ML111300462

IR 05000416-11-002; on 01/21/2011 03/27/2011; Grand Gulf Nuclear Station, Integrated Resident and Regional Report; Fire Protection, Maintenance Effectiveness, Radiological Hazard Assessment and Exposure Controls, and Event Follow-Up

ML111300462
Person / Time
Site:	Grand Gulf
Issue date:	05/10/2011
From:	Vincent Gaddy NRC/RGN-IV/DRP/RPB-C
To:	Mike Perito Entergy Operations
References
IR-11-002
Download: ML111300462 (61)

See also: IR 05000416/2011002

Text

May 10, 2011 Mr. Mike Perito

Vice President Operations

Entergy Operations, Inc.

Grand Gulf Nuclear Station

P.O. Box 756

Port Gibson, MS 39150

Subject: GRAND GULF

NRC INTEGRATED INSPECTION REPORT NUMBER

05000416/2011002 Dear Mr. Perito:

On March 27, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Grand Gulf Nuclear Station. The enclosed integrated inspection report documents the inspection findings, which were discussed on April 14, 2011, with Mike Perito, Vice President Operations, and other members of your staff.

The inspections examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements occurred.

The NRC has also identified five issues that were evaluated under the risk significance determination process as having very low safety significance (Green). The NRC has determined that four of these findings have violations associated with these issues.

Additionally, o ne licensee-identified violation, which was determined to be of very low safety significance, is listed in this report. However, because of the ir very low safety significance and because

they were entered into your corrective action program, the NRC is treating these finding s as noncited violation

s, consistent with Section

2.3.2 of the NRC Enforcement Policy.

If you contest the significance of the noncited violations, 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, D.C. 20555

-0001, with copies to the Regional Administrator, U.S.

Nuclear Regulatory Commission, Region

IV, 612 E. Lamar Blvd, Suite

400, Arlington, Texas, 76011

-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555

-0001; and the NRC Resident Inspector at the

facility. In addition, if you disagree with the cross

-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date

U N I T E D S T A T E S N U C L E A R R E G U L A T O R Y C O M M I S S I O N R E G I O N I V 6 12 EAST LAMAR BLVD

, S U I T E 4 0 0 A R L I N G T O N , T E X A S 7 6 0 1 1-4125

Entergy Operations, Inc.

- 2 - of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV, and the NRC Resident Inspector at the facility

.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site 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, /RA/ Vincent Gaddy, Chief

Project Branch

C Division of Reactor Projects

Docket: 50

-416 License: NPF-29 Enclosed: NRC Inspection Report 05000416/2011002

w/Attachment: Supplemental Information

Distribution via ListServe

Entergy Operations, Inc.

- 3 - Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov

) Deputy Regional Administrator (Art.Howell@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov) DRP Deputy Director (Troy.Pruett@nrc.gov) DRS Director (Anton.Vegel@nrc.gov) Senior Resident Inspector

(Rich.Smith@nrc.gov

) Branch Chief, DRP/C (Vincent.Gaddy@nrc.gov) Senior Project Engineer, DRP/C

(Bob.Hagar@nrc.gov

) Project Engineer, DRP/C (Rayomand.Kumana@nrc.gov

) GG Administrative Assistant

(Alley.Farrell@nrc.gov) Public Affairs Officer (Victor.Dricks@nrc.gov

) Public Affairs Officer (Lara.Uselding@nrc.gov

) Project Manager (Alan.Wang@nrc.gov)

Branch Chief, DRS/TSB (Michael.Hay@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov

) Regional Counsel (Karla.Fuller@nrc.gov

) Congressional Affairs Officer (Jenny.Weil@nrc.gov

) RIV OEDO/ETA (Stephanie Bush

-Goddard@nrc.gov)

OEMail Resource

ROP Reports

File located: R:

\_REACTORS\_GG\GG 2011 00 2 RP-RLS-vgg.docx SUNSI Rev Compl.

Yes No ADAMS Yes No Reviewer Initials VGG Publicly Avail

Yes No Sensitive Yes No Sens. Type Initials

VGG SRI:DRP/PBC

SPE:DRP/PBC

C:DRS/EB1 C:DRS/EB2 RLSmith BHagar TRFarnholtz

NFO'Keefe /RA/RCHagar for

/RA/ /RA/ /RA/ 5/4/2011 5/4/2011 4/21/2011 4/15/2011 C:DRS/OB C:TSS C:DRS/PSB1

C:DRS/PSB2

C:ACES/SAC MHaire MHay MPShannon GEWerner NTaylor /RA/ /RA/ /RA/ /RA/ /RA/ 4/15/2011 4/18/2011 4/18/2011 4/15/2011 4/18/2011 C:DRP/C VGaddy /RA/ 5/10/11 OFFICIAL RECORD COPY

T=Telephone E=E

-mail F=Fax

- 1 - Enclosure U.S. NUCLEAR REGULATORY COMMISSION

REGION IV Docket: 05000416 License: NPF-29 Report: 05000416/20 11 00 2 Licensee: Entergy Operations, Inc.

Facility: Grand Gulf Nuclear Station

Location: 7003 Baldhill Road

Port Gibson, MS 39150

Dates: January 21, 2011

, through March 27, 2011

Inspectors:

R. Smith, Senior Resident Inspector

M. Baquera, Resident Inspector, Palo Verde

A. Fairbanks, Reactor Inspector

C. Graves, Health Physicist

L. Ricketson, P.E., Senior Health Physicist

E. Uribe, Reactor Inspector

Approved By:

Vincent Gaddy, Chief

, Project Branch C

Division of Reactor Projects

- 2 - Enclosure SUMMARY OF FINDINGS

IR 05000416/2011002; 1/1/2011

- 3/27/2011; Grand Gulf Nuclear Station, Integrated

Resident and Regional Report;

Fire Protection , Maintenance Effectiveness

, Radiological Hazard Assessment and Exposure Controls

, and Event Follow

-U p. The report covered a 3

-month period of inspection by resident inspectors and an announced baseline inspection by region

-based inspector

s. Five Green noncited violations of significance were identified

and one Green finding

of significance w

as identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance Determination Process." The cross-cutting aspect is determined using Inspection Manual Chapter 0310, "Components Within the Cross Cutting Areas." Findings for which the significance determination process does

not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe

operation of commercial nuclear power reactors is described in NUREG

-1649, "Reactor Oversight Process," Revision 4, dated December 2006. A. NRC-Identified Findings and Self

-Revealing Findings

Cornerstone: Mitigating Systems

SLIV. Inspectors identified a noncited violation of 10 CFR 50.71(e)(4)

, which requires the final safety analysis report be updated, at intervals not exceeding 24

months, to reflect changes made in the facility or procedures described in the final safety analysis report. Licensee

personnel failed to update the original revision of the final safety analysis report to reflect the actual number of low pressure coolant injection loops available for automatic initiation during shutdown cooling operations in Mode 3.

The licensee plans to update the final safety analysis report at the next scheduled revision.

This finding was entered into the licensee's corrective action program as condition report CR

-GGN-2011-01631. The failure of licensing personnel to update the final safety analysis report to reflect the available low pressure coolant injection loops for automatic initiation during shutdown cooling operations in Mode 3 was a performance deficiency. This finding was evaluated using traditional enforcement because it had the potential for impacting the NRC's ability to perform its regulatory function. The inspectors used the NRC Enforcement Policy, dated September 30, 2010, to evaluate the significance of this violation. Consistent with the NRC Enforcement

Policy, this finding was determined to be a Severity Level IV noncited violation.

Green. The inspectors identified a noncited

violation of 10 CFR Part 50.65(a)(2) for the licensee's failure to demonstrate that the performance of the train B control room air conditioner was being effectively controlled through the performance of appropriate preventive maintenance. Engineering

did not properly evaluate maintenance rule functional failures resulting in the system remaining in an

a(2) status instead of

an a(1) status. As corrective action, the

- 3 - Enclosure train B control room air conditioner was moved into an a(1) status. The licensee entered this issue into their corrective action program as Condition Report CR-GGN-2011-01623. The finding was more than minor because it was associated with the equipmen

t performance 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. Inspectors performed a Phase 1 screening, in accordance with Inspection Manual Chapter 0609, Attachment 4, "Phase 1

- Initial Screening and Characterization of Findings," and determined that the finding was of very low safety significance (Green) because the maintenance rule aspect of the finding did not cause an actual loss of safety function of the system nor did it cause a component to be inoperable. As corrective action, the train B control room air conditioner was moved into an (a)(1) status. This finding had

a crosscutting aspect in the area of human performance associated with the decision making component because licensee personnel failed to make appropriate safety-significant or risk

-significant decisions to address the multiple failures of the train B control room air conditioner

compressor

. H.1(a) (Section 1R12.b.2) Green. The inspectors reviewed a self

-revealing noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, after the licensee failed to determine the cause and prevent recurrence of a significant condition adverse to quality associated with the train B control room air conditioner compressor tripping due to low oil pressure. Specifically, on December 13, 2010, the train B control room air

conditioner compressor tripped

on low oil pressure after the licensee had performed a root cause analysis to identify the cause and prevent recurrence of a similar compressor trip on October 14, 2010. As immediate corrective action, the licensee installed an inline suction filter. No additional failures have occurred since its installation. The finding was entered into the licensee's corrective action program as Condition Report CR

-GGN-2010-07315. This finding was more than minor because it was associated with the equipmen

t performance 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. Using Inspection Manual Chapter 0609, "Significance Determination Process," Phase 1 worksheets, the inspectors

determined that a Phase 2 analysis was required because the finding represented a loss of system safety function. The plant

-specific risk informed notebook does not include the evaluation of risk caused by the loss of cooling to the main control room.

Therefore, the senior reactor analyst conducted a Phase 3 analysis. Based on the bounding analysis, the analyst determined that the change in core damage frequency result was 5.9 x 10-7. This noncited violation was therefore determined to be of very low safety significance (Green).

This finding had a crosscutting aspect in the area of problem identification and resolution

associated with the corrective action program

component because licensee personnel failed to

- 4 - Enclosure thoroughly evaluate the multiple failures of the

train B control room air conditioner compressor

. P.1(c) (Section 4OA3.1.b) Cornerstone: Barrier Integrity

Green . The inspectors identified a noncited violation of Facility Operating License Condition 2.C(41), involving the failure to ensure that transient combustible were not stored in the fire exclusion zone

near the independent spent fuel storage installation

. The inspectors performed a quarterly fire protection inspection of independent spent fuel storage installation

and identified a large air conditioner with combustible material covering it located in the fire exclusion zone that was

within 60 feet of the dry

fuel storage pad. The inspectors determined through interviews that the material had been placed there the previous day by the maintenance department.

As immediate corrective action the licensee removed the combustible material from the area. The finding was entered into the licensee's corrective action program as Condition Report

CR-GGN-2011-00455. This finding was more than minor because it was associated human performance attribute of the Barrier Integrity Cornerstone to provide reasonable assurance

that physical design barriers protect the public from radionuclide releases caused

by accidents or events.

Using Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination Process," the inspectors determined that the finding impacted th

e fire prevention and administrative controls

category. The inspectors assigned a low degradation rating due to the fact that the amount of combustible material in the area was minimal.

The inspectors concluded that the finding was of very low safety significance (Green) due to the fact there were

no fire ignition sources in the area. The cause of this finding has a crosscutting aspect in the area of human performance associated with

th e work practices

component because the licensee failed to

effectively

communicate expectations regarding storage of combustible material near the dry fuel storage pad

. H.4(b) (Section 1R05.1.b) Green. The inspectors reviewed a self-revealing , Green finding of EN

-DC-115, "Engineering Change Process," involving the failure to maintain adequate design control measures associated with the installation of the mitigation monitoring system. On November 8, 2010, a reactor coolant pressure boundary failure occurred at the skid mounted Online Noble Chemical

- Mitigation Monitoring System pump inside primary containment. The positive displacement sample pump ejected the pump piston from the housing

, resulting in an approximate

7 gpm leak of reactor coolant. The steam leak resulted in a reactor recirculation system flow control valve lockup (due to hydraulic power unit motor failure) and approximately 15,000 square feet of contaminated area in the primary containment structure.

The licensee failed to ensure proper validation testing for the pump prior to installation. Specifically

, the licensee did not ensure that the pump could withstand the operating pressures and temperatures of the system in

- 5 - Enclosure which it was installed. The licensee

removed the mitigation monitoring system from service and isolated the skid from the reactor water cleanup system. This finding was entered into the licensee's corrective action program as Condition

Report CR-GGN-2010-07852. The finding is more than minor because it affects the design control attribute of the Barrier Integrity Cornerstone to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.

Therefore, using inspection Manual Chapter 0609, "Significance Determination Process," Phase 1 Worksheet for LOCA initiators, the inspectors concluded that the finding was of very low safety significance (Green) because the failure of the mitigation monitoring system would not have exceeded technical specifications limits for identified leakage in the reactor coolant system.

This finding has a crosscutting aspect in the work practices component of the human

performance area; because the licensee failed to adequately oversee the design

of the mitigation monitoring system

such that nuclear safety is supported

. H.4(c) (Section 4OA3.2.b)

Cornerstone: Occupational Radiation Safety

Green. The inspectors identified a noncited violation of Technical Specification 5.7.2, resulting from the licensee's failure to use a qualified radiation protection technician to provide direct continuous coverage of work in a locked high radiation area. The finding was placed into the corrective action program as Condition Report CR

-GG N-2011-01045 , and corrective action was being evaluated.

The failure to use a qualified radiation protection technician to provide direct continuous coverage of work in a locked high radiation area is a performance deficiency. The finding was more than minor because it was associated with the Occupational Radiation Safety Cornerstone attribute (exposure control) of program and process and affected the cornerstone objective, in that, the failure to use qualified radiation protection technicians to provide job coverage in a high radiation area with dose rates in excess of 1000 mrem/hr had the potential to

increase personnel dose. Using the Occupational Radiation Safety Significance Determination Process, the inspectors determined the finding to have very low safety significance because: (1) it was not associated with ALARA

planning or work controls, (2)

there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised.

(Section 2RS01.b) B. Licensee-Identified Violations

Violations of very low safety significance, which were identified by the licensee, have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. These violations and corrective action tracking numbers (condition report numbers) are listed in Section 4OA7.

- 6 - Enclosure REPORT DETAILS

Summary of Plant Status

Grand Gulf Nuclear Station began the inspection period at full rated thermal power.

On January 9, 2011, operators reduced power to 68 percent for a planned control rod sequence exchange and isolation of the moisture separator reheaters (MSRs) second stage steam to both the 'A' and 'B' MSRs due to tube leaks in the 'A' MSR. The plant was returned to 96 percent power on January 10, 2011

, which was maximum power level allowed with MSR second stage steam isolated. On February 18, 2011, operators reduced power to 77 percent for monthly control rod testing, turbine testing

, and to remove 'B' heater drain pump from service in

an attempt to repair a steam leak on the heater drain pump 'B' discharge flange.

The plant was returned to 96 percent power on

February 19, 2011. On March 11, 2011, operators reduced power to

84 percent power for a planned control rod testing and to remove 'B' heater drain pump from service in another attempt to repair a steam leak on the heater drain pump 'B' discharge flange. The plant was returned to 96 percent power on

March 12, 2011.

On March 23, 2011, operators reduced power to 93 percent power to remove the 'B' heater drain pump from service again in

another attempt to repair a steam leak on the heater drain pump 'B' pump

discharge flange. The plant was returned to 96 percent power on

March 12, 2011. The plant remained at 96 percent power for the remainder of the inspection period.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

1R01 Adverse Weather Protection (71111.01)

.1 Readiness for Seasonal Extreme Weather Conditions

a. The inspectors performed a review of the adverse weather procedures for seasonal extreme low temperatures. The inspectors verified that weather

-related equipment deficiencies identified during the previous year were corrected prior to the onset of

seasonal extremes

, and evaluated the implementation of the adverse weather preparation procedures and compensatory measures for the affected conditions before the onset of, and during, the adverse weather conditions.

Inspection Scope

During the inspection, the inspectors focused on plant

-specific design features and the procedures used by plant personnel to mitigate or respond to adverse weather conditions. Additionally, the inspectors reviewed the updated final safety analysis report

and performance requirements for systems selected for inspection

and verified that operator actions were appropriate as specified by plant

-specific procedures. Specific documents reviewed during this inspection are listed in the attachment. The inspectors

also reviewed corrective action program items to verify that plant personnel

were identifying adverse weather issues at an appropriate threshold and entering them into

- 7 - Enclosure their corrective action program in accordance with station corrective action procedures. The inspectors' reviews focused specifically on the following plant systems:

Standby service water Emergency diesel

generator s Plant service water

Fire water pumps and tanks

These activities constitute completion of one readiness for seasonal adverse weather sample as defined in Inspection Procedure

71111.01-05. b. No findings were identified.

Findings .2 Readiness for Impending Adverse Weather Conditions

a. Since extreme cold conditions and icing were forecast in the vicinity of the facility for January 9, 2011, the inspectors reviewed overall preparations/protection for the expected weather conditions. On

January 7, 2011, the inspectors inspected the standby service water towers because their safety

-related functions could be affected as a result of the extreme cold and icing conditions forecast for the facility. The inspectors observed space heater operation and weatherized enclosures to ensure operability of affected systems. The inspectors reviewed licensee procedures and discussed potential compensatory measures with control room personnel. The inspectors focused on plant management's actions for implementing the station's procedures for ensuring adequate personnel for safe plant operation and emergency response would be available. Specific documents reviewed during this inspection are listed in the attachment.

Inspection Scope

These activities constitute completion

of one readiness for impending adverse weather condition sample as defined in Inspection Procedure

71111.01-05. b. No findings were identified.

Findings 1R04 Equipment Alignments (71111.04)

.1 Partial Walkdown

a. The inspectors performed partial system walkdowns of the following risk

-significant systems: Inspection Scope

Division II

standby service water system

during Division I maintenance outage

- 8 - Enclosure Residual heat removal system

B during residual heat removal system

A maintenance outage

Residual heat removal system C during residual heat removal system

A maintenance outage

Division II standby diesel generator system during Division I maintenance outage

Standby liquid control system A during standby liquid control system B maintenance outage The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, UFSAR, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact

of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The

inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors

also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five partial system walkdown sampl

es as defined in Inspection Procedure

71111.04-05. b. No findings were identified.

Findings 1R05 Fire Protection (71111.05)

Quarterly Fire Inspection Tours

a. The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk

-significant plant areas:

Inspection Scope

Division II diesel generator room (1D303)

- 9 - Enclosure Residual heat removal pump and heat exchanger rooms A (1A102 and 1A103)

Residual heat removal pump and heat exchanger rooms B (1A10

5 and 1A10 6) Reactor Core Isolation Pump Room (1A104)

Dry fuel storage pad area

(Area 59 the Yard)

The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensee's fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later

additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that

fire detectors and sprinklers were unobstructed

that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's corrective action program. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five quarterly fire

-protection inspection sampl

es as defined in Inspection Procedure

71111.05-05. b. Findings Introduction

. The inspectors identified a Green noncited violation of Facility Operating License Condition 2.C(41), involving the failure to ensure that transient combustible were not stored in the fire exclusion zone

near the independent spent fuel storage installati

on. Description

. On January 24, 2011, the inspectors performed a quarterly fire protection inspection of independent spent fuel storage installation. The inspectors identified a large air conditioner with combustible material covering it located in the fire exclusion zone that appeared to be within 60 feet of the dry fuel storage pad. The inspectors brought this to the attention of the work center senior reactor operator. The work center senior reactor operator contacted the site fire engineer, who walked down the fire exclusion zone and determined that the combustible material covering the air conditioner was within the 60 feet of the dry fuel storage pad, which is in violation of plant procedural requirements. The inspectors determined through interviews that the material had been placed there the day before by the maintenance department. The site had the air conditioner and the covering material removed from the fire exclusion zone to restore

compliance.

The licensee documented this violation in Condition Report

CR-GGN-2011-00455. Its short-term corrective actions included removing the combustible material from the area.

- 10 - Enclosure Analysis. The inspectors determined that the failure to follow fire protection procedures developed for control of transient combustible material stored near the dry spent fuel storage pad was a performance deficiency.

This finding was more than minor because it was associated human performance attribute of the Barrier Integrity Cornerstone to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.

Using Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination Process," the inspectors determined that the finding impacted the fire prevention and administrative controls

category. The inspectors assigned a low degradation rating due to the fact that the amount of combustible material in the area was minimal.

The inspectors concluded that the finding was of very low safety significance (Green) due to the fact there were no fire ignition sources in the area. The finding has a crosscutting aspect in the area of human performance associated with

the work practices

component because the licensee failed

to effectively

communicate expectations regarding storage of combustible material near the dry fuel storage pad. H.4(b) Enforcement

. Grand Gulf Nuclear Station Facility Operating License Condition 2.C(41) 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, "Administrative

Controls," section 9B.6.a, govern s the handling and limit

s the use of ordinary combustible materials

in safety related areas.

Fire area 59

, defined as the yard

, contains the fire exclusion area next to the dry fuel storage pad and prohibits the storage

of any combustible material in this area. Contrary to this, on January 23, 2011, the licensee stored combustible material inside the transient combustible exclusion zone

near the dry fuel storage pad. The licensee restored compliance by removing the

material from the area on January 25, 2011. Because the finding was of very low safety significance (Green) and was documented in the licensee's corrective action program

as CR-GGN-201 1-0 455, this finding is being treated as a noncited violation (NCV) consistent with Section VI.A of the NRC Enforcement Policy:

NCV 05000416/201

1 00 2-01; Transient Combustible Stored in the Fire Exclusio n Zone Near the Independent Spent Fuel Storage Installation

. 1R06 Flood Protection Measures (71111.06)

a. The inspectors reviewed the flooding analysis, and plant procedures to assess seasonal susceptibilities involving internal flooding;

reviewed the Updated Final Safety Analysis Report and corrective action program to determine if licensee personnel identified and corrected flooding problems; inspected underground bunkers/manholes to verify the adequacy of sump pumps, level alarm circuits, cable splices subject to submergence, and drainage for bunkers/manholes; subject to flooding that contain cables whose failure

could disable risk

-significant equipment. The inspectors walked down the areas listed below. Specific documents reviewed during this inspection are listed in the attachment.

Inspection Scope

January 11, 2011 , division 1 and 2 standby service water manholes

- 11 - Enclosure These activities constitute completion of

one bunker/manhole sample as defined in Inspection Procedure

71111.06-05. b. No findings were identified.

Findings

1R07 Heat Sink Performance (71111.07)

a. The inspectors reviewed licensee programs, verified performance against industry standards, and reviewed critical operating parameters and maintenance records for the Division 1 emergency diesel generator jacket water and lube oil heat exchangers. The inspectors verified that performance tests were satisfactorily conducted for heat exchangers/heat sinks and reviewed for problems or errors; the licensee utilized the periodic maintenance method outlined in EPRI Report

NP 7552, "Heat Exchanger Performance Monitoring Guidelines"; the licensee properly utilized biofouling controls; the licensee's heat exchanger inspections adequately assessed the state of cleanliness of their tubes; and the heat exchanger was correctly categorized under 10

CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Specific documents reviewed during this inspection are listed in the attachment.

Inspection Scope

These activities constitute completion of one heat sink inspection sample as defined in

Inspection Procedure

71111.07-05. b. Findings No findings were identified.

1R11 Licensed Operator Requalification Program (71111.11)

a. On January 31, 2011, the inspectors observed a crew of licensed operators in the plant's simulator to

verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

Inspection Scope

Licensed operator performance

Crew's clarity and formality of communications

Crew's ability to take timely actions in the conservative direction

Crew's prioritization, interpretation, and verification of annunciator alarms

Crew's correct use and implementation of abnormal and emergency procedures

- 12 - Enclosure Control board manipulations

Oversight and direction from supervisors

Crew's ability to identify and implement appropriate technical specification actions and emergency plan actions and notifications

The inspectors compared the crew's performance in these areas to preestablished operator action expectations and successful critical task completion requirements. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one quarterly licensed

-operator requalification program sample as defined in Inspection Procedure

71111.11. b. No findings were identified.

Findings 1R12 Maintenance Effectiveness (71111.12)

a. The inspectors evaluated degraded performance issues involving the following risk significant systems:

Inspection Scope

Appendix R emergency lighting units (Z92)

Control room air conditioning (Z51)

Residual heat removal (E12)

The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

Implementing appropriate work practices Identifying and addressing common cause failures

Scoping of systems in accordance with 10 CFR 50.65(b)

Characterizing system reliability issues for performance

Charging unavailability for performance

Trending key parameters for condition monitoring

- 13 - Enclosure Ensuring proper classification in accordance with 10

CFR 50.65(a)(1) or

-(a)(2) Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described in 10 CFR 50.65(a)(1)

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three quarterly maintenance effectiveness sample s as defined in Inspection Procedure

71111.12-05. b. .1 Failure to Update Available Low Pressure Cooling Injection Loops in the Updated Final Safety Analysis Report

Findings Introduction. Inspectors identified a Severity Level IV, noncited violation for the licensee's failure to update the final (updated) safety analysis report in accordance with 10 CFR 50.71(e)(4). Specifically, the licensee failed to update Section 6.3, "Emergency Core Cooling Systems," to appropriately reflect the available emergency core cooling equipment during shutdown cooling operations in Mode 3.

Description. On February 28, 2011, while reviewing the updated final safety analysis report for a maintenance effectiveness inspection of the residual heat removal system,

the inspectors determined that Section 6.3.1.1.1.e, "Emergency Core Cooling Systems," states, "The ECCS is designed to satisfy all criteria specified in Section 6.3 for any normal mode of reactor operation." Additionally, Section 6.3.1.1.2.d states, "In the event of a break in a pipe that is part of the reactor coolant pressure boundary, no single active component failure in the emergency core cooling system

shall prevent automatic initiation and successful operation of less than the following combination of emergency core cooling system

equipment: 1) Three low pressure coolant injection

loops, the low pressure core spray

and the automatic depressurization system

(i.e., high pressure core spray failure); 2) Two low pressure coolant injection loops, the

high pressure core spray and the automatic depressurization system

(i.e., low pressure core spray

diesel generator failure); and 3) One low pressure coolant injection

loop, the low pressure core spray, the high pressure core spray

and automatic depressurization system

(i.e., low pressure coolant injection

diesel generator failure)." Procedure 03

-1-01-3, "Plant Shutdown," Revision 118, Section 6.14 states, "When shutdown cooling is placed in service at less than 135 psig, then the associated containment spray and low pressure coolant injection systems may be considered

- 14 - Enclosure operable if capable of being manually realigned and not otherwise inoperable." Inspectors noted that because the residual heat removal system that provides shutdown cooling in Mode 3 is not available for automatic initiation (must be manually realigned) of low pressure coolant injection, in the event of a reactor coolant system pipe break, that

the aforementioned statements in Section 6.3 did not appropriately reflect the available emergency core cooling equipment during shutdown cooling operations. In other words , the combinations of emergency core cooling equipment available for automatic initiation would include one less low pressure coolant injection

loop. The licensee entered this issue into their

corrective actions program as Condition Report CR-GGN-2011-01631. The licensee planned to

take actions to update the updated final safety analysis report at the next scheduled revision.

Analysis. The failure of licensing personnel to update the final safety analysis report to reflect the available low pressure coolant injection loops for automatic initiation during

shutdown cooling operations in Mode 3 was a performance deficiency. Th

is finding was evaluated using traditional enforcement because it had the potential for impacting the NRC's ability to perform its regulatory function. The inspectors used the NRC Enforcement Policy, dated September 30, 2010, to evaluate the significance of this

violation. Consistent with the NRC Enforcement Policy, this finding was determined to be a Severity Level IV noncited violation. This finding had no crosscutting aspect as it was associated with a traditional enforcement violation.

Enforcement. Title 10 CFR 50.71(e)(4) requires the final safety analysis report be updated, at intervals not exceeding 24 months, and states in part, "the revisions must reflect all changes made in the facility or procedures described in the FSAR." Contrary

to the above, licensing personnel failed to update the original revision of the final safety analysis report to reflect the actual number of low pressure coolant injection loops available for automatic initiation during shutdown cooling operations in Mode 3.

Because the finding is of very low safety significance and has been entered into th

e corrective action program as Condition Report CR-GGN-2011-01631, this violation is being treated as a noncited violation consistent with the NRC Enforcement Policy:

NCV 0500416/20011002

-02, "Failure to Update Available Low Pressure Coolant Injection Loops in the Updated Final Safety Analysis Report." .2 Failure to Demonstrate Maintenance Effectiveness of Train B Control Room Air Conditioner

Introduction

. The inspectors identified a Green noncited violation of 10 CFR Part 50.65(a)(2) for the failure to demonstrate that the performance of the

train B control room air conditioner was being effectively controlled through the performance of appropriate preventive maintenance.

Description. On March 2, 2011, the inspectors perform

ed a maintenance effectiveness inspection of the control room air conditioning system. Inspectors

determined that on February 3, 2010, the train B control room air conditioner

compressor was replaced with a remanufactured compressor as part of annual preventative maintenance of the system. On March 27, 2010, the control room air conditioner

compressor tripped on low

- 15 - Enclosure usable oil pressure. The licensee's investigation revealed that the compressor pencil strainer was approximately fifty percent covered with unidentified contaminants. Similar contaminants were identified on the oil sump strainer. The licensee concluded that the compressor had been installed with contaminants inside the lower half of the compressor, and subsequently replaced the remanufactured compressor on April 1, 2010, with a newly rebuilt compressor. System engineering did not classify this event as a maintenance rule functional failure even though operations had declared the train inoperable and also stated in their operability determination that it could not meet its 30 day mission time.

The train B control room air conditioner

compressor subsequently either tripped or failed to properly cool the control room, due to low usable oil pressure, on three separate occasions (once in April, once May

, and once in June). In response to the June failure, the licensee performed extensive maintenance on the train B control room air conditioner

compressor, which included installing a five micron suction line filter in the system. Additionally, all three events were identified as maintenance rule functional failures attributed to foreign material fouling in the system, which would have resulted in the performance criteria being exceeded (less than or equal to two maintenance rule

functional failure events or as a repeat functional failure). However, the site's maintenance rule coordinator informed the inspectors that the first two events in April and May were not counted toward the criteria because they were from the same cause as the June event and; therefore, they would all be counted as one failure even thought

the train was returned to service each time after corrective maintenance was performed and declared operable by operations. Additionally, on June 22, 2010, the train was

declared inoperable due to multiple Freon leaks and was classified as another maintenance rule functional failure for the train. On August 10, 2010, the licensee performed a Maintenance Rule (a)(1) evaluation for the subject system and, based on the presentation to the expert panel by system engineering, the panel only considered two events as maintenance rule functional failures.

System engineering did not count the one failure in March or consider the two failures in April or May. The expert panel only considered the failures in June due to low oil pressure and Freon leaks. Therefore

the expert panel concluded that, although the train B control room air conditioner

system had exceeded its established performance criteria for functional failure events, a number

of effective corrective actions had been identified and implemented and additional corrective actions were not necessary; therefore, the subject system was allowed to

retain its (a)(2) status.

The train B control room air conditioner

compressor subsequently either tripped or failed to properly cool the control room, due to low us

able oil pressure, on two separate occasions (once in September and once in October). The October trip of the subject

system compressor occurred while the train A control room air conditioner

was out of service for routine maintenance. The compressor pencil strainer and sump strainer were again identified with contaminants on them. The licensee was required to make an eight-hour report to the NRC and submit a licensee event report due to both trains of control room air conditioner

being inoperable. The licensee's root cause analysis failed to identify that the train B control room air conditioner

performance had not been demonstrated through the performance of appropriate preventative maintenance; nor did the root cause identify that the licensee failed to

set goals and monitor the system as

- 16 - Enclosure required by 10 CFR 50.65(a)(1). The train B control room air conditioner

was ultimately moved into (a)(1) status on February 4, 2011, after the subject compressor again tripped due to low oil pressure on December 13, 2010. After this trip and upon further evaluation, the licensee performed an additional corrective action that installed an in line suction filter with smaller filtering diameter and larger surface area to remove foreign material from the system. They also modified the operator rounds to obtain daily readings of differential pressure across this new filter and through calculation, determined a differential pressure necessary for the filter to be changed out

and the unit to be inspected for foreign material s. The licensee entered this issue into their

corrective actions program as Condition Report CR-GGN-2011-01623. From installation

of the new inline suction filter

to the conclusion of the inspection period , no additional trips of train B control room air conditioning have occurred. Analysis. The inspectors determined that the failure to demonstrate that the performance of the train B control room air conditioner was being effectively controlled through the performance of appropriate preventive maintenance was a performance deficiency. The finding was more than minor because it was associated with the equipment performance 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. Inspectors performed a Phase 1 screening, in accordance with Inspection Manual Chapter 0609, Attachment 4, "Phase 1

- Initial Screening and Characterization of Findings," and determined that the finding was of very low safety significance (Green)

because it did not result in a loss of system safety function since the train A control room air conditioner

remained operable.

This finding had

a crosscutting aspect in the area of human performance associated with the decision making

component because licensee personnel failed to make appropriate safety-significant or risk

-significant decisions to address the multiple failures of the train B CRAC compressor

. H.1(a) Enforcement. Title 10 CFR 50.65(a)(2), states, in part, that "monitoring as specified in paragraph (a)(1) of this section is not required where it has been demonstrated that the performance or condition of a structure, system, or component is being effectively controlled through the performance of appropriate preventative maintenance, such that the structure, system, or component remains capable of performing its intended function." Contrary to the above, from March

2010 to February 2011, the licensee failed to demonstrate that the performance of the train B control room air conditioning system

was effectively controlled through the performance of appropriate preventative maintenance. This finding was entered into the licensee's corrective action program as

Condition Report CR-GGN-2011-01623. Because this finding was determined to be of very low safety significance and was entered into the licensee's corrective action

program, this violation is being treated as a noncited violation consistent with the NRC Enforcement Policy: NCV 05000285/2011002

-03, "Failure to Demonstrate Maintenance Effectiveness of Train B Control Room Air Conditioner."

- 17 - Enclosure 1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. The inspectors reviewed licensee personnel's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk

-significant and safety

-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

Inspection Scope

On January 9, 2011, during an ice storm requiring the plant to enter a yellow risk condition and enter their off normal event procedure for severe weather.

On February 3, 2011, during an ice storm requiring the plant to enter a yellow risk condition and enter their off normal event procedure for severe weather. The weather required the site to cancel work and monitor their safety related standby service water system for icing conditions.

On February 9, 2011, during

a winter storm, while a divisions 1 diesel generator and residual heat removal A were out for planned maintenance outage requiring the plant to enter orange risk.

On February 28, 2011, during the accidental unearthing of energized plant service water pump cables, no consequence to the plant but resulted in work

stoppage and evaluation of risk status for the site.

On March 8

-9, 2011, with an emergent issue with the division 1 diesel generator

and a tornado watch issued for the area requiring the plant to enter yellow risk. The site entered their severe weather off normal procedure; this procedure

required the site to secure from half scram surveillances.

The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10

CFR 50.65(a)(4) and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when

applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific

documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five emergent work control inspection sample

s as defined in Inspection Procedure

71111.13-05.

- 18 - Enclosure b. No findings were identified.

Findings 1R15 Operability Evaluations (71111.15)

a. The inspectors reviewed the following issues:

Inspection Scope

Division 3 high pressure core spray diesel generator outside air fan temperature switch fluctuating

Train A standby service water drift eliminator support base plate corrosion and missing brass bolts

Train A standby service water valve P41-F299A flange degradation

Residual heat removal equipment area temperature high/inoperable due to temperature switch

Site fire truck

inoperable

Division 1 diesel generator auxiliary oil pump not obtaining procedural pressures during pre

-lube prior to surveillance run

The inspectors selected these potential operability issues based on the risk

significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to the licensee

personnel's

evaluations

to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the

inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this inspection are listed in the

attachment.

These activities constitute completion of six operability evaluations inspection samples as defined in Inspection Procedu

re 71111.15-04

- 19 - Enclosure b. No findings were identified.

Findings 1R18 Plant Modifications (71111.18)

a. To verify that the safety functions of important safety systems were not degraded , the inspectors reviewed the following temporary modifications

Inspection Scope

Temporary Modification for RWCU A/B Leak Detection (EC 22625 & EC 22635)

Temporary Modification to install bypass signals for 'B' first stage Pressure Sensor (EC22768)

The inspectors reviewed the temporary modification

s and the associated

safety-evaluation screening against the system design bases documentation, including the updated final safety analysis report

and the technical specifications, and verified that the modification did not adversely affect the system operability/availability. The inspectors

also verified that the installation and restoration were consistent with the modification documents and that

configuration control was adequate. Additionally, the inspectors verified that the temporary modification was identified on control room drawings, appropriate tags were placed on the affected equipment, and licensee personnel evaluated the combined effects on mitigating systems and the integrity of radiological barriers.

These activities constitute completion of two sample s for temporary plant modifications as defined in Inspection Procedure

71111.18-05. b. No findings were identified.

Findings 1R19 Postmaintenance Testing (71111.19)

a. The inspectors reviewed the following postmaintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

Inspection Scope

For standby liquid B after a maintenance outage

For reactor protection motor generator

B after required maintenance

For residual heat removal system A after a maintenance outage

- 20 - Enclosure For standby service water system A after a maintenance outage

For division 1 diesel generator after a maintenance outage

For high pressure core spray minimum flow valve 1E22

-F012 after corrective maintenance

The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following (as applicable):

The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed

Acceptance criteria were clear and demonstrated operational readiness; test

instrumentation was appropriate

The inspectors evaluated the activities against the technical specifications, the UFSAR , 10 CFR Part 50 requirements, licensee procedures, and various NRC generic

communications to ensure that the test results adequately ensured that

the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with postmaintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their

importance to safety. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of six postmaintenance testing inspection sample

s as defined in Inspection Procedure

71111.19-05. b. No findings were identified.

Findings 1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors reviewed the UFSAR, procedure requirements, and technical specifications to ensure that the surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the following:

Preconditioning

- 21 - Enclosure Evaluation of testing impact on the plant

Acceptance criteria

Test equipment

Procedures

Test data Testing frequency and method demonstrated technical specification operability

Test equipment removal

Restoration of plant systems

Updating of performance indicator data

Engineering evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct

Reference setting data

Annunciators and alarms setpoints

The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.

On January 7, 2011, reactor coolant system leakage detection surveillance

On February 4, 2011, inservice test of residual heat removal system B quarterly

On February 23, 2011, reactor coolant routine chemistry

surveillance

On March 2, 2011, fuel handling area ventilation exhaust radiation monitor time response test

On March 10, 2011, division 1 diesel generator monthly surveillance

On March 18, 2011, division 3 diesel generator monthly surveillance

On March 20

-21, 2011 , functional checks with reactor core isolation cooling valves at the remote shutdown panel

Specific documents reviewed during this inspection are listed in the attachment.

- 22 - Enclosure These activities constitute completion of seven surveillance

(one reactor coolant system leakage detection, one inservice test, and five routine tests)

testing inspection sample

s as defined in Inspection Procedure

71111.22-05. b. No findings were identified.

Findings Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.0

6) .1 Emergency Preparedness Drill Observation

a. The inspectors evaluated the conduct of a routine licensee emergency drill on March 3, 2011, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator control room and emergency operations facility

to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector

-observed weakness with those identified by the licensee staff in order to evaluate the critique and

to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the attachment.

Inspection Scope

These activities constitute completion of one sample as defined in Inspection Procedure 71114.06-05. b. No findings were identified.

Findings 2. RADIATION SAFETY

Cornerstone: Occupational and Public Radiation Safety

2RS01 Radiological Hazard Assessment and Exposure Controls (71124.01)

a. Inspection Scope

This area was inspected to: (1)

review and assess licensee's performance in assessing the radiological hazards in the workplace associated with licensed activities and the implementation of appropriate radiation monitoring and exposure control measures for both individual and collecti

ve exposures, (2) verify the licensee is properly identifying and reporting Occupational Radiation Safety Cornerstone performance indicators, and

- 23 - Enclosure (3) identify those performance deficiencies that were reportable as a performance indicator and which may have represented a substantial potential for overexposure of the worker.

The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensee's procedures required by technical specifications as criteria for determining compliance. During the inspection, the inspectors interviewed the radiation protection manager, radiation protection supervisors, and radiation workers. The inspectors performed walkdowns of various portions of the plant, performed independent radiation dose rate measurements and reviewed the following items:

Performance indicator events and associated documentation reported by the licensee in the Occupational Radiation Safety Cornerstone

The hazard assessment program, including a review of the license's evaluations of changes in plant operations and radiological surveys to detect dose rates, airborne radioactivity, and surface contamination levels

Instructions and notices to workers, including labeling or marking containers of radioactive material, radiation work permits, actions for electronic dosimeter alarms, and changes to radiological conditions

Programs and processes for control of sealed sources and release of potentially contaminated material from the radiologically controlled area, including survey

performance, instrument sensitivity, release criteria, procedural guidance, and sealed source accountability

Radiological hazards control and work coverage, including the adequacy of surveys, radiation protection job coverage, and contamination controls; the use of electronic dosimeters in high noise areas; dosimetry placement; airborne radioactivity monitoring; controls for highly activated or contaminated materials (non-fuel) stored within spent fuel and other storage pools; and posting and physical controls for high radiation areas and very high radiation areas

Radiation worker and radiation protection technician performance with respect to radiation protection work requirements

Audits, self

-assessments, and corrective action documents related to radiological hazard assessment and exposure controls

since the last inspection

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedur

e 71124.01-05.

b. Findings

- 24 - Enclosure Introduction. The inspectors identified a Green, noncited violation of Technical Specification 5.7.2, resulting from the licensee's failure to use a qualified radiation protection technician to provide direct continuous coverage of work in a locked high radiation area

. Description. The inspectors reviewed Condition Report CR

-GGN-2011-00655, which documented the identification by Cooper Nuclear Station that a contractor seeking employment as a radiation protection technician did not meet ANSI 18.1 requirements. The finding, documented February 2, 2011, was discussed with Entergy sites during a teleconference. Then, Grand Gulf Nuclear Station determined the individual had been employed as a radiation protection technician at Grand Gulf Nuclear Station during Refueling Outage 17, conducted in April and May 2010. In response, Grand Gulf Nuclear Station reviewed the radiation surveys performed by the individual (from April 15 through May 13, 2010), concluded the surveys contained

"data comparable with that documented in other surveys in the same areas under similar conditions," and closed the

condition report on February 8, 2011. The inspectors reviewed the radiation survey records included in the condition report and noted something the licensee had not addressed. On April 27, 2010, the individual had provided job coverage for work in a locked high radiation area (an area with dose rates greater than 1000 mrem/hour). Survey GG-1004-0660 identified the work area as the 128

-foot auxiliary pipe chase, above the reactor water cleanup pump rooms. Since the individual used by the licensee to provide job coverage and surveillance in a locked high radiation area was not a qualified radiation protection technician, the inspectors identified this as a performance deficiency.

Analysis. The failure to use a qualified radiation protection technician to provide direct continuous coverage of work in a locked high radiation area is a performance deficiency. The finding was more than minor because it was associated with the Occupational Radiation Safety Cornerstone attribute (exposure control) of program and process and affected the cornerstone objective, in that, the failure to use qualified radiation protection technicians to provide job coverage in a high radiation area with dose rates in excess of 1000 mrem/hr had the potential to increase personnel dose. Using the Occupational Radiation Safety Significance Determination Process, the inspectors determined the finding to have very low safety significance because: (1) it was not associated with ALARA planning or work controls, (2)

there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised.

The inspectors identified no cross

-cutting aspect associated with this finding. Enforcement. Technical Specification 5.7.2, controls for high radiation areas with dose

rates greater than 1000 mrem/hour, consists of all the controls for high radiation areas (Technical Specification 5.7.1) plus it requires doors to the area remain locked except during periods of access by personnel under an approved radiation work permit that shall specify the dose rate levels in the immediate work areas and the maximum allowable stay times

for individuals in those areas. In lieu of the stay time specification for the radiation work permit, direct or remote continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure

- 25 - Enclosure control over

the activities being performed within the area. Contrary to the above, during work in an area with dose rates greater than 1000 mrem/hour on April 27, 2010, in lieu of the stay time specification for the radiation work permit, direct or remote surveillance was not made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities being performed within the area. Instead, an unqualified person was assigned to provide surveillance of a locked high radiation on April 27, 2010. The licensee initiated Condition Report CR

-GGN-2011-01045 to document the fact that it failed to identify this performance deficiency as part of the review associated with the closure of Condition Report CR

-GGN-2011-00655. Because the violation was of very low safety significance and it was entered into the licensee's corrective action program, the violation is being treated as a noncited

violation, consistent with the enforcement policy. NCV

05000416/2011002

-04, "Failure to Use a Qualified Radiation Protection

Technician to

Provide Direct Continuous

Coverage of

Work in a Locked High Radiation Area." 2RS02 Occupational ALARA Planning and Controls (71124.02)

a. Inspection Scope

This area was inspected to assess performance with respect to maintaining

occupational individual and collective radiation exposures as

low as is reasonably achievable (ALARA). The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensee's procedures required by technical specifications as criteria for determining compliance. During the inspection, the inspectors interviewed licensee personnel and reviewed the following items:

Site-specific ALARA procedures and

collective exposure history, including the current 3-year rolling average, site

-specific trends in collective exposures, and source-term measurements

ALARA work activity evaluations/postjob reviews, exposure estimates, and exposure mitigation requirements

The methodology for estimating work activity exposures, the intended dose outcome, the accuracy of dose rate and man

-hour estimates, and intended versus actual work activity doses and the reasons for any inconsistencies

Records detailing the historical trends and current status of tracked plant sourc

e terms and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry

Radiation worker and radiation protection technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas

Audits, self

-assessments, and corrective action documents related to ALARA planning and controls since the last inspection

- 26 - Enclosure Specific documents reviewed during this inspection are listed in the

attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure

71124.02-05. b. Findings No findings were identified.

4. OTHER ACTIVITIES

4OA1 Performance Indicator Verification (71151)

.1 Data Submission Issue

a. The inspectors performed a review of the performance indicator data submitted by the licensee for the fourth Quarter 20 10 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual

Chapter 0608, "Performance Indicator Program."

Inspection Scope

This review was performed as part of the inspectors' normal plant status activities and, as such, did not constitute a separate inspection sample.

b. No findings were identified. Findings .2 Unplanned Scrams per 7000 Critical Hours (IE01)

a. The inspectors sampled licensee submittals for the unplanned scrams per 7000 critical hours performance indicator for the period from the first quarter 2010 through the fourth

quarter 2010. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used

definitions and guidance contained in NEI Document 99

-02, "Regulatory Assessment Performance Indicator Guideline," Revision

6. The inspectors reviewed the licensee's operator narrative logs, condition reports, event reports , and NRC integrated inspection reports for the period of January 2010 through December 2010 to validate the accuracy of the submittals. The inspectors also review

ed the licensee's condition report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report. Inspection Scope

These activities constitute completion of

one unplanned scrams per 7000 critical hours sample as defined in Inspection Procedure

71151-05.

- 27 - Enclosure b. No findings were identified.

Findings .3 Unplanned Scrams with Complications (IE02)

a. The inspectors sampled licensee submittals for the unplanned scrams with complications

performance indicator for the period from first quarter 2010 through the fourth quarter 2010. To determine the accuracy of the performance indicator data

reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99

-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors reviewed the licensee's operator narrative logs, condition reports, event reports, and NRC integrated inspection reports for the period of January 2010 through December 2010 to validate the accuracy of the submittals. The inspectors also reviewed the licensee's condition report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

Inspection Scope

These activities constitute completion of

one unplanned scrams with complications sample as defined in Inspection Procedure

71151-05. b. No findings were identified.

Findings .4 Unplanned Power Changes per 7000 Critical Hours (IE03)

a. The inspectors sampled licensee submittals for

the unplanned power changes per 7000 critical hours performance indicator for the period from first quarter 2010 through the fourth quarter 2010.

To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99

-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors reviewed the licensee's operator narrative logs, condition reports, event reports, and NRC integrated inspection reports for the period of January 2010 through December 2010 to validate the accuracy of the submittals. The inspectors also reviewed the licensee's condition report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified

. Specific documents reviewed are described in the attachment to this report. Inspection Scope

These activities constitute completion of

one unplanned transients per 7000 critical hours sample as defined in Inspection Procedure

71151-05.

- 28 - Enclosure b. No findings were identified.

Findings .5 Occupational Exposure Control Effectiveness (OR01)

a. Inspection Scope

The inspectors reviewed performance indicator data for the second quarter of 2010

through the fourth quarter of 2010. The objective of the inspection was to determine the accuracy and completeness of the performance indicator data reported during these periods. The inspectors used the definitions and clarifying notes contained in NEI

Document 99

-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, as criteria for determining whether the licensee was in compliance.

The inspectors reviewed corrective action program records associated with high radiation area (greater than 1 rem/hr) and very high radiation area non

-conformances. The inspectors reviewed radiological, controlled area exit transactions greater than

100 mrem. The inspectors also conducted walkdowns of high radiation areas (greater than 1 rem/hr) and very high radiation area entrances to determine the adequacy of the controls of these areas.

These activities constitute completion of the occupational exposure control effectiveness sample as defined in Inspection Procedure

71151-05. b. Findings No findings were identified.

.6 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (PR01)

a. Inspection Scope The inspectors reviewed performance indicator data for the second quarter of 2010 through the fourth quarter of 2010. The objective of the inspection was to determine the accuracy and completeness of the performance indicator data reported during these periods. The inspectors used the definitions and clarifying notes contained in NEI Document 99

-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, as criteria for determining whether the licensee was in compliance.

The inspectors reviewed the licensee's corrective action program records and selected individual annual or special reports to identify potential occurrences such as

unmonitored, uncontrolled, or improperly calculated effluent releases that may have impacted offsite dose.

- 29 - Enclosure These activities constitute completion of the radiological effluent technical specifications/offsite dose calculation manual radiological effluent occurrences sample as defined in Inspection Procedure

71151-05. b. Findings No findings were identified. 4OA2 Identification and Resolution of Problems (71152)

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection

.1 Routine Review of Identification and Resolution of Problems

a. As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness

of corrective actions. Minor issues entered into the licensee's corrective action program because of the inspectors' observations are included in the attached list of documents reviewed. Inspection Scope

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in

Section 1 of this report.

b. No findings were identified.

Findings .2 Daily Corrective Action Program Reviews

a. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow

-up, the inspectors performed a daily screening of Inspection Scope

- 30 - Enclosure items entered into the licensee's corrective action program. The inspectors accomplished this through review

of the station's daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. No findings were identified. Findings .3 Selected Issue Follow

-up Inspection

a. During a review of items entered in the licensee's corrective action program, the inspectors recognized CR-GGN- 2009-05879 a corrective action item documenting temperature switches for safety related ventilation system. The inspectors reviewed that item as described in Inspection Procedure 71152.02 to verify, in part, licensee evaluation and disposition of operability and reportability issues; consideration of extent of condition and cause, generic implications, common cause, and previous occurrences; classification and prioritization of the problem's resolution commensurate with the safety significance; and identification of corrective actions that were appropriately focused to correct the problem.

Inspection Scope

These activities constitute completion of one in

-depth problem identification and resolution sample as defined in Inspection Procedure 71152

-05. b. No findings were identified.

Findings 4OA3 Event Follow

-up (71153)

.1 (Closed) LER 05000416/2010

-002-00, "Control Room Air Conditioning Inoperability

- Loss of Both Trains"

a. On October 14, 2010, while operating at approximately 100 percent power, the train B

control room air conditioner subsystem tripped on low oil pressure while the train A control room air conditioner subsystem was out of service for maintenance. The control room temperature increased and actions were taken to maintain control room temperatures below the technical specification limit

of 90 degrees Fahrenheit. The two control room air conditioning subsystems were inoperable for 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> and 24 minutes until the train A control room air conditioner was declared operable.

Inspection Scope

The three possible failure mechanisms that the licensee identified in their root cause evaluation were 1) the intermittent failure of the low oil differential pressure switch, 2) the

- 31 - Enclosure intermittent failure of one or more loading/unloading mechanisms, and 3) one or more of the temperature control valves were in an open condition or in a more than desired open position. The licensee also identified a contributing cause of failure to exclude foreign material during maintenance activities on the train B control room air conditioner. Inspectors reviewed the circumstances surrounding the event, the licensee's response

to the event, and the licensee's corrective actions to preclude repetition

. Documents reviewed as part of this inspection are listed in the attachment. The enforcement aspects of this finding are discussed in this section and in Section 1R12. This LER is closed. b. Findings Introduction. The inspectors reviewed a self

-revealing , Green noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, after the licensee failed to determine the

cause and prevent recurrence of a significant condition adverse to quality associated with the train B control room air conditioner compressor tripping due to low oil pressure. Description. On October 14, 2010, the train B control room air conditioner subsystem tripped on low oil pressure while the train A control room air conditioner subsystem was

out of service for maintenance. The control room temperature increased, and actions were taken to maintain control room temperatures below the technical specification limit of 90 degrees Fahrenheit. The licensee determined that the event (i.e., one subsystem inoperable and unavailable for maintenance while the other subsystem was inoperable due to a trip) was reportable to the NRC. The two control room air conditioning subsystems were inoperable for 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> and 24 minutes until the train A control room air conditioner was declared operable.

This was a significant condition because it rendered technical specification required equipment inoperable.

The licensee's corrective actions to address the event involved performing a root cause evaluation. The licensee concluded that the three possible failure mechanisms were 1) an intermittent failure of low oil differential pressure switch, 2) an intermittent failure of one or more loading/unloading mechanisms, and 3) failure of one or more thermal expansion valves. The licensee also concluded that a contributing cause of the event was the failure to exclude foreign material during maintenance activities of the system. The licensee address

ed each of the possible root causes, as well as the contributing cause, since a single root cause could not be determined. The corrective action for the three probable root causes included 1) ensuring that only original differential

pressure switches are used (or a suitable equivalent) for replacement; 2) revising planned

maintenance tasks to included instructions for the loader/unloader disassembly, inspection and reassembly; 3) revising tasks for compressor A and B rebuilds; and 4)

revising compressor preventative maintenance tasks to record the degree of superheat for each thermal expansion valve.

Despite the corrective actions implemented by the licensee, the train B control room air

conditioner compressor again tripped on December 13, 2010, due to low oil pressure. After this trip and upon further evaluation, the licensee performed an additional corrective action that installed an inline suction filter with smaller filtering diameter and

- 32 - Enclosure larger surface area to remove foreign material from the system. The licensee

also modified the operator rounds to obtain daily readings of differential pressure across this new filter and through calculation, determined a differential pressure necessary to change the filter. The condition report

that documented the December 13

th event was closed to the corrective actions associated with the October 14

th compressor trip and the new corrective action associated with the newly installed in line suction filter.

The licensee entered this event into their corrective actions program as condition report

CR-GGN-2010-07315. Since the use of the new inline suction filter

, they have not had any additional trips of the control room air conditioning B.

The April 2011 inspection showed that the filter had reduced foreign material on the compressor suction strainer by

40 percent from the March 2011 inspection. Also in May 2011, the licensee plans to boroscope the evaporation section of the air conditioner to search for any other foreign material. Analysis. The inspectors determined that the failure to take corrective actions to prevent recurrence of the

train B control room air conditioner

compressor tripping due to low oil pressure was a performance deficiency. This finding was more than minor because it was associated with the equipment performance 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. Using Inspection Manual Chapter 0609, "Significance Determination Process," Phase 1 worksheets, the inspectors determined that a Phase 2 estimate was required because the finding represented a loss of system safety function. The plant-specific risk informed notebook does not include the evaluation of risk caused by the loss of cooling to the main control room. Therefore, the senior reactor analyst conducted a Phase 3 analysis.

The analyst noted that understanding the risk affect of control room chillers required a review of the following items:

Loss of offsite power frequency

LOOP): Several alternative methods of cooling control room equipment are available provided offsite power is available. Therefore, the dominant risk impact of essential chillers is during a loss of offsite power. The loss of offsite power frequency documented in the plant

-specific SPAR model is 3.59 x 10

-2/year. Loss of the opposite train probability (P

CH-A): The performance deficiency only affected Train B CRAC. Therefore, the Train A would still be available to cool the

main control room. The generic failure probability for a single train of safety

-related equipment is approximately 3 x 10

-2/demand. Exposure Period (EXP): Although the Train B CRAC system was placed in service without correcting the failure mechanism on November 1, 2010, the

chiller continued to be utilized and run for much of the time until failure on December 13, 2010. The analyst noted that the chiller ran from November 12 until it failed on December 13, 2010. Therefore, the time that the chiller was actually unavailable to perform it's 24

-hour risk significant mission time was

- 33 - Enclosure about 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of its run and the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> it took to repair). This gave an exposure time of 2 days.

Conditional Core Damage Probability (CCDP): In the worst case failure of control room air conditioning would result in main control room abandonment.

The generic CCDP for shutting the reactor down from outside the main control room is approximately 0.1.

The analyst determined that a bounding assessment of the change in core damage LOOP * P CH-A * EXP * CCDP = 3.59 x 10

-2/year * 3 x 10

-2/demand * 2 days/365 days/year * 0.1

= 5.9 x 10

-7 Based on the above bounding analysis, the analyst determined that the change in core damage frequency result was 5.9 x 10-7. This noncited violation was therefore determined to be of very low safety significance (Green).

This finding had a crosscutting aspect in the area of problem identification and resolution

associated with the corrective action program

component because licensee personnel failed to

thoroughly evaluate the multiple failures of the

train B control room air conditioner compressor

. P.1(c) Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," states, in part, that in the case of a significant condition adverse to quality, "measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition." Contrary to the above, plant personnel did not implement corrective actions to preclude repetition of a significant condition adverse to quality associated with the tripping of the train B control room air conditioning compressor due to low oil

pressure. Specifically, on December 13, 2010, the train B control room air conditioner compressor tripped due to low oil pressure after the licensee had a performed a root cause analysis to identify the cause and prevent recurrence of the compressor tripping due to low oil pressure. Because the finding was of very low safety significance and has been entered into the corrective action program as Condition Report CR

-GGN-2010-07315, this violation is being treated as a noncited violation, consistent with the NRC

Enforcement Policy. NCV 05000416/2011002

-05 , "Failure to Prevent Recurrence of Control Room Air Conditioner Compressor Tripping Due to Low Oil Pressure

." .2 Steam Leak in the Containment

a. On November 8, 2010, the inspectors responded to the control room to observe operator response to a steam leak in containment. The newly installed mitigation monitoring system positive displacement pump ejected the cylinder causing an approximate seven gallons per minute reactor coolant leak. The inspectors observed operator actions, control room briefs and overall plant response to the event. The inspectors also Inspection Scope

- 34 - Enclosure observed control room indications used to identify abnormal conditions in the containment building. Documents reviewed for this inspection are listed in the attachment.

b. Findings Introduction.

The inspectors reviewed a self-revealing, Green finding of EN-DC-115, "Engineering Change Process,"

involving the failure to maintain adequate design control measures associated with the installation

of the mitigation monitoring system.

Description.

On November 8, 2010, at approximately 5:30 am, a reactor coolant pressure boundary failure occurred at the skid mounted Online Noble Chemical

- Mitigation Monitoring System pump inside primary containment.

The positive displacement sample pump ejected the pump piston from the housing resulting in an approximate 7 gpm leak of reactor coolant. The leak was not detected for approximately 4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, resulting in the release of approximately 2

,000 gallons of reactor coolant which flashed directly to steam. The steam leak resulted in a reactor recirculation system

flow control valve lockup (due to HPU motor failure) and approximately 15,000 square feet of contaminated area in the primary containment structure

. The inspectors reviewed the mitigation monitoring system modification documentation and found that the design documentation did not appropriately address the design requirements for the installation of th

e mitigation monitoring system pump. The licensee failed to ensure proper validation testing for the pump prior to installation in the plant.

Specifically

, they did not ensure that the pump would be able to withstand the system operating pressures and temperatures in which it was installed. They failed to validate the design, which had a single point vulnerability, that resulted in the piston injecting from the pump and caused the leakage and contamination of the containment. In addition, the inspectors reviewed the root cause analysis of the event and found that the licensee failed to apply the appropriate oversight of the engineering vendor due to weaknesses in the procedure EN

-DC-114, "Vendor Quality Management/Oversight." The licensee entered this event into their corrective actions program as condition report

CR-GGN-2010-07852. The licensee has currently removed the mitigation monitoring system pump from the plant

, and isolated the mitigation monitoring system skid fro m the reactor water cleanup system. They are evaluating the design to make appropriate

changes to ensure a repeat of this event will not occur.

Analysis. The failure to implement adequate design control measures for modifications to the plant

, which impact

ed the reactor coolant pressure boundary

, is a performance deficiency. Specifically procedure EN

-DC-115, "Engineering Change Process," step 5.1[1], requires "during the engineering change development a choice of new technology or application is an error precursor which will need to have defensive functions built into the design, testing and maintenance, including developing in

-house expertise." Contrary to this, the engineering change package that implemented this design change failed to ensure proper validation testing was performed prior to installation in the plant. The finding is more than minor because

it affects the design control attribute of the Barrier Integrity Cornerstone to provide reasonable assurance that physical design barriers

- 35 - Enclosure protect the public from radionuclide releases caused by accidents or events.

Therefore, using inspection Manual Chapter 0609, "Significance Determination Process," Phase 1 Worksheet for LOCA initiators, the inspectors concluded that the finding was of very low safety significance (Green) because the failure of the mitigation monitoring system would not have exceeded technical specifications limits for identified leakage in the reactor coolant syste

m. This finding has a crosscutting aspect in the

area of human performance associated with the work practices componen

t because the licensee failed to adequately oversee the design of the mitigation monitor system

such that nuclear safety is supported. H.4(c) Enforcement. No violation of regulatory requirements occurred. This finding was entered into the licensee's corrective action program as

CR-GGN-2010-07852, and is identified as: FIN 05000416/201

1 00 2-0 6 , "Inadequate Design Control for the Mitigation Monitoring System Modification."

4OA5 Other Activities

1. (Closed) Temporary Instruction (TI) 2515/179, "Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10 CFR 20.2207)"

a. Inspection Scope

An NRC inspection was performed to confirm that the licensee has reported their initial inventories of sealed sources pursuant to 10 CFR 20.2207 and to verify that the National Source Tracking System database correctly reflects the Category

1 and 2 sealed sources in custody of the licensee. Inspectors interviewed personnel and performed the following:

Reviewed the licensee's source inventory

Verified the presence of any Category 1 or 2 sources

Reviewed procedures for and evaluated the effectiveness of storage and handling of sources

Reviewed documents involving transactions of sources

Reviewed adequacy of licensee maintenance, posting, and

labeling of nationally tracked sources

b. Findings While comparing the National Source Tracking System database information, the Licensee's information submittal, and original source certificates, the inspector noted that the licensee erroneously reported information for one of the four sources meeting the reporting criteria. The licensee used original leak test data and submitted the wrong

- 36 - Enclosure serial number and activity date for the source. The licensee reviewed all relevant data and submitted corrected documents within the five business days allowed by

10 CFR 20.2207(g). This finding was considered as an administrative error and of minor safety significance.

4OA6 Meetings Exit Meeting Summary

On February 18, 2011, the inspectors presented the results of

the radiation safety

inspections to Mr. J. Browning, General Plant Manager, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On April 14, 2011, the inspectors presented the inspection results to

M. Perito , Site Vice-President Operations

and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by the licensee and are violations of NRC requirements which meet the criteria of Section 2.3.2 of the NRC Enforcement Policy

for being dispositioned as noncited violation

s. .1 Technical Requirements Manual (TRM) section 6.2.

1 requires that fire detection instrumentation for each fire detection zone shall be operable

and if the required detection system is

inoperable an hourly fire

watch must be established. Contrary to this, on February 9, 201 1 the licensee identified that fire detection instrumentation

for fire zone 2-1 2 had been left in the non

-audible alarm for the main control room on the fire computer when the limiting condition for operations was cleared on December 8, 2010

when zone was returned to operable status. The control room supervisor on February 9, 2011, discovered this condition when entering a fire

-limiting condition for operation for the division 1 diesel generator room to allow welding. The licensee determined that it

had been in non-audible status from December 8, 2010, through February 9, 2011. This issue was documented in the licensee's corrective action program in condition report

CR-GGN-201 1-0 0851. The senior reactor analyst from region IV performed a bounding evaluation of the change in risk caused by this condition. According to the Grand Gulf Updated Final Safety Analysis Report, Fire Zone 2

-12 only contains Division I equipment. A fire that consumed the equipment in the area could not result in a loss of offsite power or other unplanned transient. Given the ignition frequency of the area, the

60-day exposure period, and the conditional core damage probability with the loss of the Division I emergency diesel generator, the analyst calculated that the change in risk

was significantly less than 1E

-6. Therefore, this finding was of very low safety significance (Green).

- 37 - Enclosure

A-1 Attachment

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Benson, Manager (Acting), Radiation Protection

J. Browning, General Plant Manager

D. Coulter, Senior Licensing Specialist

H Farris, Assistant Operation Manager

K. Higgenbotham, Planning and Scheduling

Manager J. Houston, Maintenance Manager

R. Jackson, Licensing

C. Lewis , Manager, Emergency Preparedness

C. Perino, Licensing

Manager M. Perito, Site Vice President of Operations

M. Richey , Director, Nuclear Safety Assurance

F. Rosser, Supervisor, Dosimetry

R. Sumrall, Superintendant, Operations Training

R. Sylvan, Supervisor, Radiation Protection

T. Trichell, Radiation Protection Manager

D. Wiles, Engineering Director

R. Wilson , Manager, Quality Assurance E. Wright, Supervisor, Radiation Protection

NRC Personnel

R. Smith, Senior Resident Inspector

A-2 Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000416/2011 00 2-01 NCV Transient Combustible Stored in the Fire Exclusion Zone

Near the Independent Spent Fuel Storage Installation

(Section 1R05)

05000416/2011 00 2-02 NCV Failure to Update Available Low Pressure Coolant Injection Loops in the Updated Final Safety Analysis Report

(Section 1R12)

05000416/2011 00 2-03 NCV Failure to Demonstrate Maintenance Effectiveness of Train B Control Room Air Conditioner(Section 1R12)

05000416/2011 00 2-04 NCV Failure to Use a Qualified Radiation Protection

Technician to

Provide Direct Continuous Coverage of

Work in a Locked High Radiation Area (Section 2RS01)

05000416/2011 00 2-05 NCV Failure to Prevent Recurrence of Control Room Air Conditioner Compressor Tripping Due to Low Oil Pressure

(Section 4OA3)

05000416/2011 00 2-06 FIN Inadequate Design Control for the Mitigation Monitoring System Modification

(Section 4OA3)

Closed TI 2515/179

TI Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking

System Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10

CFR 20.2207) (Section 4OA5) 05000416/2010

-002-00 LER Control Room Air Conditioning Inoperability

- Loss of Both Trains

(Section 4OA3)

A-3 Attachment

LIST OF DOCUMENTS REVIEWED

Section 1RO1: Adverse Weather Protection

PROCEDURE NUMBER TITLE REVISION ENS-EP-302 Severe Weather Response

11 05-1-02-VI-2 Hurricanes, Tornados, and Severe Weather

113 04-1-01-P41-1 Standby Service Water System

133 04-1-01-N71-1 Circulating Water System

72 04-1-03-A30-1 Cold Weather Protection

20 OTHER NUMBER TITLE DATE SSW Pump Discharge Temperatures

January 6-10, 2011 WORK ORDER WO 52233022

Section 1RO4: Equipment Alignment

PROCEDURE NUMBER TITLE REVISION 9.3-17 - 9.3-25 GG UFSAR 3 07-1-34-C41-C001-1 Standby Liquid Control Pump

10 04-1-01-C41-1 Standby Liquid Control System

119 04-1-01-P75-1 Standby Diesel Generator System

88 04-1-01-P41-1 Standby Service Water System

133 04-1-01-E12-1 System Operating Instructions Residual Heat Removal System 137 04-1-01-E12-1 Residual Heat Removal B

137 04-1-01-E12-1 Residual Heat Removal C

137

A-4 Attachment

PROCEDURE NUMBER TITLE REVISION 04-1-01-E12-1 Residual Heat Removal B Attachment IB

137 04-1-01-E12-1 Residual Heat Removal B Attachment IIIB

137 04-1-01-E12-1 Residual Heat Removal C Attachment IC

137 04-1-01-E12-1 Residual Heat Removal B Attachment VB

137 04-1-01-E12-1 Residual Heat Removal (Interface Valves) Attachment IIE

137 04-1-01-P41-1 Standby Service Water System Attachment IIB

133 04-1-01-P41-1 Standby Service Water System Attachment IIIB

113 OTHER NUMBER TITLE DATE 11-4568 Scaffolding Evaluation Request

February 15, 2001 CALCULATION

NUMBER TITLE DATE 9645 Diesel Generator Building Walls

August 2, 1976 C-C400 SSW CT and Basin (Pump

-House) Tornado and No Earthquake

May 28, 1976

C-0-100 Diesel Generator Bldg. Walls Tornado Wind Load W'

August 2, 1976 WORK ORDER

WO 52256371

WO 00260559 WO 00259801

Section 1RO5: Fire Protection

PROCEDURE NUMBER TITLE REVISION Fire Pre-Plan DG-03 Division II Diesel Generator Room

3 9A-343 - 9A347 GG UFSAR Fire Pre-Plan A-02 RHR A Pump Room 1A103

1

A-5 Attachment

PROCEDURE NUMBER TITLE REVISION Fire Pre-Plan A-03 RCIC Pump Room 1A104

1 Fire Pre-Plan A-04 RHR B Pump Room 1A105

1 9A.5.2.2 Safe Shutdown Equipment

Appendix 9B

Fire Protection Program

CONDITION REPORT

CR-GGN-2011-00862 CR-GGN-2011-01939 CR-GGN-2011-00851 CR-GGN-2011-00455 Section 1RO6: Flood Protection Measures

PROCEDURE NUMBER TITLE REVISION / DATE 9A-336 - 9A338 GG UFSAR 9A.5.59 GG UFSAR FIRE AREA 59

EN-OP-104 Operability Determination Process Immediate Determination For Degraded of Nonconforming Conditions

4 OTHER NUMBER TITLE DATE Russell Daniel Oil Co. Inc. Delivery Date Schedule

February 10, 2011 CONDITION REPORT

CR-GGN-2011-00198 CR-GGN-2011-00562 CR-GGN-2011-00654 WORK ORDER

WO 52281566

WO 52210679 03

WO 52210679 02

WO 52210679 01

WO 00041743

WO 52210679

A-6 Attachment

ENGINEERING CHANGE

EC No. 24971 EC No. 24904

EC No. 24972

Section 1R07:

PROCEDURE NUMBER TITLE REVISION 08-S-03-10 Chemistry Procedure

-Closed Loops

48 OTHER NUMBER TITLE DATE CCE 2006-0002 Commitment Change Evaluation Form

Letter Response to Generic Letter 89

-13; Service

Water System Problems Affecting Safety

-Related Equipment

January 29, 1990 WORK ORDER

WO 00178965 01

WO 00178965 02

WO 00178965 03

Section 1R11: Licensed Operator Requalification Program

OTHER NUMBER TITLE REVISION / DATE GSMS-LOR-WEX03 LOR Training-Double Recirculation Pump Trip/ATWS

January 18, 2011 Rev 17 Turnover and Simulator Differences 2011 Cycle 1 Simulator Training 1 Per Control Room Walkdown, Modifications to TREX L

oad January 7, 2011 Letter Emergency Preparedness January 31, 2011 Simulator Drill Performance Indicators

February 1, 2011

A-7 Attachment

Section 1R12: Maintenance Effectiveness

PROCEDURE NUMBER TITLE REVISION / DATE EN-FP-S-001-Multi Engineering Standard

-Appendix R Emergency Lighting Units

January 10, 2011 07-S-12-143 Big Beam Emergency Light Inspection, Battery Capacity Verification, and Functional Test

2 EN-DC-203 Maintenance Rule Program

1 EN-DC-206 Maintenance Rule (a)(1) Process

1 EN-DC-207 Maintenance Rule Periodic Assessment

1 NMM EN-LI-118 Root Cause Evaluation Report Attachment IV (54 of 54)

12 EN-DC-205 Maintenance Rule Monitoring

2 GG UFSAR Table 7.5

-1 Safety-Related Display Instrumentation

GG UFSAR Table 7.5

-2 Post-Accident Monitoring Instrumentation

GG UFSAR 6.3 Emergency Core Cooling Systems 0 03-1-01-3 Integrated Operating Instructions Plant Shutdown

118 OTHER NUMBER TITLE REVISION / DATE Emergency Lighting

- GGNS Discussion of Recent Activities

Maintenance Rule Expert Panel June 22, 2010 Meeting Minutes Maintenance Rule Expert Panel August 10, 2010 Meeting Minutes Entergy Nuclear

-GGNS Maintenance Rule Program Basis Document, Control Room and Emergency Lighting (Z92) System 0 Z92 Maintenance Rule Database Control Room and Emergency Lighting TM M348X.8001

Midtron 3200

Battery Conductance Tester

A-8 Attachment

OTHER NUMBER TITLE REVISION / DATE VMA97/0181

Emergency Lights

Maintenance Rule Database Information

- Main Control Room Air Conditioning (Z51) System

March 21, 2009 to December 23, 2010 Maintenance Rule Database Z51 Control Room HVAC System EC No.: 27856 Engineering Evaluation

0 Maintenance Rule Program (a)(1) Evaluation and Action Plan Main Control Room Air Conditioning (Z51) System

Agenda for Maintenance

Rule Expert Panel Meeting

February 4, 2010 RHR Heat Exchanger SSW Flow Indication (a)(1)

Status Maintenance Rule Database E12 RHR System

Maintenance Rule Program (a)(1) Evaluation for the Residual Heat Removal (E12/RHR) System CR

-GGN-2009-0754 CA No. 002 Maintenance Rule (a)(1) Evaluation Standby Service Water (P41) System (GR-GGN-2010-00305) Agenda Items from Maintenance Rule Expert Panel Meeting

June 24, 2010 Agenda Items from Maintenance Rule Expert Panel Meeting

June 22, 2010 CONDITION REPORT

CR-GGN -2009-05330 CR-GGN -2010-00381 CR-GGN -2010-04575 CR-GGN -2010-04585 CR-GGN -2010-06346 CR-GGN -2011-00481 CR-GGN -2011-00521 CR-GGN -2011-01212 CR-GGN-2011-01650 CR-GGN-2010-01984 CR-GGN-2011-11505 CR-GGN-2011-01308 CR-GGN-2010-07315 CR-GGN-2009-00842 CR-GGN-2009-00754 GR-GGN-2009-01729 CR-GGN-2009-02477 CR-GGN-2009-03394 CR-GGN-2009-02947 CR-GGN-2009-02848 CR-GGN-2009-03292 CR-GGN-2009-03574 CR-GGN-2009-03592 CR-GGN-2009-04219

A-9 Attachment

CR-GGN-2010-01031 CR-GGN-2009-04048 CR-GGN-2009-05930 CR-GGN-2009-05215 CR-GGN-2009-05932 CR-GGN-2009-05472 CR-GGN-2009-06066 CR-GGN-2009-04733 CR-GGN-2010-00036 CR-GGN-2010-01329 CR-GGN-2011-00789 CR-GGN-2010-07351 CR-GGN-2010-04009 CR-GGN-2010-05892 CR-GGN-2011-00791 CR-GGN-2011-00820 CR-GGN-2011-00985 CR-GGN-2009-01204 CR-GGN-2010-00684 CR-GGN-2010-05290 CR-GGN-2010-01585 CR-GGN-2010-00800 CR-GGN-2010-01474 CR-GGN-2010-01337 CR-GGN-2009-05508 CR-GGN-2010-01320 CR-GGN-2010-01345 CR-GGN-2009-05731 CR-GGN-2009-06174 CR-GGN-2010-02797 CR-GGN-2010-02200 CR-GGN-2010-03655 CR-GGN-2010-04629 CR-GGN-2010-02990 CR-GGN-2010-03241 CR-GGN-2009-00350 CR-GGN-2009-00426 CR-GGN-2009-00846 CR-GGN-2009-01518 CR-GGN-2010-02805 CR-GGN-2010-04015 CR-GGN-2010-03333 CR-GGN-2010-04625 CR-GGN-2010-04255 CR-GGN-2009-05527 CR-GGN-2010-02974 CR-GGN-2010-06137 CR-GGN-2010-05208 CR-GGN-2010-05330 CR-GGN-2010-04686 CR-GGN-2010-04963 CR-GGN-2010-05572 CR-GGN-2010-03650 CR-GGN-2010-06978 CR-GGN-2010-06148 CR-GGN-2010-06150 CR-GGN-2010-05328 CR-GGN-2010-06142 CR-GGN-2011-00403 CR-GGN-2011-00749 CR-GGN-2011-00819 CR-GGN-2011-00850 CR-GGN-2010-06895 CR-GGN-2010-06918 CR-GGN-2011-01212 CR-GGN-2010-05147 WORK ORDER

WO 52255810

WO 52223396

WO 52271013 01

WO 52196016

WO 52220690

Section 1R13: Maintenance Risk Assessment and Emergent Work Controls

PROCEDURE NUMBER TITLE REVISION EN-WM-101 On-line Work Management Process

7 EN-WM-100 Work Request Generation, Screening and Classification

5 EN-WM-101 On-line Work Management Process

8 EN-WM-101 On Line Emergent Work Addition/Deletion Approval Form for the Week of March 7, 2011 7

A-10 Attachment

PROCEDURE NUMBER TITLE REVISION EN-WM-101 On Line Emergent Work Addition/Deletion Approval Form for the Week of February 28, 2011

7 WORK ORDER

WO250074 WO247598 WO52290243

WO52290462

WO52290463

WO52290464

WO70346 WO52291451

WO52291458

WO52291454

WO52291456

WO52291689

WO52291690

WO261213 WO52284287

WO52269835

WO52290236

WO52290463

WO52290464

WO52291844

WO52291454

WO52291456

WO261601 WO250966-02 WO237429 WO256910-01 WO52290639

WO52287735

WO52290638

WO52287736

WO52276935

WO260417 WO260212-02 WO260212-01 WO00219198

WO260529-07 WO52204865

WO260503 WO52243284

WO260529-07 WO52204865

WO52199495

WO255787-01,02,03,04

WO52249417

WO52271012

WO261175 WO259639 WO257881 WO200935-02 WO00257063

WO224859 WO261706 WO255360-08 WO263130 WO261181-01 and 02 WO262143 WO234988-04 WO234992-04 WO52250110

-03 WO234985-04 WO259003-05 WO259005-05 WO259007-05 WO112951-08 WO52270042

WO52259286

WO52275616

WO52288663

WO52290468

WO52270252

WO52291424

WO52270250

WO52291423

WO235034 WO52288844

WO51563342

WO160041 WO52290473

WO52281103

A-11 Attachment

Section 1R15: Operability Evaluations

PROCEDURE NUMBER TITLE REVISION EN-OP-104 Operability Determination Process

4 EN-DC-115 EC No. 20228

0 CALCULATION

NUMBER TITLE REVISION PDS0170B SSW Basin "A" Relief Valve

2 DRAWING NUMBER TITLE REVISION FSK-M-KC187-01C1-Y Design Change Drawing SSW Basin "A" and "B"

8 Design Change Drawing Reinforced Concrete Distribution Support System Tower Elevation 157'

-8" 8 OTHER NUMBER TITLE REVISION / DATE 2007-029 LBDCR Initiation

Grand Gulf Nuclear Station, Unity 1

- Conforming License Amendment to Incorporate the Mitigation Strategies Required by Section B.5.b of the Commission Order EA

- 02 - 026 July 18, 2007

GNRO-2007/00037

Supplementary Response Regarding Implementation Details for the Phase 2 and 3 Mitigation Strategies Grand Gulf Nuclear Station

June 7, 2007

NEI 06-12 B.5.b Phase 2 & 3 Submittal Guideline

Rev 2 December 2006 7-15 GG FSAR Rev 59 9.5-3 GG UFSAR Attachment 9.2

Immediate Determination for Degraded of Nonconforming Conditions CR

-GGN-2011-01512

A-12 Attachment

OTHER NUMBER TITLE REVISION / DATE Attachment 9.5

Operability Evaluation CR

-GGN-2011-00155 NUS Switch Status

CONDITION REPORT

CR-GGN-2011-01173 CR-GGN-2011-00765 CR-GGN-2011-00155 CR-GGN-2011-00766 CR-GGN-2011-00799 CR-GGN-2011-01512 CR-GGN-20 09-06838 CR-GGN-2011-01349 CR-GGN-2011-04701 CR-GGN-2011-00369 CR-GGN-2011-00643 CR-GGN-2011-00647 CR-GGN-2011-00665 CR-GGN-2011-00666 CR-GGN-2011-00667 CR-GGN-2011-00668 CR-GGN-2011-00669 CR-GGN-2011-00670 CR-GGN-2011-00671 Section 1R18: Plant Modifications

PROCEDURE NUMBER TITLE REVISION EN-DC-136 Temporary Modifications

5 EN-LI-102 Corrective Action Process

16 DRAWING NUMBER TITLE REVISION E-1187-007 E31 Leak Detection System RWCU Flow Circuit Computer Input 7 E1165014 Schematic Design Rod Control and Information System Rod Position Information and SCRAM Time Test

13 E1173028 Schematic Design Reactor Protection System Testability

6 M1051A Main and Reheat System

33 OTHER NUMBER TITLE 06-OP-1000-D-0001 Log Data

A-13 Attachment

OTHER NUMBER TITLE CR-GGN-2009-02198 CA 26

CR Periodic Review (initial at 6 months/follow by annual) and/or Long Tem CA Classification Form

CONDITION REPORT

CR-GGN-2009-02198 CR-GGN-2010-0 4451 CR-GGN-2011-0 1231 WORK ORDER

WO00238932

WO00238928

WO00193921

WO00193920

WO002239736

-01 WO002239736

-02 WO002239736

-03 ENGINEERING CHANGE

EC22768 EC22625 EC22635 Section 1R19: Postmaintenance Testing

PROCEDURE NUMBER TITLE REVISION / DATE 06-OP-1E12-Q-0005 LPCI/RHR Subsystem A MOV Functional Test

112 06-OP-1E12-Q-0023 LPCI/RHR Subsystem A Quarterly Functional Test

121 06-0P-1E12-0006 LPCI/RHR System B MOV Functional Test

111 06-OP-1P41-Q-0004 Standby Service Water Loop A Valve AND Pump Operability Test 119 04-1-03-P75-1 Div 1 Diesel Generator Unexcited Run 7 06-OP-1P75-M-001 Data Sheet III Standby Diesel Generator 11 Functional Test

February 12, 2011 07-S-12-40 General Cleaning and Inspection of Rotating Electrical Equipment

2 07-S-12-146 General Maintenance Instruction Motor Off Line Diagnostic

1

A-14 Attachment

PROCEDURE NUMBER TITLE REVISION / DATE Data Acquisition

07-S-12-55 Insulation Resistance Testing

10 06-IC-1E22-Q-0004 HPCS System Flow Rate

- Low (Bypass) Functional Test

104 OTHER NUMBER TITLE DATE RPS Motor GEN B

- MCE Stator

February 2, 2011 HPCS Min Flow Valve Position

March 18, 2011 DRAWING NUMBER TITLE DATE BRKR No. 52

-142229 IC71SOOIOB

BRKR No. 52

-142229 IC7IS003B (Local C71

-S003B) BRKR No. 52

-142229 IC7IS003D (Local C71

-S003D) Timeline for Events leading to NRC Notification Call on HPCS March 18, 2011 CONDITION REPORT CR-GGN-2011-00945 WORK ORDER

WO52311451

WO52311569

WO52285575

WO00251847

WO52224645

WO52223715

WO00262318

WO00259110

-01 WO00259110

-03 WO00237650

-01 WO00237650

-04 WO00237650

-05 WO00237650

-06 WO52304041

WO00270205

-01

A-15 Attachment

WO00270205

-02 Section 1R22: Surveillance Testing

PROCEDURE NUMBER TITLE REVISION 06-CH-1B21-O-0002 Reactor Coolant Routine Chemistry

-Sample February 23, 2011 106 06-CH-1B21-O-0002 Reactor Coolant Routine Chemistry

-Sample February 18, 2011 106 06-CH-1B21-O-0002 Plant Operations Manual

-Reactor Coolant Routine Chemistry

106 06-CH-1B21-W-0008 Reactor Coolant Dose Equivalent Iodine

104 06-OP-1C61-R-0002 Functional Checks with E51 Valves

109 06-OP-1P75-M-0001 Standby Diesel Generator Functional Test

132 06-IC-1D17-R-0010 Fuel Handling Area Ventilation Exhaust High High Radiation Electronics Time Response Test

102 04-1-01-P81-1 High Pressure Core Spray Diesel Generator

67 06-OP-1P81-M-0002 HPCS Diesel Generator 13 Functional Test

123 EN-OP-109 Conduct of Operations

2 OTHER NUMBER TITLE DATE Drywell Unidentified Leakage Rate vs. "A" Recirc Seal Delta

T June 2010- January 2011

CONDITION REPORT

CR-GGN-2011-01932 CR-GGN-2011-01868 WORK ORDER

WO52271012

WO52289870

WO52288401

WO52261837

WO52307262

WO00270146

-01

A-16 Attachment

Section 1EP6: Drill Evaluation

OTHER NUMBER TITLE DATE Emergency Facility Log

March 3, 2011

Repair and Corrective Action Table

March 3, 2011

Emergency Notification Form 1

-7 for EP Drill

March 3, 2011

GGNS 2011 1

st Quarter ERO Training Drill

CONDITION REPORT

CR-GGN-2011-01481 CR-GGN-2011-01486 CR-GGN-2011-01495 CR-GGN-2011-01499 CR-GGN-2011-01510 CR-GGN-2011-01519 CR-GGN-2011-01520 CR-GGN-2011-01522 Section 2RS01: Radiological Hazard Assessment and Exposure Controls

PROCEDURES

NUMBER TITLE REVISION EN-RP-100 Radiation Worker Expectations

6 EN-RP-101 Access Control for Radiologically Controlled Areas

5 EN-RP-102 Radiological Control

2 EN-RP-106 Radiological Survey Documentation

2 01-S-08-1 Administration of the GGNS Radiation Protection Program

105 01-S-08-6 Radioactive Source Control

113 08-S-02-50 Radiological Surveys and Surveillances

116 AUDITS, SELF

-ASSESSMENTS, AND SURVEILLANCES

NUMBER TITLE DATE LO-GLO-2010-93 Pre-NRC Rad Hazard Assessment and Exposure Controls Assessment

December 16, 2010

CONDITION REPORTS

CR-GGN-2011-00183 CR-GGN-2011-00551 CR-GGN-2011-00655 CR-GGN-2011-00926 CR-GGN-2011-00740

A-17 Attachment

RADIOLOGICAL SURVEY

NUMBER TITLE DATE GG-1102-0146 Routine Daily Surveys

February 15, 2011

GG-1012-0083 208 CTMT Entire Elevation

December 7, 2010

GG-1102-0152 208 CTMT Entire Elevation

February 15, 2011

GG-1012-0118 119 AB RHR A Room

December 9, 2010

GG-1012-0086 119 AB RHR A Room

February 7, 2011

GG-1011-0254 119 AB RHR B Room

November 30, 2010

GG-1101-0156 119 AB RHR B Room

January 16, 2011

GG-1011-0064 93 Aux RHR C & ADHR Hx Rooms

November 6, 2010

GG-1102-0044 93 Aux RHR C & ADHR Hx Rooms

February 3, 2011

GG-1011-0018 119 Aux Piping Penetration & Valve Room

November 2, 2010

GG-1102-0041 119 Aux Piping Penetration & Valve Room

February 3, 2011

GG-1011-0063 93 Aux HPCS Pump Room

November 6, 2010

GG-1102-0042 93 Aux HPCS Pump Room

February 3, 2011

RADIATION WORK PERMITS

NUMBER TITLE 20101005 Tours and Inspections into all areas

20111054 Locked High Radiation Area Entries for Plant/System

Investigations, Valve Manipulations, Tagouts, and Misc.

Activities

20111058 Maintenance in HRA /HCA

& Above Section 2RS02: Occupational ALARA Planning and Controls

PROCEDURES

NUMBER TITLE REVISION EN-RP-105 Radiological Work Permits

9 EN-RP-110 ALARA Program

7 AUDITS, SELF

-ASSESSMENTS, AND SURVEILLANCES

NUMBER TITLE DATE LO # LO-GLO-2010-00094 Pre-NRC Inspection for ALARA Planning and Controls

-Assessment

Nove mber 9, 2010

CONDITION REPORTS

A-18 Attachment

CR-GGN-2011-00425 CR-GGN-2011-00425 CR-GGN-2010-06335 RADIATION WORK PERMIT PACKAGES

NUMBER TITLE 2010-1402 Refuel Floor High Water Activities

2010-1403 Reactor Disassemble/Reassemble

2010-1508 Under Vessel Activities

2010-1530 B Recirc Pump Replacement

2010-1534 B21F011B Stem Replacement

Section 4OA1: Performance Indicator Verification

PROCEDURE NUMBER TITLE REVISION EN-LI-114 1 st Quarter 2010 Unplanned Scrams per 7,000 Critical Hours 4 EN-LI-114 2 nd Quarter 2010 Unplanned Scrams per 7,000 Critical Hours 4 EN-LI-114 3 rd Quarter 2010 Unplanned Scrams per 7,000 Critical Hours 4 EN-LI-114 4 th Quarter 2010 Unplanned Scrams per 7,000 Critical Hours 4 EN-LI-114 1 st Quarter 2010 Unplanned Scrams with Complications

4 EN-LI-114 2 nd Quarter 2010 Unplanned Scrams with Complications

4 EN-LI-114 3 rd Quarter 2010 Unplanned Scrams with Complications

4 EN-LI-114 4 th Quarter 2010 Unplanned Scrams with Complications

4 EN-LI-114 1 st Quarter 2010 Unplanned Power Changes per 7,000 Critical Hours

4 EN-LI-114 2 nd Quarter 2010 Unplanned Power Changes per 7,000 Critical Hours

4 EN-LI-114 3 rd Quarter 2010 Unplanned Power Changes per 7,000 Critical Hours

4 EN-LI-114 4 th Quarter 2010 Unplanned Power Changes per 7,000 Critical Hours

4

A-19 Attachment

OTHER NUMBER TITLE January 2010 Core Thermal Power

February 2010 Core Thermal Power

March 2010 Core Thermal Power

April 2010 Core Thermal Power

May 2010 Core Thermal Power

June 2010 Core Thermal Power

July 2010 Core Thermal Power

August 2010 Core Thermal Power

September 2010 Core Thermal Power

October 2010 Core Thermal Power

November 2010 Core Thermal Power

December 2010 Core Thermal Power

Section 4OA2: Identification and Resolution of Problems

OTHER NUMBER TITLE DATE GGNS Position on Riley Temperature Switch Replacement

Maintenance Rule Program Functional Failures-Riley Temperature Switches

NUS Switch Status

February 2, 2011 Riley History Discussion by Lee Eaton

Riley History Presentation to 2009 PInR

CONDITION REPORT

CR-GGN-2009-05879

A-20 Attachment

Section 4OA3: Event Follow

-Up PROCEDURE NUMBER TITLE REVISION EN-DC-167 Classification of Structures, Systems, and Components

3 EN-HU-103 Human Performance Error Reviews for CR

-GGN-2010-7877 4 EN-DC-115 Engineering Change Process

11 DRAWINGS NUMBER TITLE REVISION M-1127A Piping and Instrumentation

Diagram Noblechem Monitoring

System 0 M-1081B Control Rod Drive Hydraulic System

28 M-1078A Reactor Recirculation System Unit 1

33 M-1079 Reactor Water Clean

-up System Unit 1

46 M-1069A Process Sampling System Unit 1

24 OTHER NUMBER TITLE DATE Root Cause Evaluation Report

-Control Room Air Conditioner B Trip (Event Date 10

-14-2010) October 16, 2010 GNRO-2010/00077

LER 2010-002-00Control Room Air Conditioning

December 13, 2010 Root Cause Evaluation Report Mitigation Monitor Durability Monitor Pump Failure

November 8, 2010 MMS Skid Piping/Component Design Basis

Compliance with NRC Regulatory Guide 1.26

CONDITION REPORT

CR-GGN-2010-07315 CR-GGN-201 0-08580 CR-GGN-2010-07852 ENGINEERING CHANGE

A-21 Attachment

EC13135 EC13132 EC13138 Section 4OA5 Temporary Instruction 2515/17

9 PROCEDURES

NUMBER TITLE REVISION EN-RP-143 Source Control

7 MISCELLANEOUS DOCUMENTS

TITLE DATE National Source Tracking System Annual Inventory Reconciliation Report

2010 National Source Tracking System Annual Inventory Reconciliation Report

2011 Section 4OA7: Licensee

-Identified Violations

CONDITION REPORT

CR-GGN-201 1-0 0851