ML20127J013

Integrated Inspection Report 05000416/2020001

ML20127J013
Person / Time
Site:	Grand Gulf
Issue date:	05/06/2020
From:	Jason Kozal NRC/RGN-IV/DRP/RPB-C
To:	Emily Larson Entergy Operations
References
IR 2020001
Download: ML20127J013 (23)

See also: IR 05000416/2020001

Text

May 6, 2020

Mr. Eric Larson

Site Vice President

Entergy Operations, Inc.

Grand Gulf Nuclear Station

P.O. Box 756

Port Gibson, MS 39150

SUBJECT: GRAND GULF NUCLEAR STATION - INTEGRATED INSPECTION

REPORT 05000416/2020001

Dear Mr. Larson:

On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at Grand Gulf Nuclear Station. On April 7, 2020, the NRC inspectors discussed the results of

this inspection with you and other members of your staff. The results of this inspection are

documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding

involved a violation of NRC requirements. We are treating this violation as a non-cited violation

(NCV) consistent with Section 2.3.2 of the Enforcement Policy.

A licensee-identified violation which was determined to be of very low safety significance is also

documented in this report. We are treating this violation as a non-cited violation (NCV)

consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance of the violations documented in this inspection

report, you should provide a response within 30 days of the date of this inspection report, with

the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document

Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator,

Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Grand Gulf

Nuclear Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the

NRC Resident Inspector at Grand Gulf Nuclear Station.

E. Larson 2

This letter, its enclosure, and your response (if any) will be made available for public inspection

and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document

Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public

Inspections, Exemptions, Requests for Withholding.

Sincerely,

Jason W. Digitally signed by Jason

W. Kozal

Kozal Date: 2020.05.06 16:04:18

-05'00'

Jason W. Kozal, Chief

Reactor Projects Branch C

Division of Reactor Projects

Docket No. 05000416

License No. NPF-29

Enclosure:

As stated

cc w/ encl: Distribution via LISTSERV

ML20127J013

Non-Sensitive Publicly Available

SUNSI Review

Sensitive Non-Publicly Available

OFFICE SRI:DRP/C RI:DRP/C BC:DRS/EB1 BC:DRS/EB2 BC:DRS/OB

NAME TSteadham MThomas VGaddy NTaylor GWerner/GEW

DATE 4/22/2020 04/23/2020 04/23/2020 04/22/2020 04/22/2020

OFFICE BC:DRS/RCB TL:DRS/IPAT BC:DNMS/RIB SPE:DRP/C BC:DRP/C

NAME MHaire AAgrawal ANA GWarnick GGW CYoung JKozal

DATE 04/22/2020 04/27/2020 04/23/2020 04/22/2020 05/06/2020

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000416

License Number: NPF-29

Report Number: 05000416/2020001

Licensee: Entergy Operations, Inc.

Facility: Grand Gulf Nuclear Station

Location: Port Gibson, MS

Inspection Dates: January 1, 2020 to March 31, 2020

Inspectors: I. Anchondo-Lopez, Reactor Inspector

D. Antonangeli, Health Physicist

M. Chambers, Physical Security Inspector

N. Greene, PhD, Senior Health Physicist

J. Melfi, Project Engineer

T. Steadham, Senior Resident Inspector

M. Thomas, Resident Inspector

C. Young, Senior Project Engineer

Approved By: Jason W. Kozal, Chief

Reactor Projects Branch C

Division of Reactor Projects

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees

performance by conducting an integrated inspection at Grand Gulf Nuclear Station, in

accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs

program for overseeing the safe operation of commercial nuclear power reactors. Refer to

https://www.nrc.gov/reactors/operating/oversight.html for more information. A licensee-

identified non-cited violation is documented in report Section 71153.

List of Findings and Violations

Failure to Follow Procedures with an Improper Entry into a High Radiation Area

Cornerstone Significance Cross-Cutting Report

Aspect Section

Occupational Green [H.11] - 71124.01

Radiation Safety NCV 05000416/2020001-01 Challenge the

Open/Closed Unknown

The inspectors reviewed a self-revealed Green finding and associated non-cited violation of

Technical Specification 5.4.1 for a failure to follow procedures, which resulted in an improper

entry into a high radiation area. Specifically, on March 3, 2020, a worker received a dose rate

alarm after entering a high radiation area in an overhead section of the drywell without first

contacting radiation protection or receiving a briefing to be aware of the actual dose rates in

the area, as required by radiation protection procedures and the radiological work permit.

Additional Tracking Items

Type Issue Number Title Report Section Status

LER 05000416/2016009-01 Entry into Mode of 71153 Closed

Applicability with the

Oscillation Power Range

Monitor Upscale Settings

Incorrectly Set

LER 05000416/2018008-00 Unplanned System Actuation 71153 Closed

(Diesel Generator) Caused

by Inadvertently Opening the

Wrong Fuse Drawer

LER 05000416/2017-007-01 Engineered Safety Features 71153 Closed

System Actuations due to

the Loss of Engineered

Safety Features

Transformer 11

2

PLANT STATUS

Grand Gulf Nuclear Station, Unit 1, began this inspection period at 95 percent reactor power.

On January 3, 2020, power was lowered to 65 percent for control rod pattern improvement. The

unit was returned to 98 percent power on January 8, 2020. On January 9, 2020, power was

lowered to 71 percent for a rod pattern improvement. The unit returned to rated thermal power

on January 10, 2020. On February 22, 2020, the unit was shut down for refueling outage 22

and remained shut down for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in

effect at the beginning of the inspection unless otherwise noted. Currently approved

IPs with their attached revision histories are located on the public website at

http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.

Samples were declared complete when the IP requirements most appropriate to the inspection

activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor

Inspection Program - Operations Phase. From January 1 - March 19, 2020, the inspectors

performed plant status activities described in IMC 2515, Appendix D, Plant Status, and

conducted routine reviews using IP 71152, Problem Identification and Resolution. The

inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel to assess licensee performance and compliance with Commission rules and

regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President

of the United States on the public health risks of the coronavirus (COVID-19), resident

inspectors were directed to begin telework and to remotely access licensee information using

available technology. During this time the resident inspectors performed periodic site visits

each week and during that time conducted plant status activities as described in IMC 2515,

Appendix D; and observed risk-significant activities when warranted. In addition, resident and

regional baseline inspections were evaluated to determine if all or a portion of the objectives

and requirements stated in the IP could be performed remotely. If the inspections could be

performed remotely, they were conducted per the applicable IP. In the cases where it was

determined the objectives and requirements could not be performed remotely, management

elected to postpone and reschedule the inspection to a later date.

REACTOR SAFETY

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) Residual heat removal pump C while in cooldown on February 27, 2020

(2) Residual heat removal A while in shutdown cooling on March 2, 2020

3

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the

reactor core isolation cooling system during the Division 3 maintenance outage on

January 8, 2020.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a

walkdown and performing a review to verify program compliance, equipment functionality,

material condition, and operational readiness of the following fire areas:

(1) Emergency diesel generator building on February 27, 2020

(2) Fire water pump house on February 28, 2020

(3) Residual heat removal A pump room on March 4, 2020

(4) Reactor core isolation cooling room on March 4, 2020

(5) Division 1 standby service water pump room on March 5, 2020

(6) Residual heat removal B pump room on March 9, 2020

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Division 3 emergency diesel generator jacket water heat exchanger A and B

inspections and cleaning, Work Orders 52791443 and 52790008, on January 7, 2020

71111.08G - Inservice Inspection Activities (BWR)

BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding

Activities (IP Section 03.01) (1 Sample)

(1) The inspectors verified that the reactor coolant system boundary, reactor vessel

internals, risk-significant piping system boundaries, and containment boundary were

appropriately monitored for degradation and that repairs and replacements were

appropriately fabricated, examined, and accepted by reviewing the following activities

from March 2-5, 2020:

03.01.a - Nondestructive Examination and Welding Activities.

1. Ultrasonic Examination

a. Weld 1B21G025W17, Feedwater System - Pipe-to-Flued Head

circumferential weld

b. Weld 1B21G026W1, Feedwater System - Pipe-to-Flued Head

circumferential weld

4

c. 1B21F028D, Feedwater System - Bolt/Stud ultrasonic inspection

d. 1B21G026W4, Feedwater System - Valve-to-Pipe circumferential weld

e. N02C-IR, Reactor Coolant System - Inlet Nozzle to Reactor Pressure

Vessel Inner Radius Weld

Problem Identification and Resolution

The inspector reviewed 18 notifications that dealt with inservice inspections issues

and found that items were entered into the corrective action program at the

appropriate level and adequately addressed.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(2 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the control

room during control rod sequence exchange on January 3, 2020.

(2) The inspectors observed and evaluated licensed operator performance in the control

room during shutdown for Refueling Outage 22 on February 22, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following

structures, systems, and components remain capable of performing their intended function:

(1) Reactor core isolation cooling 10-year overhaul inspection on March 6, 2020

(2) Reactor core isolation cooling maintenance rule review on March 25, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the

following planned and emergent work activities to ensure configuration changes and

appropriate work controls were addressed:

(1) Risk management for the Division 3 maintenance outage during the week of

January 6, 2020

(2) Outage risk management during the week of March 9, 2020

(3) Risk management while residual heat removal A in shutdown cooling on

March 6, 2020

(4) Foreign material exclusion risk to reactor core during fuel movement on

March 5, 2020

(5) Yellow outage risk management during recirculation pump B seal replacement and

control rod drive mechanism removal on March 15, 2020

5

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the

following operability determinations and functionality assessments:

(1) Reactor pressure and turbine control valve oscillations at 87 percent reactor power on

January 24, 2019

(2) Scram discharge volume vent and drain valves 1C11F010 and 1C11F011 after failure

to meet surveillance test procedure acceptance criteria on February 12, 2020

(3) Seismic qualification of jet pump plugs, Engineering Change 86247, on

March 31, 2020

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) New procedure issuance: Procedure 02-S-01-45, "Water Inventory Control,"

Revision 0, on February 28, 2020

(2) Engineering Change 85565 replacement of the Division 3 emergency diesel

generator speed switch following its failure on March 31, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated the following post maintenance test activities to verify system

operability and functionality:

(1) Division 3 emergency diesel generator post maintenance test following an extended

maintenance outage on January 10, 2020

(2) Division 3 emergency diesel generator speed switch and mag pickup functional post

maintenance test following replacement on January 20, 2020

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated outage-related activities from February 22, 2020,

through March 31, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01) (3 Samples)

(1) Fire protection system testing on March 3, 2020

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(2) Division 2 emergency core cooling system testing on March 26, 2020

(3) Containment electrical penetration local leak-rate test on March 4, 2020

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Standby liquid control pump B quarterly inservice test on January 16, 2020

Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)

(1) Suppression pool water level penetrations local leak-rate test on March 5, 2020

FLEX Testing (IP Section 03.02) (1 Sample)

(1) 1FLEXS010 480 V battery charger emergency diesel generator annual operational

test on January 14, 2020

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identified the magnitude and extent of

radiation levels and the concentrations and quantities of radioactive materials and

how the licensee assessed radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated radiological protection-related instructions to plant workers.

Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)

The inspectors evaluated licensee processes for monitoring and controlling contamination

and radioactive material.

(1) The inspectors observed workers donning and doffing personal protection equipment

at the contaminated drywell entry/exit point.

(2) The inspectors observed the actions of workers while performing tasks in the

contaminated areas of the drywell during the refueling outage.

(3) The inspectors observed the radiation protection staff perform surveys of potentially

contaminated material leaving the radiologically controlled area (RCA) and workers

monitored via the personnel contamination monitors as they exited the RCA during

the refueling outage.

7

Radiological Hazards Control and Work Coverage (IP Section 03.04) (5 Samples)

The inspectors evaluated in-plant radiological conditions during facility walkdowns and

observation of radiological work activities.

(1) Radiation Work Permit (RWP) 2020-1502, "Drywell Coordinator, Safety and NRC

Walkdowns/Tours in the Drywell"

(2) RWP 2020-1509, "General Decon Activities and Support for the Drywell"

(3) RWP 2020-1510, "Visually Inspect/Remove/Test/Replace Snubbers in RF-22"

(4) RWP 2020-1511, "General Maintenance in the Drywell During RF-22"

(5) RWP 2020-1915, "Emergent Work for Maintenance, Tours and Inspections"

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)

The inspectors evaluated licensee controls of the following High Radiation Areas and Very

High Radiation Areas:

(1) Turbine Building Areas (87-foot level and 133-foot level)

(2) AUX Building Areas (128-foot level, 180-foot level, 208-foot level)

(3) Containment Areas (161-foot level, 170-foot level, 208-foot level)

(4) Offgas Charcoal Vault Area (93-foot level)

(5) Radwaste Building Reactor Water Cleanup Phase Separator Decay Tank Area

(118-foot level)

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP

Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician

performance as it pertains to radiation protection requirements.

71124.02 - Occupational ALARA Planning and Controls

Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (4 Samples)

The inspectors evaluated the licensees communication of as low as is reasonably

achievable (ALARA) and radiological work controls for the following work activities:

(1) RWP 2020-1502, "Drywell Coordinator, Safety and NRC Walkdowns/Tours in the

Drywell"

(2) RWP 2020-1509, "General Decon Activities and Support for the Drywell"

(3) RWP 2020-1510, "Visually Inspect/Remove/Test/Replace Snubbers in RF-22"

(4) RWP 2020-1915, "Emergent Work for Maintenance, Tours and Inspections"

Radiation Worker Performance (IP Section 03.04) (1 Sample)

The inspectors evaluated radiation worker and radiation protection technician performance

during:

(1) The inspectors evaluated the implementation of ALARA techniques for work activities

during Refueling Outage 22.

8

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (1 Sample)

(1) January 1, 2019 - December 31, 2019

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)

(1) January 1, 2019 - December 31, 2019

BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)

(1) January 1, 2019 - December 31, 2019

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) July 1, 2019 - December 31, 2019

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual

Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample

(IP Section 02.16) (1 Sample)

(1) July 1, 2019 - December 31, 2019

71153 - Follow-up of Events and Notices of Enforcement Discretion

Event Report (IP Section 03.02) (3 Samples)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000416/2016-009-01, Entry into Mode of Applicability with the Oscillation

Power Range Monitor Upscale Settings Incorrectly Set (ADAMS Accession

No. ML17228A275). The inspection conclusions associated with this LER are

documented in this report as a licensee-identified non-cited violation in the Inspection

Results.

(2) LER 05000416/2017-007-01, Engineered Safety Features System Actuations due to

the Loss of Engineered Safety Features Transformer 11 (ADAMS Accession

No. ML18346A393). The inspectors determined that the licensee's cause evaluation

associated with the issue identified that the licensee's procedures for conducting

Tan-Delta cable testing had previously failed to include a requirement to perform

cable shielding continuity testing. This performance deficiency was identified by the

licensee as being associated with a possible missed opportunity to identify cable

degradation prior to failure (not as being the direct cause of this event). The

inspectors determined that the safety significance associated with this issue was not

more than very low safety significance (Green). The testing of cables associated with

an offsite power circuit was a nonsafety-related activity. The inspectors did not

identify a violation of NRC requirements.

9

(3) LER 05000416/2018-008-00, Unplanned System Actuation (Diesel Generator)

Caused by Inadvertently Opening the Wrong Fuse Drawer (ADAMS Accession

No. ML18187A402). The inspection conclusions associated with this LER are

documented in this report as a minor violation in the Inspection Results.

INSPECTION RESULTS

Failure to Follow Procedures with an Improper Entry into a High Radiation Area

Cornerstone Significance Cross-Cutting Report

Aspect Section

Occupational Green [H.11] - 71124.01

Radiation Safety NCV 05000416/2020001-01 Challenge the

Open/Closed Unknown

The inspectors reviewed a self-revealed Green non-cited violation of Technical

Specification 5.4.1 for a failure to follow procedures, which resulted in an improper entry into

a high radiation area. Specifically, on March 3, 2020, a worker received a dose rate alarm

after entering a high radiation area in an overhead section of the drywell without first

contacting radiation protection or receiving a briefing to be aware of the actual dose rates in

the area, as required by radiation protection procedures and the radiological work permit.

Description: On March 3, 2020, the licensee briefed two workers for entry into the drywell to

identify some snubber components. The briefing informed the workers that they would enter

a maximum general area dose rate of 20 millirem per hour on their job travel path and work

area. However, one of the workers climbed into a normally inaccessible overhead piping

area of the drywell to identify the serial number on a snubber, causing his self-reading

dosimeter (SRD) to alarm unexpectedly. His SRD recorded a maximum dose rate of

802 millirem per hour; the dose rate alarm set-point was 300 millirem per hour. The individual

was signed onto Task 1 of radiation work permit (RWP) 2020-1510. Task 1 was a high

radiation area task, but the worker had not been briefed for entry into the specific overhead

area within the high radiation area. Once the worker identified the alarm, the individual

climbed down from the overhead area, informed his co-worker, and they both exited the RCA

to contact radiation protection (RP).

The RAD Worker Instructions section of RWP 2020-1510, Task 1, included the following

statements:

Be aware of and stay away from Hot spots/pipes

Contact RP [radiation protection] for High Radiation Area entry requirements

Contact RP prior to work in normally inaccessible area for current radiological

conditions and protective requirements

Procedure EN-RP-101, Access Control for Radiologically Controlled Areas, Revision 14,

Section 5.4, required a brief of personnel entering high radiation areas on the radiological

conditions, and access was allowed only after dose rates in the area were determined and

entry personnel were made aware of them.

Procedure EN-RP-100, Radiation Worker Expectations, Revision 12, Section 5.3 [4], stated

that No entry to areas above seven [7] feet is permitted without prior permission from

[radiation protection] RP. The overhead piping area entered was above 7 feet from the floor

level and was normally inaccessible and not typically surveyed. Also, in this procedure,

10

Section 5.3 [19] stated, in part, that to enter a high radiation area, the radiation worker must

be briefed and sign on the appropriate RWP. Section 5.4 [1] stated, in part, Compliance with

an RWP is a legal requirement. Failure to comply could result in NRC violation.

As allowed by procedure, the overhead area the worker entered had not been surveyed or

posted by RP prior to his entry, as there were no work plans for this area and it was deemed

inaccessible. After the dose rate alarm, a follow-up survey identified dose rates in the

overhead piping area, near the snubber, as approximately 3500 millirem per hour on contact

and 800 millirem per hour at 30 cm. The RP staff then posted the overhead as an area with

elevated dose rates. The licensee believes the individual utilized a nearby ladder to access

the overhead area. The ladder was not posted as Contact RP prior to working or climbing

above 7 feet or controlled, as required by licensee Procedure EN-RP-108, Radiation

Protection Posting.

Corrective Actions: The licensee assessed this issue and implemented multiple immediate

corrective actions. Some of the actions taken included:

All involved parties were interviewed and coached

The individual was restricted from the RCA and placed in the licensees performance

management process

The occurrence was placed in the Site Outage Status Report to inform all licensee

staff of the requirements to follow RWP instructions and licensee procedures

Corrective Action References: This issue was placed into the corrective action program as

Condition Report CR-GGN-2020-02586.

Performance Assessment:

Performance Deficiency: A radiation worker failed to follow procedures and made an

improper entry into a high radiation area.

Screening: The inspectors determined the performance deficiency was more than minor

because it was associated with the program and process attribute of the Occupational

Radiation Safety Cornerstone and adversely affected the cornerstone objective to ensure the

adequate protection of the worker health and safety from exposure to radiation from

radioactive material during routine civilian nuclear reactor operation. Specifically, the failure

to follow requirements involving radiological controls had the potential to increase the

individuals dose. In addition, the inspectors reviewed NRC Inspection Manual Chapter 0612,

Appendix E, Examples of Minor Issues, to inform the more-than-minor determination.

Although Example 6.g was similar, there were no current examples that appropriately fit the

consequences of this occurrence. The failure to follow procedural requirements and making

an improper entry into the overhead area, within the high radiation area, resulted in an

exposure of roughly 40 times the general area dose rates for which the individual was briefed.

Significance: The inspectors assessed the significance of the finding using Inspection

Manual Chapter 0609, Appendix C, Occupational Radiation Safety SDP. The inspectors

determined the finding to be of very low safety significance (Green) because (1) it was not

associated with as low as is reasonably achievable (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.

11

Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with

uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, the

worker failed to stop and assess the radiological conditions he may enter prior to entering the

overhead area in the drywell with elevated dose rates, resulting in a dose rate alarm.

Licensee procedures require workers to adhere to RWP requirements, which required RP

approval to enter the overhead area. This enables RP to establish area dose rates and

controls, as overhead areas are not routinely surveyed or accessible.

Enforcement:

Violation: Technical Specification 5.4.1 requires, in part, that procedures be written,

implemented, and established for those areas recommended in Regulatory Guide 1.33,

Appendix A, Revision 2, 1978. Section 7(e) of this appendix requires RP procedures.

Procedure EN-RP-100, Radiation Worker Expectations, Revision 12, Section 5.3 [4], stated

that no entry to areas above 7 feet was permitted without prior permission from RP.

Contrary to the above, on March 3, 2020, an individual failed to receive permission from RP

prior to entering an area above 7 feet, resulting in an improper entry into a high radiation area

and a dose rate alarm of 802 millirem per hour.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

Licensee-Identified Non-Cited Violation 71153

This violation of very low safety significance was identified by the licensee and has been

entered into the licensee corrective action program and is being treated as a non-cited

violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Technical Specification 3.3.1.1, Reactor Protection System (RPS)

Instrumentation, required Action L, requires that thermal power be reduced to less than

16.8 percent rated thermal power within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if action has not been initiated to implement

the manual backup stability protection (BSP) regions defined in the Core Operating Limits

Report (COLR) in accordance with required Actions J.1 and K.1 after one or more required

channels of the oscillation power range monitor (OPRM) upscale function has been

inoperable for longer than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Contrary to the above, on March 27, 2016, the licensee failed to reduce thermal power to less

than 16.8 percent rated thermal power within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> when action had not been initiated to

implement the manual BSP regions defined in the COLR in accordance with required

Actions J.1 and K.1 after one or more required channels of the OPRM upscale function had

been inoperable for longer than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Specifically, the unit was operated at or above

16.8 percent rated thermal power without the OPRM function being calibrated to the

appropriate setpoints as required by technical specifications.

Significance/Severity: Green. The performance deficiency associated with this non-cited

violation was determined to be more than minor because it was associated with the design

control 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 (i.e., core damage).

Specifically, the failure to calibrate the OPRM function to the appropriate setpoints resulted in

an RPS function being in an inoperable condition while operating on a mode or condition of

applicability. The finding was determined to be of very low safety significance (Green) in

12

accordance with Inspection Manual Chapter 0609, Appendix A, Exhibit 2.C, because the

finding did not affect a single RPS trip signal to initiate a reactor scram nor the function of

other redundant trips or diverse methods of reactor shutdown.

Corrective Action References: Condition Report CR-GGN-2016-08765

Minor Violation 71153

Minor Violation: On May 11, 2018, while performing the Division 1 emergency diesel

generator functional test portion of Division 1 loss of power (LOP)/loss of coolant accident

(LOCA) surveillance testing with the plant in Mode 5, a maintenance technician inadvertently

opened the incorrect fuse drawer associated with the 15AA (Division 1) safety electrical bus.

This action resulted in an undervoltage condition on the 15AA bus and an unplanned

automatic start of the Division 1 emergency diesel generator. Neither the Division 1

emergency diesel generator nor the associated Division 1 standby service water subsystem

were required to be operable in this mode of operation. This issue was entered into the

licensees corrective action program as Condition Report CR-GGN-2018-05485.

Technical Specification 5.4.1.a requires that written procedures shall be established,

implemented, and maintained covering the applicable procedures recommended in

Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Section 8.b of Appendix A to

Regulatory Guide 1.33 requires implementing procedures for each surveillance test listed in

the technical specifications. The licensee established Procedure 06-OP-1P75-R-0003,

Attachment IV, SDG 11, Functional Test - Test No. 6 - Div 1 LOP/LOCA Test,

Revision 138, to meet the Regulatory Guide 1.33 requirement. Step 5.8.15 of this procedure

stated to RACK OUT line PT for Bus 15AA feeder Breaker 152-1514 ESF 11 PT, in front of

Cubicle M2 of Bus 15AA.

Contrary to the above, on May 11, 2018, the licensee failed to rack out line potential

transformer (PT) for bus 15AA feeder breaker 152-1514 ESF 11 PT, in front of Cubicle M2 of

bus 15AA. Specifically, a maintenance technician opened the fuse drawer for the bus 15AA

PT fuse instead of the line PT fuse drawer.

Screening: The inspectors determined the performance deficiency was minor because it

could not be reasonably viewed as a precursor to a significant event; if left uncorrected, it

would not have the potential to lead to a more significant safety concern; and it did not

adversely affect the associated cornerstone objective to limit the likelihood of events that

upset plant stability and challenge critical safety functions during shutdown as well as power

operations. Specifically, the issue was determined to be similar to Example 4.b of Inspection

Manual Chapter 0612, Appendix E.

Enforcement: The licensee has taken actions to restore compliance. This failure to comply

with Technical Specification 5.4 constitutes a minor violation that is not subject to

enforcement action in accordance with the NRCs Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On March 5, 2020, the inspectors presented the inservice inspection results to

Mr. E. Larson, Site Vice President, and other members of the licensee staff.

13

On March 5, 2020, the inspectors presented the radiation safety inspection results to

Mr. E. Larson, Site Vice President, and other members of the licensee staff.

On April 7, 2020, the inspectors presented the integrated inspection results to

Mr. E. Larson, Site Vice President, and other members of the licensee staff.

14

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Corrective Action CR-GGN- 2018-06005, 2018-06546, 2018-06784, 2018-09566

Documents

Drawings E-0740-005 Motor Operated Valves Wiring Diagrams 5

E-1185-002 Reactor Core Isolation Cooling System RCIC Injection Shutoff 10

MOV F013-A

KA762E421D Process Diagram Reactor Core Isolation Cooling System A

M-1065 P&I Diagram Condensate & Refueling Water Storage & 53

Transfer System Unit 1

M-1083A P&I Diagram Reactor Core Isolation Cooling System - Unit 1 43

M-1083B P&I Diagram Reactor Core Isolation Cooling System - Unit 1 41

M-1086 High Pressure Core Spray System Unit 1 35

Engineering EC-GGN- Admin Change to Update Drawing E0740-005 0

Changes 0000079071

Miscellaneous Clearance 1C22-1 Tagout E22-006-1E22C001

GGNS UFSAR Chapters 4, 5, 6

ES-18 Motor Operated Valve - Wiring and Limit Switch Control 4

Procedures 04-1-01-E51-1 Reactor Core Isolation Cooling System 142

04-1-01-P81-1 High Pressure Core Spray Diesel Generator 81

SDC-E51 Reactor Core Isolation Cooling System 3

Work Orders WO 00503748, 00507876

71111.05 Corrective Action CR-GGN- 2020-02580

Documents

Drawings E1809 Smoke Detector SP65N6251 RHR A 93 ft West

Fire Plans A-04 Fire Pre-Plan 2

71111.07A Corrective Action CR-GGN- 2020-0119, 2020-0123, 2020-0124, 2020-0125, 2020-0138

Documents

Drawings M-1061B P&I Diagram Standby Service Water System Unit 1 53

Miscellaneous AECM-90/0007 Grand Gulf Nuclear Station Response to Generic Letter 89-13

CCE 2006-0002 Generic Letter 89-13 Commitment Change

Procedures EN-DC-316 Heat Exchanger Performance and Condition Monitoring 11

EN-DC-340 Microbiologically Influenced Corrosion (MIC) Monitoring 5

Program

15

Inspection Type Designation Description or Title Revision or

Procedure Date

EN-EP-S-039-G Testing Standard for Safety Related Heat Exchangers Cooled 2

by Standby Service Water

Work Orders WO 52790008, 52791443

71111.08G Corrective Action CR-GGN- 2018-00329, 2018-01546, 2018-02542, 2018-03080, 2018-

Documents 03129, 2018-03984, 2018-05620, 2018-05668, 2018-06215,

2019-00266, 2019-01400, 2019-02395, 2019-03087, 2019-

09428, 2019-10463, 2020-02183, 2020-02270,

Corrective Action CR-GGN- 2020-02578, 2020-02602

Documents

Resulting from

Inspection

Drawings 767E977 Recirc Loop Piping 2

FW-11-07 Feedwater WTR Loop B 10

HL-1328J Feedwater CTMT to Reactor Pressure Vessel - Unit 1 6

RR-11-06 Recirc Loop A 10

RR-11-11 Recirc Loop B 10

RR-11-4 Recirc Loop A 10

Miscellaneous SEP-ISI-GGN- Program Section for ASME Section XI, Division 1 GGNS 10

001 Inservice Inspection Program

Procedures CEP-NDE-0404 Manual Ultrasonic Examination of Ferritic Piping Welds 8

(Section XI)

CEP-NDE-0407 Straight Beam Ultrasonic Examination of Bolts and Studs 6

(ASME XI)

CEP-NDE-0423 Manual Ultrasonic Examination of Austenitic Piping Welds 8

(ASME XI)

CEP-NDE-0903 VT-3 Examination 6

WDI-STD-006 Manual Ultrasonic Procedure for Examination of Nozzle Inner 10

Corner Radius Areas in Accordance with ASME Section XI,

Including Appendix VIII

WDI-STD-1107 Generic Procedure for the Manual Ultrasonic Examination of 3

Reactor Pressure Vessel Welds in Accordance with PDI-UT-6

71111.11Q Procedures EN-RE-215 Reactivity Maneuver Plan 7

71111.12 Miscellaneous CR-GGN-2017-12314 MRFF

CR-GGN-2019-1476 MRFF Evaluation

16

Inspection Type Designation Description or Title Revision or

Procedure Date

CR-GGN-2019-1597 MRFF Evaluation

Procedures EN-DC-203 Maintenance Rule Program 4

EN-DC-204 Maintenance Rule Scope and Basis 4

EN-DC-205 Maintenance Rule Monitoring 7

Work Orders WO 82842039-01

71111.13 Corrective Action CR-GGN- 2020-02571, 2020-02611

Documents

Procedures 01-S-18-6 Risk Assessment of Maintenance Activities 21

EN-OP-119 Protected Equipment Postings 12

71111.15 Calculations C-EC86247- Structural/Seismic Analysis for the LaSalle Jet Pump Plug 0

N1F14E021-8.0-

001

Corrective Action CR-GGN- 2020-00076, 2020-00901

Documents

Engineering EC-86427 Seismic Qualification of Jet Pump Plugs 0

Changes

Procedures 07-1-34-B13- Jet Pump Plug Installation and Removal 1

D006-3

Work Orders WO 00530093

71111.18 Engineering EC 85565 Replace 1P81K001 Div III EDG Speedswitch (SSA-1) 0

Changes

Miscellaneous IEE-344 - 2013

00200225 Procurement Engineering Evaluation

E100.0 Technical Specification for Environmental Safety Related 8

Parameter

Procedures 02-S-01-45 Water Inventory Control 0

EN-DC-115 Engineering Change Process 27

Work Orders WO 00537942

71111.19 Procedures 06-OP-1P81-M- HPCS Diesel Generator 13 Functional Test 136

0002

Work Orders WO 00537942-04, 52856327-04

71111.20 Drawings M-0002 General Arrangement Plan at EL. 113'-0", 111'-0", 119'-0", 5

120'-10", & 114'-6", Units 1 & 2

17

Inspection Type Designation Description or Title Revision or

Procedure Date

M-0003 General Arrangement Plan at EL. 133'-0", 148'-0", 139'-0", 6

135'-4", & 147'-7"

M-0004 General Arrangement Plan at EL. 166'-0", 161'-10", & 170'-0" 7

71111.22 Drawings M-1082 P&I Diagram Standby Liquid Control System Unit 1 29

Miscellaneous Attachment 4 Suppression Pool Level Instrument 1E30-LT-N003B

Procedures 04-1-05-E50-1 R3 Suppression Pool Water Level Penetrations

04-1-05-M61-2, LLRT Alignment Instructions for Electrical Penetrations 0

Att 1

04-1-07-E30-1 Suppression Pool Makeup System

R27

06-OP-1C41-Q- Standby Liquid Control Functional Test 131

0001

06-OP-1M61-V- Using Graftel Model 9623-7 Leak Rate Monitor 13

0002, Att I

EN-WM-105 FLEX Portable Diesel Generator 1FLEXS010 06/21/2011

O4-S-03-P64-20 Transformer Deluge Functional and Full Flow Test 6

Work Orders WO 509598-03, 52782437-01, 52842248-01, 52842631-01,

52872563, 5291252-01

71124.01 Corrective Action CR-GGN- 2019-06666; 2019-07844; 2019-07852; 2019-07933; 2019-

Documents 08263; 2019-08334; 2019-08335; 2019-08336; 2019-09421;

2019-09535; 2020-01891; 2020-02586; 2020-02676; 2020-

02688

Miscellaneous Non-Nuclear Material Inventory 02/11/2020

GIN-2020-00005 2020 National Source Tracking System Reconciliation for NRC 01/08/2020

License NPF-29

WO 52881814 Leak Test of Sealed Sources 11/21/2019

Procedures EN-RP-100 Radiation Worker Expectations 12

EN-RP-101 Access Control for Radiologically Controlled Areas 15

EN-RP-102 Conduct of Radiation Protection 5

EN-RP-106 Radiological Survey Documentation 7

EN-RP-108 Radiation Protection Posting 22

EN-RP-121 Radioactive Material Control 16

EN-RP-131 Air Sampling 17

18

Inspection Type Designation Description or Title Revision or

Procedure Date

EN-RP-143 Source Control 14

Radiation Surveys Air Sampling 010520-0017, 112019-0261, 112019-0262, 120419-0333,

(GGN-AS-) 122619-0421,

GGN-1912-00010 133' Turbine Building Truck Bay 12/01/2019

GGN-2002-00931 139' AUX Steam Tunnel Lower Level 02/27/2020

GGN-2002-00980 114' Drywell Entire Elevation 02/28/2020

GGN-2002-01052 147' Drywell 02/29/2020

GGN-2003-00091 161' Drywell Entire Elevation 03/01/2020

GGN-2003-00213 147' Drywell Post-Alarm Survey 03/03/2020

GGN-2003-00253 139' AUX Steam Tunnel Lower Level 03/03/2020

Radiation Work 2020-1502 Drywell Coordinator, Safety and NRC Walkdowns / Tours in 0

Permits (RWPs) the Drywell

2020-1509 General Decon Activities and Support for the Drywell 0

2020-1510 Visually Inspect/Remove/Test/Replace Snubbers in RF-22 0

2020-1915 Emergent Work for Maintenance, Tours, and Inspections 0

(Normal and Low Risk Only)

Self-Assessments LO-GLO-2020- Pre-NRC Radiological Hazard Assessment and Exposure 01/24/2020

00005 Controls (71124.01)

71124.02 Corrective Action CR-GGN- 2019-03675, 2019-04131, 2019-10146, 2019-10399

Documents

Miscellaneous RF-21 Lessons Learned 02/06/2020

LO-GLO-2018- Pre-NRC Inspection: Occupational ALARA Planning and 12/03/2019

00176 Controls Assessment (IP 71124.02)

Procedures EN-FAP-RP-013 Radiation Protection Outage Preparation and Execution 0

EN-RP-105 Radiological Work Permits 19

EN-RP-110 ALARA Program 14

EN-RP-110-03 Collective Radiation Exposure (CRE) Reduction Guidelines 4

EN-RP-110-06 Outage Dose Estimating and Tracking 1

Radiation Work 2020-1502 Drywell Coordinator, Safety and NRC Walkdowns/Tours in the 0

Permits (RWPs) Drywell

2020-1509 General Decon Activities and Support for the Drywell 0

2020-1510 Visually Inspect/Remove/Test/Replace Snubbers in RF-22 0

2020-1915 Emergent Work for Maintenance, Tours, and Inspections 0

19

Inspection Type Designation Description or Title Revision or

Procedure Date

(Normal and Low Risk Only)

71153 Corrective Action CR-GGN- 2016-08765, 2017-12299, 2017-12314, 2018-05485

Documents

Procedures 06-IC-1C51-R- Average Power Range Monitor Calibration Channel A 100

0077A

06-OP-1P75-R- SDG 11, Functional Test - Test No. 6 - Div 1 LOP/LOCA Test 138

0003, Attachment

IV

EN-DC-159 System and Component Monitoring 9

EN-DC-205 Maintenance Rule Monitoring 7

EN-DC-310 Predictive Maintenance Program 8

EN-DC-324 Preventive Maintenance Program 18

EN-DC-335 PM Basis Template 8

EN-DC-346 Cable Reliability Program 6

EN-MA-138 VLF Tan Delta and Withstand Testing Of Electrical Power 4

Cables

Work Orders WO 0033200501, 0033200601

20