IR 05000416/2017003

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NRC Integrated Inspection Report 05000416/2017003
ML17318A184
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 11/13/2017
From: Jason Kozal
NRC/RGN-IV/DRP/RPB-C
To: Emily Larson
Entergy Operations
JASON KOZAL
References
IR 2017003
Download: ML17318A184 (34)


Text

ovember 13, 2017

SUBJECT:

GRAND GULF NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000416/2017003

Dear Mr. Larson:

On September 30, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Grand Gulf Nuclear Station. On October 5, 2017, 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.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

Further, inspectors documented a licensee-identified violation which was determined to be of very low safety significance (Green) in this report. The NRC is treating this violation as an NCV consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of these NCVs, 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 the 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 the Grand Gulf Nuclear Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Jason Kozal, Branch Chief Project Branch C Division of Reactor Projects Docket No. 50-416 License No. NPF-29 Enclosure:

Inspection Report 05000416/2017003 w/ Attachment: Supplemental Information

x SUNSI Review: ADAMS: Non-Publicly Available x Non-Sensitive Keyword:

By: JKozal/dll x Yes No x Publicly Available Sensitive NRC-002 OFFICE SRI:DRP/C ASRI:DRP/C RI:DRP/C BC:DRS/EB1 BC:DRS/EB2 BC:DRS/OB NAME MYoung RSmith NDay TFarnholtz GWerner VGaddy SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 11/03/2017 11/01/2017 11/3/2017 11/01/2017 11/01/2017 11/2/17 OFFICE BC:DRS/PSB2 TL:DRS/IPAT SPE:DRP/C BC:DRP/C NAME HGepford THipschman CYoung JKozal SIGNATURE /RA/ /RA/ E /RA/ /RA/

DATE 11/01/2017 11/1/2017 11/1/2017 11/13/2017

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000416 License: NPF-29 Report: 05000416/2017003 Licensee: Entergy Operations, Inc.

Facility: Grand Gulf Nuclear Station, Unit 1 Location: 7003 Baldhill Road Port Gibson, MS 39150 Dates: July 1 through September 30, 2017 Inspectors: M. Young, Senior Resident Inspector N. Day, Resident Inspector R. Smith, Nuclear System Engineer, Response Coordination Branch M. Hayes, Operations Engineer T. Farina, Operations Engineer C. Steely, Operations Engineer Approved Jason Kozal By: Chief, Project Branch C Division of Reactor Projects Enclosure

SUMMARY

IR 05000416/2017003; 07/01/2017 - 09/30/2017; Grand Gulf Nuclear Station; Surveillance

Testing.

The inspection activities described in this report were performed between July 1 and September 30, 2017, by the resident inspectors at Grand Gulf Nuclear Station and inspectors from the NRCs Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. Additionally,

NRC inspectors documented in this report one licensee-identified violation of very low safety significance (Green). The significance of inspection findings is indicated by their color (i.e., Green, greater than Green, White, Yellow, or Red), determined using Inspection Manual Chapter 0609, Significance Determination Process, dated April 29, 2015. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, dated July 2016.

Cornerstone: Mitigating Systems

Green.

The inspectors reviewed a self-revealed, non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to accomplish quality related activities in accordance with Surveillance Procedure 06-IC-1E31-A-1004, RCIC Equipment Room High Temperature Calibration Channel A, Revision 106. Specifically, on August 21, 2017, the licensee did not follow Step 5.15.4, which states, Identify and disconnect field lead located at Terminal EE-50 in 1H13-P632. This step was not performed correctly; therefore, the reactor core isolation cooling (RCIC) system isolation feature was not bypassed. When performing the next step, an inadvertent isolation of the RCIC system occurred. On August 21, 2017, the licensee restored compliance by performing actions to restore the leads to the correct location and performing the surveillance test satisfactorily. This issue has been entered into the licensees corrective action program as Condition Report CR-GGN-2017-08246.

The failure to follow Surveillance Procedure 06-IC-1E31-A-1004 was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because it was associated with the human 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. Specifically, the licensees failure to follow Surveillance Procedure 06-IC-1E31-A-1004 resulted in unplanned inoperability and unavailability of the reactor core isolation cooling system. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, and Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating System Screening Questions, the inspectors determined that the finding was of very low safety significance (Green) because the finding was not a deficiency affecting the design or qualification of a mitigating structure, system, or component; did not represent a loss of safety function; did not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time, and did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The inspectors determined that the finding had a field presence cross-cutting aspect within the human performance area because licensee management failed to ensure supervisory and management oversight of work activities, including contractors and supplemental personnel. Specifically, the performer in the field was a supplemental worker that was observed by a licensee instrumentation and controls technician. The technician telephoned the supervisor to ensure that they were performing the steps correctly, and the supervisor did not go into the field to verify the step was performed correctly [H.2]. (Section 1R22)

Licensee-Identified Violations

A violation of very low safety significance (Green) that was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and associated corrective action tracking numbers are listed in Section 4OA7 of this report.

PLANT STATUS

Grand Gulf Nuclear Station started the inspection period at 100 percent power.

On July 1, 2017, operations personnel reduced power to perform power suppression testing to identify a failed fuel rod.

On July 2, 2017, operations personnel increased power to 100 percent following power suppression testing.

On July 13, 2017, operations personnel reduced power to 50 percent to repair a main feedwater pump B oil leak.

On July 14, 2017, operations personnel increased power to 65 percent while still continuing work on the main feedwater pump B oil leak.

On July 17, 2017, operations personnel reduced power to 51 percent to restore main feedwater pump B, and then increased power to approximately 75 percent. The licensee maintained this power level until July 20, 2017, due to a condensate booster pump A seal issue.

On August 4, 2017, operations personnel completed a power increase and reached 100 percent power.

On August 17, 2017, operations personnel reduced power to 50 percent to secure main feedwater pump A due to a leak.

On August 19, 2017, operations personnel increased power to 65 percent while repairing the main feedwater pump A.

On August 29, 2017, operations personnel reduced power and manually scrammed the plant to enter a forced outage to replace the residual heat removal pump A due to its failure to meet a technical specification surveillance test.

On September 30, 2017, Grand Gulf Nuclear Station was in Mode 2 commencing a restart from a forced outage.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

.1 Partial Walk-Down

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant systems:

  • September 13 - 14, 2017, standby service water, train B, during shutdown cooling operations with residual heat removal system A out of service The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems or trains were correctly aligned for the existing plant configuration.

These activities constituted two partial system walk-down samples, as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walk-Down

a. Inspection Scope

On August 18, 2017, the inspectors performed a complete system walk-down inspection of the residual heat removal system, train C. The inspectors reviewed the licensees procedures and system design information to determine the correct system lineup for the existing plant configuration. The inspectors also reviewed outstanding work orders, open condition reports, temporary modifications, and other open items tracked by the licensees operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.

These activities constituted one complete system walk-down sample, as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety:

  • July 25, 2017, No. 2 flex equipment building
  • July 26, 2017, upper control room due to fire suppression system in alarm
  • August 8, 2017, offgas building due to indication of smoke
  • August 24, 2017, main control room due to inattentive continuous fire watch For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constituted four quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

.2 Annual Inspection

a. Inspection Scope

On August 10, 2017, the inspectors completed their annual evaluation of the licensees fire brigade performance. This evaluation included observation of an announced fire drill for a simulated fire in the turbine building switchgear room, elevation 113 feet. During this drill, the inspectors evaluated the capability of the fire brigade members, the leadership ability of the brigade leader, the brigades use of turnout gear and fire-fighting equipment, and the effectiveness of the fire brigades team operation. The inspectors also reviewed whether the licensees fire brigade met NRC requirements for training, dedicated size and membership, and equipment.

These activities constituted one annual inspection sample, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On July 13, 2017, the inspectors observed simulator training for an operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance.

These activities constituted completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened risk due to performing control rod sequence exchange and scram time testing. The inspectors observed the operators performance of the following activities:

  • July 17, 2017, a control rod sequence exchange was being performed when the sequence exchanged was halted by reactor engineering due to approaching limits of the operating envelope due to fuel failure already present in the core.

The inspectors attended a jump up meeting with operations management and reactor engineers to determine the best course of action going forward.

In addition, the inspectors assessed the operators adherence to plant procedures, including the conduct of operations procedure and other operations department policies.

These activities constituted completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.3 Biennial Review of Requalification Program

a. Inspection Scope

The licensed operator requalification program involves two training cycles that are conducted over a 2-year period. In the first cycle, the annual cycle, the operators are administered an operating test consisting of job performance measures and simulator scenarios. In the second part of the training cycle, the biennial cycle, operators are administered an operating test and a comprehensive written examination.

To assess the performance effectiveness of the licensed operator requalification program, the inspectors reviewed both the written examination and operating test quality and observed licensee administration of an annual requalification test while onsite. The operating tests observed included six job performance measures and two scenarios that were used in the current biennial requalification cycle. These observations allowed the inspectors to assess the licensee's effectiveness in conducting the operating test to ensure operator mastery of the training program content and to determine if feedback of performance analyses into the requalification training program was being accomplished.

On September 1, 2017, the licensee informed the inspectors of the completed cycle results for Grand Gulf Nuclear Station for both the written examinations and the operating tests:

  • 7 of 7 crews passed the simulator portion of the operating test
  • 37 of 37 licensed operators passed the simulator portion of the operating test
  • 43 of 44 licensed operators passed the written examination The individual that failed the written examination was remediated, retested, and passed the retake examination. The difference in the number of operators taking the operating test and those taking the written exam was due to a recently completed senior reactor operator upgrade licensing exam requiring these individuals to take the biennial written exam only and not an operating test.

The inspectors observed examination security measures in place during administration of the exams (including controls and content overlap) and reviewed any remedial training and re-examinations, if necessary. The inspectors also reviewed medical records of 10 licensed operators for conformance to license conditions.

The inspectors reviewed simulator performance for fidelity with the actual plant and the overall simulator program of maintenance, testing, and discrepancy correction.

These activities constituted completion of one inspection sample of the biennial licensed operator requalification program, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed four instances of degraded performance or condition of safety-significant structures, systems, and components (SSCs):

  • August 10, 2017, firewater and fire suppression systems, due to scheduling of fire extinguisher annual preventive maintenance testing past yearly requirements
  • August 24, 2017, feedwater system, due to unavailability from a leak in the main feedwater pump B control valve oil system
  • September 25, 2017, residual heat removal system, due to subsystem A failing quarterly surveillance requirements The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of four maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed two risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:

  • September 14, 2017, risk evaluation for an operation with the potential to drain the reactor vessel during residual heat removal pump A lifting The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the results of the assessments.

The inspectors also observed portions of three emergent work activities that had the potential to cause an initiating event:

  • August 17, 2017, low pressure feedwater heater drain piping leak repair
  • August 18, 2017, reactor feedwater pump A seal steam isolation with unexpected radiation alarms The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected SSCs.

These activities constituted completion of five maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed four operability determinations and functionality assessments that the licensee performed for degraded or nonconforming SSCs:

  • July 3, 2017, operability determination of the drywell gaseous and particulate radiation monitors and alarms concurrent with suspected failed fuel indication
  • September 25, 2017, operability determination of the high pressure core spray system due to two rusted mounting bolts The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable or functional, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded SSC.

These activities constituted completion of four operability and functionality review samples, as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

On July 25, 2017, the inspectors reviewed a temporary plant modification that affected risk-significant SSCs. Specifically, the inspectors reviewed the leak injection of main steam line drain valve 1N11F007, and a subsequent modification to leave the valve gagged open until the forced outage. The inspectors verified that the licensee had installed this temporary modification in accordance with technically adequate design documents. The inspectors verified that this modification did not adversely impact the operability or availability of affected SSCs. The inspectors reviewed design documentation and plant procedures affected by the modification to verify the licensee maintained configuration control.

These activities constituted completion of one sample of temporary modifications, as defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed seven post-maintenance testing activities that affected risk-significant SSCs:

  • July 11, 2017, standby gas treatment B following corrective maintenance after a failure of damper 1T48-F005 to operate during surveillance testing
  • July 26, 2017, reactor feedwater pump, train B, following repair of a control valve leak
  • September 28, 2017, residual heat removal pump, train A, following pump replacement The inspectors reviewed licensing- and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.

These activities constituted completion of seven post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

During the stations forced outage that concluded on October 1, 2017, the inspectors evaluated the licensees outage activities. The station began the forced outage on August 29, 2017, due to a technical specification required shutdown for the residual heat removal pump A surveillance failure. The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions.

This verification included the following:

  • Review of the licensees outage plan prior to and during the outage
  • Review and verification of the licensees fatigue management activities
  • Monitoring of shut-down and cool-down activities
  • Verification that the licensee maintained defense-in-depth during outage activities
  • Review of operations with a potential for draining the reactor vessel (BWR)
  • Final inspection of drywell before startup activities
  • Monitoring of heat-up and startup activities These activities constituted completion of one outage activities sample, as defined in Inspection Procedure 71111.20.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed nine risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions:

In-service tests:

  • August 11, 2017, residual heat removal, train C, discharge flow low bypass test Containment isolation valve surveillance tests:
  • July 24, 2017, standby service water A outboard outlet from drywell purge compressor isolation valve testing Other surveillance tests:
  • August 25, 2017, bypass valve testing using the automatic turbine tester The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.

These activities constituted completion of nine surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

Introduction.

The inspectors reviewed a self-revealed, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to accomplish quality related activities in accordance with Surveillance Procedure 06-IC-1E31-A-1004, RCIC Equipment Room High Temperature Calibration Channel A, Revision 106. Specifically, on August 21, 2017, the licensee did not follow Step 5.15.4, which states, Identify and disconnect field lead located at Terminal EE-50 in 1H13-P632. This step was not performed correctly; therefore, the reactor core isolation cooling (RCIC) system isolation feature was not bypassed. When performing the next step, an inadvertent isolation of the RCIC system occurred.

Description.

On August 21, 2017, the licensee was performing the RCIC equipment room high temperature calibration. This calibration was performed using safety-related Surveillance Procedure 06-IC-1E31-A-1004, RCIC Equipment Room High Temperature Calibration Channel A, Revision 106. Step 5.15.4, states, Identify and disconnect field lead located at Terminal EE-50 in 1H13-P632. Two individuals, one a supplemental employee, performed this step based on previous experience that the field lead is always on the right side of the panel. However, in this particular panel, the field lead was located on the left side of the panel. The instrumentation and control (I&C)technician overseeing the supplemental worker did not perform an adequate peer check following the action taken. Prior to Step 5.15.5, there is a note in the procedure that states, Caution: Following steps initiates an RCIC isolation signal. Step 5.15.4 bypasses actual RCIC isolation. The technician called the supervisor to ensure that they performed the steps correctly; however, the I&C supervisor only discussed this over the phone and did not go into the field to verify the condition prior to initiating the RCIC isolation signal. Following the discussion with the supervisor, the individuals proceeded to the next step in the procedure. Because bypassing the isolation signal was not performed correctly in Step 5.15.4, an actual isolation of the RCIC system occurred when Step 5.15.5 was performed, making the system inoperable. The licensee entered this into their corrective action program as Condition Report CR-GGN-2017-08246. On August 21, 2017, the licensee restored compliance by restoring the leads to the correct location and performing the surveillance test satisfactorily.

Analysis.

The failure to follow Surveillance Procedure 06-IC-1E31-A-1004 was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because it was associated with the human 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. Specifically, the licensees failure to follow Surveillance Procedure 06-IC-1E31-A-1004 resulted in unplanned inoperability and unavailability of the reactor core isolation cooling system. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, and Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating System Screening Questions, the inspectors determined that the finding was of very low safety significance (Green) because the finding was not a deficiency affecting the design or qualification of a mitigating structure, system, or component; did not represent a loss of safety function; did not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time, and did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The inspectors determined that the finding had a field presence cross-cutting aspect within the human performance area because licensee management failed to ensure supervisory and management oversight of work activities, including contractors and supplemental personnel. Specifically, the performer in the field was a supplemental worker that was observed by a licensee instrumentation and controls technician. The technician telephoned the supervisor to ensure that they were performing the steps correctly, and the supervisor did not go into the field to verify the step was performed correctly [H.2].

Enforcement.

10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, on August 21, 2017, the licensee failed to accomplish activities affecting quality in accordance with prescribed instructions, procedures, or drawings. Specifically, the licensee did not follow Surveillance Procedure 06-IC-1E31-A-1004, RCIC Equipment Room High Temperature Calibration Channel A, Revision 106, Step 5.15.4, which states, Identify and disconnect field lead located at Terminal EE-50 in 1H13-P632.

This resulted in unplanned inoperability and unavailability of the RCIC system. On August 21, 2017, the licensee restored compliance by performing actions to restore the leads to the correct location and performing the surveillance test satisfactorily. Because this finding was of very low safety significance and was entered into the licensees corrective action program as Condition Report CR-GGN-2017-08246, this finding is being treated as a non-cited violation consistent with Section 2.3.2.a. of the NRC Enforcement Policy. (NCV 05000416/2017003-01, Isolation of Reactor Core Isolation Cooling System during Surveillance Testing)

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

a. Inspection Scope

The inspectors observed an emergency preparedness drill on July 12, 2017, to verify the adequacy and capability of the licensees assessment of drill performance. The inspectors reviewed the drill scenario, observed the drill from the simulator and the emergency operations facility. The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors determined all emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and they were entered into the corrective action program for resolution.

These activities constituted completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06.

b. Findings

No findings were identified.

OTHER ACTIVITIES

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

4OA1 Performance Indicator Verification

.1 Mitigating Systems Performance Index: High Pressure Injection Systems (MS07)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of July 1, 2016, through June 30, 2017, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for high pressure injection systems, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index: Heat Removal Systems (MS08)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of July 1, 2016, through June 30, 2017, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for heat removal systems, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Mitigating Systems Performance Index: Residual Heat Removal Systems (MS09)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of July 1, 2016, through June 30, 2017, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for residual heat removal systems, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Semiannual Trend Review

a. Inspection Scope

On August 16, 2017, the inspectors completed a review of the licensees fire protection program due to an increase in fire impairments and an increase in conditions adverse to quality identified pertaining to fire watch duties. The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address identified adverse trends.

These activities constituted completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.

b. Observations and Assessments On June 29, 2017, Grand Gulf Nuclear Station had identified an inattentive continuous fire watch in the main control room. The inspectors noted that this was the third instance of a fire watch issue with the same continuous fire watch in this area. The first issue was an instance of the fire watch not fully understanding their response roles, and the second issue was an inattentive fire watch. The inspectors interviewed station management following this third example to understand the similarities between the multiple examples and the licensees actions to address these issues. The inspectors determined that the three examples, taken individually, are of minor safety significance because the control room is continuously manned by knowledgeable individuals (licensed operators) that are nearby and would be able to assist if needed. However, since the three examples had occurred within the last two years, they constitute a trend of multiple current human performance issues and are indicative of ineffective corrective actions. The inspectors also noted that the compensatory action of staging a continuous fire watch was because of a degraded suppression (halon) system. The station has yet to repair this system due to obsolete parts not being available. The inspectors noted that the station did not have a repair or replacement plan in place for component aging degradation. The licensee has also increased the number of individuals in the control room to perform the required duties as a corrective action.

On August 14, 2017, while the inspector was in the offgas building following a report of smoke in the area, the inspector noted that annual maintenance had not been performed as required for fire extinguishers in the area. Maintenance had last been performed on August 5, 2016, and was due on August 5, 2017. When discussing this issue with the fire protection engineer, the inspector noted that the licensees scheduling was done to ensure that the annual maintenance is done one year from when the first occurance takes place. However, the inspector noted that if maintenance checks are performed earlier than the one-year date (and documented on the extinguisher tag), subsequent maintenance is not re-scheduled to occur within one year from the date of the most recent performance. This meant that further maintenance checks were being scheduled into the grace periods. The inspectors did not identify a violation of regulatory requirements, but did identify poor maintenance scheduling to ensure the frequency interval of 365 days is achieved.

c. Findings

No findings were identified.

.3 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors selected one issue for an in-depth follow-up:

  • On September 20, 2017, the inspectors reviewed a loss of safety function assessment provided by the licensee for the standby gas treatment system, as documented in Condition Report CR-GGN-2017-02968. The cause was determined to be a failure to properly install an adequate power supply for the flow damper. The licensee did not adequately test the system following installation, and the power supply later failed. The inspectors questioned the licensees evaluation of the failure mode. Through further evaluation, the licensee deteremined that the damper failed open and did not cause a loss of safety function. This determination resulted in the licensees retraction of a previously reported loss of safety function. The licensee originally reported a loss of safety function in Licensee Event Report (LER) 2017-002-00, which was retracted in LER 2017-002-01.

The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.

These activities constituted completion of one annual follow-up sample, as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On October 5, 2017, the inspectors presented the licensed operator requalification program inspection results to Mr. E. Larson, Site Vice President, and other members of the licensee's 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 October 5, 2017, the inspectors presented the inspection results to Mr. E. Larson, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned, treated in accordance with guidance, or destroyed.

4OA7 Licensee-Identified Violations

The following licensee-identified violation of NRC requirements was determined to be of very low safety significance (Green) and meets the NRC Enforcement Policy criteria for being dispositioned a non-cited violation:

  • Title 10 CFR 55.49 requires, in part, that licensees shall not engage in any activity that compromises the integrity of any test or examination required by 10 CFR 55.49. The integrity of a test or examination is considered compromised if any activity, regardless of intent, affected, or, but for detection, would have affected the equitable and consistent administration of the test or examination. Contrary to the above, on August 8, 2017, Grand Gulf Nuclear Station engaged in an activity that compromised the integrity of an examination required by 10 CFR 55.49. Specifically, the licensee left written exam material from a previous weeks exam unattended. The previous weeks exam contained half of the current weeks written exam material. The exam material was marked appropriately and located within an instructors office. This finding was determined to be of very low safety significance (Green) because the finding did not have an actual effect on the equitable and consistent administration of the biennial requalification exam cycle. The licensee entered this issue into the corrective action program as Condition Report CR-GGN-2017-07723.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Ellis, Regulatory Assurance
M. Giacini, General Manager Plant Operations
J. Graham, Assisant Operations Manager
E. Larson, Site Vice President
R. Meister, Regulatory Assurance
R. Meyer, Assistant Operations Manager
D. Neve, Manager, Regulatory Assurance
M. Pait, Superintendent, Training
B. Wertz, Manager, Operations
P. Williams, Director, Engineering

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

Isolation of Reactor Core Isolation Cooling System during

05000416/2017003-01 NCV Surveillance Testing (Section 1R22)

LIST OF DOCUMENTS REVIEWED