Text

Notice of Violation; Integrated Inspection Report 05000416/2023001 and NRC Investigation Report 4-2022-004
	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)
	v • d • e

May 10, 2023

EA-22-104

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

ML23110A800

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

EA-22-104

EA-22-115

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

EA-22-115

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

FIN 05000416/2023001-03

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

NCV 05000416/2023001-04

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

NCV 05000416/2023001-05

Open/Closed

EA-22-104

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

NOV 05000416/2023001-06

Open

EA-22-104

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

high radiation areas:

(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

EA-22-115

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

13

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 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 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

FIN 05000416/2023001-03

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