was the result of deficiencies that occurred
approximately 11 years prior to the event, a cross-cutting aspect is not applicable.
Enforcement: Inspectors did not identify a violation of regulatory requirements associated with
this finding.
Failure to Submit a Licensee Event Report Within 60 Days
Cornerstone Severity Cross-Cutting Report
Aspect Section
Not Severity Level IV Not 71153
Applicable NCV 05000416/2023001-04 Applicable
Open/Closed
The inspectors identified two examples of a Severity Level IV non-cited violation of
10 CFR 50.73(a), Licensee Event Report System, for the licensees failure to submit two
licensee event reports within 60 days after discovery of the event. Specifically, the licensee
determined on November 4, 2021, that an issue associated with jet pump summer
miscalibration resulted in multiple cases of operation in a condition prohibited by technical specification 3.2.2 and the licensee event report was submitted 76 days later, on
January 19, 2022. Additionally, the licensee determined on December 2, 2021, that an issue
associated with oscillation power range monitors was a reportable event and the licensee
event report was submitted 62 days later on February 2, 2022.
Description: First Example: Licensee Event Report (LER) 2021-004-00
19
As described in Inspection Report 05000416/2021003 (ML21312A172), the inspectors
identified a non-cited violation related to the licensees failure to identify a condition adverse
to quality associated with the jet pump flow indications. As a result, the licensee entered the
issue into the corrective action program as condition report CR-GGN-2021-05802. As part of
its evaluation, the licensee performed a past operability evaluation and ultimately reported the
issue as LER 2021-004-00, Procedure Inadequacy Resulted in Core Monitoring System
Miscalibration and Violation of Technical Specifications, (ML22019A270) on
January 19, 2022.
On November 4, 2021, the licensee concluded in the past operability evaluation that there
were 1677 instances in the past 3 years where the plant was operating in a condition
prohibited by technical specification (TS) LCO 3.2.2. LCO 3.2.2 required that all minimum
critical power ratios (MCPR) shall be greater than or equal to the MCPR operating limits
specified in the core operating limit report. Condition A of this LCO required that for any
MCPR not within limits to restore MCPR(s) to within limits within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Condition B
required that if the required action of condition A was not met to reduce thermal power to less
than 21.8 percent RTP. For the 1677 cases identified, the licensee determined that MCPR
was not within limits for greater than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> while reactor power was greater than
21.8 percent RTP.
On November 8, 2021, the licensee initiated a corrective action to condition report
CR-GGN-2021-05802 to revise the past operability evaluation to update the core monitoring
cases used in the thermal limit evaluation to exclude those ran during a transient and
re-evaluate the results. The licensee concluded the revised evaluation on November 18,
2021, and eliminated two of the 1677 cases. In discussions with engineering, the inspectors
learned that the purpose of the revised evaluation was only to determine the correct number
of cases where the TSs were violated. Engineering never had any doubt that the fundamental
conclusion that the TSs were violated would not change because the vast majority of the
already identified cases were during steady state operations and would not have been
affected by the revision.
Because the revised evaluation essentially confirmed the results of the original evaluation
and only sought to finalize the most accurate number of cases where the TSs were violated,
the inspectors concluded that the engineers who performed, checked, and approved the past
operability evaluation discovered the reportable condition on November 4, 2021. On
November 23, 2021, the licensee concluded that the identified condition prohibited by
TS 3.2.2 was a reportable condition. The licensee set a due date to submit the LER within
60 days of their determining that the condition was reportable rather than 60 days from the
date that the reportable condition was identified. Consequently, LER 2021-004-00 was
submitted 76 days after the condition was identified (November 4, 2021).
Licensee Procedure EN-LI-108, Event Notification and Reporting, revision 19, defines time
of discovery as the moment a condition is identified by anyone working at or for the facility.
This applies when dealing with Reportability. In the LER, the licensee stated that, On
November 18, 2021, a past operability evaluation determined that an issue associated with
the jet pump summer miscalibration was a reportable event. The inspectors determined that
because the licensee originally discovered the reportable condition on November 4, 2021,
and at no point during the revision process did the licensee ever have a reasonable belief that
the conclusion that the plant operated in a condition prohibited by TSs would change.
The inspectors reviewed the applicable TS, the licensees documents related to the discovery
20
such as the past operability evaluation and condition report CR-GGN-2021-05802, and the
circumstances surrounding the discovery of the failure to meet TS 3.2.2, and determined that:
TS 3.2.2 was not administrative in nature;
the event was not a case of a late surveillance test where the oversight was corrected,
the test was performed, and the equipment was found to be capable of performing its
specified safety functions; and
TS 3.2.2 was not revised prior to discovery of the event such that the operation or
condition was no longer prohibited at the time of discovery of the event.
The inspectors concluded that the underlying misunderstanding of what the date of discovery
is for past operability evaluations directly led to the failure to report the event within 60 days
as required by 10 CFR 50.73.
Second Example: LER 2021-005-00
As documented in this inspection report, the licensee identified on June 21, 2021, that they
failed to update the detect and suppress solution - confirmation density settings for the
oscillation power range monitors. In consultation with the vendor, the licensee performed a
past operability evaluation as documented in condition report CR-GGN-2021-04781. On
December 2, 2021, the licensee finished the past operability evaluation and determined that
the failure to update this setting resulted in operation in a condition prohibited by TSs.
On December 6, 2021, the licensee reviewed the past operability evaluation and concluded
that the condition was reportable as an LER due to violating TS 3.3.1.1. Similar to
LER 2021-004-00, the licensee assigned a due date to submit the LER within 60 days of their
determining that the condition was reportable rather than 60 days from the date that the
reportable condition was identified. On February 2, 2022, the licensee submitted
LER 2021-005-00, Oscillation Power Range Monitors Technical Specification
Noncompliance. The inspectors concluded that this LER was submitted 62 days after the
condition was identified on December 2, 2021.
The inspectors reviewed the applicable TS, the licensees documents related to the discovery
such as the past operability evaluation and condition report CR-GGN-2021-04781, and the
circumstances surrounding the discovery of the failure to meet TS 3.3.1.1, and determined
that:
TS 3.3.1.1 was not administrative in nature;
the event was not a case of a late surveillance test where the oversight was corrected,
the test was performed, and the equipment was found to be capable of performing its
specified safety functions; and
TS 3.3.1.1 was not revised prior to discovery of the event such that the operation or
condition was no longer prohibited at the time of discovery of the event.
During discussions with licensee management about these issues the inspectors determined
that the licensee had a misunderstanding of what the correct time of discovery was for
conditions such as these where a past operability evaluation had determined that a violation
of Technical Specifications had occurred. Licensee management believed that the time of
discovery for reporting timelines started when regulatory affairs determined that the issue was
reportable - not when the past operability evaluation concluded that the plant had operated in
a condition prohibited by Technical Specifications. The inspectors determined that the
21
licensees understanding was contrary to both licensee procedure EN-LI-108 and 10 CFR 50.73(a)(1), and that this misunderstanding would likely have continued without NRC
interaction.
The inspectors did not identify any additional violations as a result of these LER reviews. Both
LERs are closed.
Corrective Actions: The licensee entered the late reporting concern into the corrective action
program to correct the causes that led to the late reports.
Corrective Action References: This issue was entered into the licensees corrective action
program as condition report CR-GGN-2023-00700
Performance Assessment: The inspectors determined this violation was associated with a
minor performance deficiency. Specifically, the licensee failed to timely submit two LERs,
contrary to licensee procedure EN-LI-108. This performance deficiency was minor because
the inspectors answered No to all three screening questions in appendix B of IMC 0612.
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 using traditional enforcement .
Severity: The NRC determined this violation was Severity Level IV in accordance with
example 6.9.d.9 of the NRC Enforcement Policy because the licensee failed to submit an
LER in accordance with 10 CFR 50.73.
Violation: Title 10 CFR 50.73(a)(1) requires, in part, that a licensee shall submit an LER for
any event of the type described in this paragraph within 60 days after the discovery of the
event.
Title 10 CFR 50.73(a)(2) requires, in part, that the licensee shall report any operation or
condition which was prohibited by the plants TSs except as allowed by
10 CFR 50.73(a)(2)(i)(B)(1), 10 CFR 50.73(a)(2)(i)(B)(2), or 10 CFR 50.73(a)(2)(i)(B)(3).
Contrary to the above:
1. On January 4, 2022, the licensee failed to submit LER 2021-004-00 for a condition
which was prohibited by the plants TSs within 60 days after the discovery of the event
and the condition was not an exception as allowed by either
10 CFR 50.73(a)(2)(i)(B)(1), 10 CFR 50.73(a)(2)(i)(B)(2), or
2. On February 1, 2022, the licensee failed to submit LER 2021-005-00 for a condition
which was prohibited by the plants TSs within 60 days after the discovery of the event
and the condition was not an exception as allowed by either
10 CFR 50.73(a)(2)(i)(B)(1), 10 CFR 50.73(a)(2)(i)(B)(2), or
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
section 2.3.2 of the Enforcement Policy.
22
Failure to Evaluate a Deviation for 10 CFR Part 21 (Part 21) Applicability
Cornerstone Severity Cross-Cutting Report
Aspect Section
Not Severity Level IV Not 71153
Applicable NCV 05000416/2023001-05 Applicable
Open/Closed
The inspectors identified a Severity Level IV non-cited violation of 10 CFR 21.21(a)(1) for the
licensees failure to evaluate a deviation in a basic component within 60 days of discovery. As
a result, the licensee failed to evaluate a deviation identified on April 21, 2021, that was
associated with a reportable defect that could have created a substantial safety hazard were
it to have remained uncorrected within 60 days of discovery. The licensee completed the
evaluation on August 3, 2022, and determined that the deviation was associated with a
substantial safety hazard and was required to be reported under Part 21.
Description: On February 22, 2021, during a local leak rate test for the 208-foot containment
personnel airlock outer door under work order (WO) 52884887-11, the as-found leak test
exceeded TS surveillance requirement 3.6.1.2.1 limit of 16,880 SCCM. Because the licensee
was not able to stabilize at test pressure due to the capability of the test equipment, an exact
leakage rate could not be obtained. The equalizing valve on the outer door 1M23F018D was
identified to be leaking and was replaced under WO 558041-01. The issue was entered into
the corrective action program as condition report CR-GGN-2021-01451.
After replacing the equalizing valve on the outer door, the licensee discovered that the
equalizing valve on the inner door 1M23F018C was also leaking. The reported leak rate of
9000 SCCM was above the Appendix J administrative limit of 944 SCCM. Inner
door 1M23F018C was rebuilt with new O-rings and was lubricated prior to reinstallation into
the airlock. Following door 1M23F018D replacement and door 1M23F018C rebuild, the local
leak rate test tested with satisfactory results.
On April 21, 2021, the licensee determined that the cause of excessive leakage for both
doors 1M23F018C and D was the failure to lubricate the valves prior to installation which
caused premature O-ring failure. Additionally, with the inner door opened, the leakage rate
would have exceeded TS requirements. Consequently, the licensee submitted
LER 05000416/2021-001-00 on May 14, 2021.
The valves were purchased on February 7, 2018, as basic components under purchase
order 10537921. The procurement documents required the valves to be furnished in
accordance with the vendors commercial grade dedication plan CGI-013. This dedication
plan required the vendor to disassemble the valves, replace the O-rings with dedicated
O-rings, lubricate the stem and O-rings, reassemble the valves, and perform final acceptance
testing before shipping the valves as basic components. However, the licensee determined
that neither valve was lubricated when they were installed and developed corrective actions
to revise the preventive maintenance instructions to ensure replacement valves are lubricated
prior to installation.
The inspectors determined that the licensee did not recognize that a deviation or failure to
comply potentially associated with a substantial safety hazard existed, and therefore, did not
evaluate the lack of lubrication as such. Licensee Procedure EN-LI-108-01, 10 CFR 21
Evaluations and Reporting, revision 13, required the issue to be screened for Part 21
reportability.
23
The licensee entered the inspectors concerns into their corrective action program, performed
an evaluation, determined that the issue was a reportable Part 21 event on August 3, 2022,
and made the initial notification on October 31, 2022.
The inspectors determined that the pertinent reporting criteria as required by
10 CFR 21.21(d)(4) was not provided in LER 05000416/2021-001-00, and therefore, the
licensee did not meet the reporting requirement exclusion as provided by 10 CFR 21.21(d)(2).
Specifically, the licensee failed to provide the following information in their LER describing the
valve failure:
identification of the basic component which failed to comply or contained a defect
identification of the firm supplying the basic component which failed to comply or
contained a defect
nature of the defect or failure to comply and the safety hazard which was created or
could be created by such defect or failure to comply
the date on which the information of such defect or failure to comply was obtained
any advice related to the defect or failure to comply about the basic component that
has been, is being, or will be given to purchasers or licensees
The inspectors reviewed the receipt inspection, certificate of conformance, and other
procurement documents and determined that the cause of the valve failure to meet TS
surveillance requirement 3.6.1.2.1 was not reasonably foreseeable by the licensee; therefore,
no performance deficiency related to the TS violation was identified. Additionally, traditional
enforcement related to the TS violation does not apply. This LER is closed.
Corrective Actions: The licensee reported the equalizing valve failure as a Part 21 notification
on October 31, 2022, and provided training on Part 21 requirements to applicable staff.
Corrective Action References: This issue was entered into the licensees corrective action
program as condition reports CR-GGN-2022-07146 and CR-GGN-2022-09773.
Performance Assessment: The inspectors determined this violation was associated with a
minor performance deficiency. Specifically, the failure to evaluate a deviation in a basic
component for 10 CFR Part 21 reportability was contrary to licensee procedure EN-LI-108-01
and was a performance deficiency. This performance deficiency was minor because the
inspectors answered No to all three screening questions in appendix B of IMC 0612. No
performance deficiency was identified for the failure to meet TS surveillance
requirement 3.6.1.2.1.
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 using traditional enforcement.
Severity: The NRC determined that this violation initially screens as Severity Level III in
accordance with section 6.9.c.5 of the NRC Enforcement Policy. However, in reviewing the
specific circumstances of this violation (i.e., the NRC resident staff was aware of the issue,
and there was little to no impact to the inspection process/regulatory process; the impact to
overall containment leakage is mitigated by the size of the valves; your staff entered the issue
into the corrective action program and issued a licensee event report after they concluded it
was reportable under 10 CFR 50.73; and the valves were only supplied to the Grand Gulf
Nuclear Station and no other licensees) the NRC determined that it is more appropriately
24
categorized as a Severity Level IV violation.
Title 10 CFR 21.21(a)(1) requires, in part, that entities subject to the regulations in
10 CFR Part 21 shall evaluate deviations and failures to comply to identify defects associated
with substantial safety hazards as soon as practicable and, except as provided in
10 CFR 21.21(a)(2), in all cases within 60 days of discovery, in order to identify a reportable
defect that could create a substantial safety hazard, were it to remain uncorrected.
Contrary to the above, from June 21, 2021, to August 3, 2022, the licensee failed to evaluate
deviations and failures to comply to identify defects associated with substantial safety
hazards as soon as practicable and in all cases within 60 days of discovery, in order to
identify a reportable defect that could create a substantial safety hazard, were it to remain
uncorrected. Specifically, on April 21, 2021, the licensee identified that the lack of lubrication
on the containment personnel airlock equalizing valves caused the excessive leakage and
failed to identify, within 60 days, that it as a substantial safety hazard. The licensee evaluated
the condition as a substantial safety hazard on August 3, 2022.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
section 2.3.2 of the Enforcement Policy.
Failure to Make a Timely Part 21 Report
Cornerstone Severity Cross-Cutting Report
Aspect Section
Not Severity Level IV Not 71153
Applicable NOV 05000416/2023001-06 Applicable
Open
The inspectors identified a Severity Level IV violation of 10 CFR 21.21(a)(3) and
10 CFR 21.21(d) for the licensees failure to make a Part 21 report within the required time
limits specified in Part 21. Specifically, the licensee notified the responsible officer 55 working
days after making the determination that a substantial safety hazard existed (50 working days
late) and the report was made 3 calendar days after the responsible officer was notified
(1 day late).
Description: On August 3, 2022, the licensee completed an evaluation of the deviation
identified with door 1M23F018C and D, as discussed previously in this inspection report, and
determined that the reportable defect could create a substantial safety hazard were it to
remain uncorrected.
On October 6, 2022, the inspectors questioned the licensee on the Part 21 report because it
had not yet been made, and the inspectors discussed with the licensee the reporting
timelines contained in 10 CFR Part 21(a)(3) and 10 CFR Part 21(d)(3). The inspectors
determined that the licensees procedure for performing Part 21 reviews,
procedure EN-LI-108-01, revision 14, contained reporting time requirements that were
consistent with these two requirements. The inspectors were concerned that a Part 21
notification had not been made despite the site having determined several weeks prior that a
reportable defect existed.
On October 14, 2022, the licensee wrote condition report CR-GGN-2022-09773 to document
that the station concluded that a Part 21 notification was necessary but had not performed the
follow-up steps in the proper timeframe. The licensee informed the site vice president on
25
October 28, 2022, and made the initial Part 21 notification of a reportable defect on
October 31, 2022.
Corrective Actions: The licensee reported the equalizing valve failure as a Part 21 notification
on October 31, 2022, and provided training on Part 21 requirements to applicable staff.
Corrective Action References: This issue was entered into the licensees corrective action
program as condition reports CR-GGN-2022-09773 and CR-GGN-2022-10127.
Performance Assessment: The inspectors determined this violation was associated with a
minor performance deficiency. Specifically, the failure to make a timely Part 21 report was
contrary to licensee procedure EN-LI-108-01 and was a performance deficiency. This
performance deficiency was minor because the inspectors answered No to all three
screening questions in appendix B of IMC 0612.
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 using traditional enforcement.
Severity: The NRC determined this violation was Severity Level IV in accordance with
example 6.9.d.13 of the NRC Enforcement Policy because the licensee failed to implement
adequate 10 CFR Part 21 processes or procedures. Specifically, the licensee failed to
ensure that adequate process controls were in place to ensure that the required timelines
associated with the discovery of a defect associated with a substantial safety hazard were
met.
Title 10 CFR 21.21(a)(3) requires, in part, that entities subject to the regulations in
10 CFR Part 21 shall ensure that a director or responsible officer is informed as soon as
practicable, and, in all cases, within the 5 working days after completion of the evaluation
described in 10 CFR 21.21(a)(1).
Title 10 CFR 21.21(d) requires, in part, that a director or responsible officer must notify the
Commission when he or she obtains information reasonably indicating a failure to comply or a
defect within two days following receipt of the information.
Contrary to the above, from August 13, 2022, to October 31, 2022, the licensee failed to
notify the Commission after the discovery of a defect associated with a substantial safety
hazard evaluation described in 10 CFR 21.21(a)(1). Specifically, the licensee identified that
the lack of lubrication on the containment personnel airlock equalizing valves caused the
excessive leakage and evaluated the condition as a substantial safety hazard on August 3,
2022, but failed to make the timeliness requirements to notify the Commission.
Enforcement Action: This violation is being cited because the licensee failed to restore
compliance within a reasonable period of time after the violation was identified consistent with
section 2.3.2 of the Enforcement Policy.
Licensee-Identified Non-Cited Violation 71153
This violation of very low safety significance was identified by the licensee and has been
entered into the licensee corrective action program and is being treated as a non-cited
violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: The licensee identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI,
Corrective Action, when they identified the failure to adequately update the oscillation power
26
range monitor (OPRM) settings in both 2016 and 2019 which ultimately led to a reportable
event.
Title 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that
conditions adverse to quality shall be promptly identified and corrected.
Contrary to the above, from June 23, 2018, until June 23, 2021, the licensee failed to
promptly identify and correct a condition adverse to quality. Specifically, with the OPRM
DSS-CD Tmax set to 3.5 seconds, the ability of the OPRMs to perform their intended safety
function was impacted until the setting was changed to 4.0 seconds on June 23, 2021. This
failure directly led to the failure to meet TS 3.3.1.1 for the affected function and the
subsequent TS noncompliance. Therefore, a separate TS 3.3.1.1 violation is not warranted.
This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the
Enforcement Policy. As discussed in this inspection report, one additional violation for the
failure to make a timely report was identified as a result of this LER review. This LER is
closed.
Significance/Severity: The inspectors assessed the significance of the finding using
Appendix A, The Significance Determination Process (SDP) for Findings At-Power, exhibit 2
- Mitigating Systems Screening Questions. The finding screened to Green because it only
affected the OPRM RPS trip signal and did not affect the function of other redundant trips or
diverse methods of reactor shutdown.
Corrective Action References: This issue was entered into the licensees corrective action
program as condition reports CR-GGN-2021-04781 and CR-GGN-2021-06434
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On February 15, 2023, the inspectors presented the emergency preparedness exercise
scenario review inspection results to Mike Lewis, Manager, Emergency Preparedness
and other members of the licensee staff.
On March 2, 2023, the inspectors presented the occupational radiation safety inspection
results to Jason Richardson, Acting General Manager of Plant Operations, and other
members of the licensee staff.
On April 6, 2023, the inspectors presented the integrated inspection results to Brad
Kapellas, Site Vice President, and other members of the licensee staff.
On April 11, 2023, the inspectors presented the emergency preparedness performance
indicator verification and emergency plan change review inspection results to Brad
Kapellas, Site Vice President, and other members of the licensee staff.
27
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.04 Corrective Action CR-GGN- 2021-03871, 2022-01616, 2022-01772, 2022-05220, 2022-
Documents 10380, 2022-10931, 2023-00582, 2023-01532
71111.04 Procedures 04-1-01-P75-1 Standby Diesel Generator System 118
71111.04 Procedures 06-ME-1000-V-0001 Snubber Visual Inspection 108
71111.04 Work Orders WO 423277
71111.05 Corrective Action CR-GGN- 2023-00520
Documents
71111.05 Procedures 06-OP-SP64-R-0049 Fire Rated Sealed Penetrations Visual Inspection 113
71111.05 Procedures EN-DC-161 Control of Combustibles 25
71111.05 Procedures GGNS-MS-53 Control of Transient Combustible Material Exclusion and 1
Storage Areas
71111.12 Miscellaneous Receipt Inspection for PO 009900002
71111.12 Miscellaneous 009900002 Purchase Order
71111.12 Work Orders WO 590923, 593088
71111.13 Corrective Action CR-GGN- 2023-00633, 2023-00634, 2023-00636, 2023-00637, 2023-
Documents 00639, 2023-00640
71111.15 Calculations MC-Q1B33-92005
71111.15 Corrective Action CR-GGN- 2023-00478, 2023-00484, 2023-00562, 2023-00582, 2023-
Documents 00633, 2023-00721, 2023-01532
71111.15 Drawings Q1E12G03R11 Pipe Support Drawing 1
71111.15 Miscellaneous GGNS-NE-12-00025 Engineering Report
71111.18 Miscellaneous PR-PRHQN-2021-
00383
71111.18 Procedures EN-DC-161 Control of Combustibles 24, 25
71111.24 Corrective Action CR-GGN- 2021-01355, 2022-00634, 2022-00636, 2022-00637, 2022-
Documents 04646, 2023-00582, 2023-00633, 2023-00892
71111.24 Miscellaneous FTR-21-0406
71111.24 Work Orders WO 423277, 559947-01, 590923, 591227, 591510, 52916166,
52931269, 53022735
71114.01 Corrective Action CR-GGN- 2021-02198, 2022-02299, 2022-06688, 2022-06763, 2022-
Documents 06842, 2022-08537, 2022-08538, 2023-00218, 2023-01253,
2023-01264, 2023-01270
28
Inspection Type Designation Description or Title Revision or
Procedure Date
71114.01 Miscellaneous 2/22/2023 Dress Rehearsal Report 03/21/2023
71114.01 Procedures 10-S-01-12 Radiological Assessment and Protective Action 50
Recommendations
71114.01 Procedures 10-S-01-14 Emergency Radiological Monitoring 26
71114.01 Procedures 10-S-01-17 Emergency Personnel Exposure Control 19
71114.01 Procedures 10-S-01-34 Joint Information Center (JIC) Operations 23
71114.01 Procedures 10-S-01-6 Notification of Offsite Agencies and Plant On-Call 58
Emergency Personnel
71114.01 Procedures EN-EP-313 Offsite Dose Assessment using the Unified RASCAL 4
Interface
71114.01 Procedures EN-EP-609 Emergency Operations Facility (EOF) Operations 6
71114.01 Procedures EN-EP-801 Emergency Response Organization 18
71114.04 Miscellaneous 10 CFR 50.54(q)(3) Facility: GGNS, Title: GGNS EAL Technical Bases and 08/15/2022
Evaluation, Charts
Procedure/Document
Number: EAL
Technical Bases and
Charts, Revision: 2
71114.04 Miscellaneous 10 CFR 50.54(q)(3) Facility: GGNS, Title: GGNS EAL Technical Bases and 08/15/2022
Screening, Charts
Procedure/Document
Number: EAL
Technical Bases and
Charts, Revision: 2
71114.04 Miscellaneous 10 CFR 50.54(q)(3) Facility: GGNS, Title: GGNS EAL Technical Bases and 12/07/2022
Screening, Charts
Procedure/Document
Number: EAL
Technical Bases and
Charts, Revision: 3
71114.04 Miscellaneous 10 CFR 50.54(q)(3) Facility: GGNS, Title: GGNS EAL Technical Basis 12/07/2022
Screening,
Procedure/Document
Number: EAL
29
Inspection Type Designation Description or Title Revision or
Procedure Date
Technical Basis,
Revision: 3
71114.04 Miscellaneous GNRO2022-00011 Grand Gulf Nuclear Station, Unit 1; Emergency Action Level 09/08/2022
(EAL) Technical Basis Document, Revision 2
71114.04 Miscellaneous GNRO2023-00002 Grand Gulf Nuclear Station, Unit 1; Emergency Action Level 02/01/2023
(EAL) Technical Bases Document Revision 3; Grand Gulf
Nuclear Station, Unit 1; Docket No. 50-416, License No.
71114.04 Procedures 05-S-01-EP-4M1-3 Auxiliary Building Control/Radioactive Release Control 0
Modes 1-3
71114.04 Procedures 05-S-01-SAP-1M1-4 Severe Accident Procedure, RPV Control Modes 1-4 0
71114.04 Procedures 05-S-01-SAP-1M5 Severe Accident Procedure, RPV Control Mode 5 0
71114.04 Procedures 05-S-01-SAP-2M1-4 Severe Accident Procedure, Containment and Radioactive 0
Release Control Modes 1-4
71114.04 Procedures 05-S-01-SAP-2M5 Severe Accident Procedure, Containment and Radioactive 0
Release Control Mode 5
71114.04 Procedures EN-EP-305 Emergency Planning 10CFR50.54(q) Review Program 8
71114.08 Miscellaneous GIN 2021-00062 Grand Gulf Nuclear Station, EAL Technical Bases 1
71114.08 Miscellaneous GNRO-2015/00057 Grand Gulf Nuclear Station Hostile Action Based Exercise 08/14/2015
Scenario; Grand Gulf Nuclear Station, Unit 1; Docket No.
50-416; License No. NPF-29
71114.08 Miscellaneous GNRO/2018-00061 2019 Emergency Plan Full Participation Exercise Drill 01/08/2019
Scenario; Grand Gulf Nuclear Station - Unit 1; Docket
No. 50-416; License No. NPF-29
71114.08 Miscellaneous GNRO2021/00001 Grand Gulf Nuclear Station 2021 Graded Exercise Scenario; 01/14/2021
Grand Gulf Nuclear Station, Unit 1; Docket No. 50-416;
License No. NPF-29
71114.08 Miscellaneous GNRO2023-00001 Grand Gulf Nuclear Station 2023 Graded Exercise Scenario; 01/19/2023
Grand Gulf Nuclear Station, Unit 1; Docket No. 50-416;
License No. NPF-29
71114.08 Procedures 10-S-01-12 Radiological Assessment and Protective Action 49
Recommendations
71124.01 Corrective Action CR-GGN- 2022-02014, 2022-02368, 2022-02412, 2022-02794, 2022-
Documents 02802, 2022-03067, 2022-03269, 2022-04863, 2022-06893,
30
Inspection Type Designation Description or Title Revision or
Procedure Date
2022-06942, 2022-06943, 2022-07332, 2022-07727, 2022-
07743, 2022-08255, 2022-11356, 2022-20413
71124.01 Corrective Action CR-GGN- 2023-01296, 2023-01364, 2023-01371, 2023-01372
Documents
Resulting from
Inspection
71124.01 Procedures EN-RP-100 Radiation Worker Expectations 13
71124.01 Procedures EN-RP-101 Access Control for Radiologically Controlled Areas 17
71124.01 Procedures EN-RP-108 Radiation Protection Posting 23
71124.01 Procedures EN-RP-121 Radioactive Material Control 18
71124.01 Procedures EN-RP-152 Conduct of Radiation Protection 7
71124.01 Procedures EN-RP-210 Area Monitoring Program 1
71124.01 Radiation CTMT208 Containment 208-Foot Elevation 07/31/2022
Surveys
71124.01 Radiation CTMT208 Containment 208-Foot Elevation 07/17/2022
Surveys
71124.01 Radiation GGN-AS-030123- Air Sampling Report 03/01/2023
Surveys 0258
71124.01 Radiation Work RWP 2022-1313 Refuel Floor Miscellaneous Craft Support and Management 0
Permits (RWPs)
71124.01 Radiation Work RWP 2023-1070 Funda Filter Work 1
Permits (RWPs)
71124.01 Work Orders 583982 1G41A002 - Generated to Support Spent Fuel Pool 10/03/2022
Cleanout Project
71124.01 Work Orders 590804 SG17D003: Replace Floor Drain Filter Screens 1
71124.04 Corrective Action CR-GGN- 2020-11673, 2021-01524, 2021-01824, 2021-07014, 2022-
Documents 02368, 2022-03127, 2022-03415, 2022-03520, 2022-09337,
2022-10436, 2023-00693, 2023-00694, 2023-00695
71124.04 Corrective Action CR-GGN- 2023-01409
Documents
Resulting from
Inspection
71124.04 Corrective Action CR-HQN- 2023-00265, 2023-00269, 2023-00270, 2023-00271
Documents
31
Inspection Type Designation Description or Title Revision or
Procedure Date
Resulting from
Inspection
71124.04 Miscellaneous NRC Form 5 for various workers 2021, 2022
71124.04 Miscellaneous List of EDEX and Multipack Dosimetry 2022
71124.04 Miscellaneous Source Term Reduction 2022
71124.04 Miscellaneous 100518-0 NVLAP Certificate of Accreditation to ISO/IEC 17025:2017: 01/01/2023
Landauer, Inc. Ionizing Radiation Dosimetry
71124.04 Miscellaneous CR-GGN-2022- Whole Body Count and Dose Assessment 03/08/2022
02368
71124.04 Miscellaneous CR-GGN-2022- Whole Body Count and Dose Assessment 03/19/2022
03127
71124.04 Miscellaneous CR-GGN-2022- Whole Body Count and Dose Assessment 03/24/2022
03415
71124.04 Miscellaneous CR-GGN-2023- Whole Body Count and Dose Assessment 03/24/2022
01409
71124.04 Miscellaneous GGN-RPT-20-005R0 Evaluation of Grand Gulf Nuclear Station's Average Beta 05/06/2021
and Gamma Energy
71124.04 Miscellaneous GGN-RPT-21-002R0 Neutron Monitoring at Grand Gulf Nuclear Station 08/19/2021
71124.04 Procedures EN-RP-201 Dosimetry Administration 5
71124.04 Procedures EN-RP-202 Personnel Monitoring 15
71124.04 Procedures EN-RP-203 Dose Assessment 10
71124.04 Procedures EN-RP-204 Special Monitoring Requirements 11
71124.04 Procedures EN-RP-204-01 Effective Dose Equivalent (EDEX) Monitoring 3
71124.04 Procedures EN-RP-205 Prenatal Monitoring 5
71124.04 Procedures EN-RP-206 Dosimeter of Legal Record Quality Assurance 7
71124.04 Procedures EN-RP-208 Whole Body Counting/In-Vitro Bioassay 7
71124.04 Radiation Work RWP 2021-1082 DFS (Hi Storm 1F16D003BN\ MPC # 1F16D002BN) Work 0
Permits (RWPs) Order #502624
71124.04 Radiation Work RWP 2022-1508 Under Vessel Maintenance 2
Permits (RWPs)
71124.04 Radiation Work RWP 2022-1516 RF23 ISI and Support Activities 1
Permits (RWPs)
71124.04 Radiation Work RWP 2022-1531 Suppression Pool Diving and Vacuum with Diakont Robotic 3
Permits (RWPs) Decon Equipment
32
Inspection Type Designation Description or Title Revision or
Procedure Date
71124.04 Self-Assessments LO-GLO-2022- Pre-NRC Inspection Occupational Dose Assessment 01/30/2023
00086 IP 71124.04
71151 Corrective Action CR-GGN- 2022-06665, 2022-07790, 2022-08868, 2023-00218, 2023-
Documents 00219, 2023-00220
71151 Procedures EN-LI-114 Regulatory Performance Indicator Process 20
71153 Corrective Action CR-GGN- 2016-08765, 2017-12477, 2018-09890, 2019-01757, 2019-
Documents 01833, 2019-04639, 2021-01451, 2021-01536, 2021-02950,
2021-04781, 2021-05802, 2021-06434, 2022-06586, 2022-
07146, 2022-09773, 2022-10127, 2022-11392
71153 Engineering EC-23022 GGNS Extended Power Uprate Feedwater Heater Drain 0
Changes System Level Control Valve Modifications
71153 Engineering EC-91787 Issue Engineering Report GGNS-SA-21-00002 and Revise 1
Changes Engineering Report GGNS-N-16-00007
71153 Miscellaneous 10462339 Purchase Order 02/04/2016
71153 Miscellaneous 10472129 Purchase Order 02/17/2016
71153 Miscellaneous 10537921 Purchase Order 02/07/2018
71153 Miscellaneous 10619352 Purchase Order 08/25/2020
71153 Miscellaneous 55636 Receiving Inspection Report 05/22/2018
71153 Procedures EN-DC-115 Engineering Change Process 10
71153 Procedures EN-LI-108 Event Notification and Reporting 19
71153 Procedures EN-LI-108-01 10 CFR 21 Evaluations and Reporting 13 and 14
71153 Work Orders WO 526443, 526444, 526445, 526446, 558041, 52782092,
52839101, 52884887
33