IR 05000416/2018003

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NRC Integrated Inspection Report 05000416/2018003
ML18317A240
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 11/13/2018
From: Jason Kozal
NRC/RGN-IV/DRP
To: Emily Larson
Entergy Operations
References
IR 2018003
Download: ML18317A240 (12)


Text

ber 13, 2018

SUBJECT:

GRAND GULF NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000416/2018003

Dear Mr. Larson:

On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Grand Gulf Nuclear Station. On October 18, 2018, the NRC inspectors discussed the results of this inspection with Mr. R. Franssen, General Manager, Plant Operations, 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 did not involve a violation of NRC requirements.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at 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 W. Kozal, Chief Project Branch C Division of Reactor Projects Docket No. 50-416 License No. NPF-29 Enclosure:

Inspection Report 05000416/2018003

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number(s): 05000416 License Number(s): NPF-29 Report Number(s): 05000416/2018003 Enterprise Identifier: I-2018-003-0008 Licensee: Entergy Operations, Inc.

Facility: Grand Gulf Nuclear Station Location: Port Gibson, Mississippi Inspection Dates: July 1, 2018 to September 30, 2018 Inspectors: T. Steadham, Senior Resident Inspector N. Day, Resident Inspector L. Newman, Project Engineer C. Young, Senior Project Engineer Approved By: Jason W. Kozal Branch Chief 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 Unit 1 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 self-revealed finding and additional items are summarized in the tables below.

List of Findings and Violations Failure to Develop Adequate Work Instructions Cornerstone Significance Cross-cutting Inspection Aspect Procedure Mitigating Green H.9 - Human 71111.13 -

Systems FIN 05000416/2018003-01 Performance, Maintenance Closed Training Risk Assessments and Emergent Work Control A self-revealed, Green finding was identified when feedwater heater drain tank oscillations caused a feedwater perturbation which required a manual reactor scram. Specifically, the licensee failed to develop appropriate work instructions for filling and venting the feedwater heater 6A level transmitters.

Additional Tracking Items Type Issue number Title Inspection Status Procedure URI 05000416/2017001-02 Grand Gulf Unplanned 71151 - Closed Power Changes per 7000 Performance Critical Hours Performance Indicator Indicator Verification

PLANT STATUS Unit 1 began this inspection period shutdown for Refueling Outage 21. The unit was started up, following Refueling Outage 21, on July 14, 2018. On July 30, 2018, due to issues with the recirculation system protection logic, reactor power was reduced from approximately 82 percent power to approximately 27 percent power. The unit reached full rated thermal power on August 16, 2018. On August 21, 2018, due to a partial loss of feedwater heaters, power was reduced to approximately 62 percent power. The unit reached full rated thermal power on August 27, 2018. On September 14, 2018, the reactor was manually scrammed due to a partial loss of feedwater. The unit was restarted on September 18, 2018. The unit finished the inspection period during startup activities at approximately 95 percent power.

INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/

reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed 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.

REACTOR SAFETY 71111.01Adverse Weather Protection Summer Readiness (1 Sample)

The inspectors evaluated summer readiness of offsite and alternate alternating current power systems.

Impending Severe Weather (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions for tropical storm Gordon on September 4, 2018.

71111.04Equipment Alignment Partial Walkdown (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Reactor core isolation cooling system due to recent refueling outage configuration on August 12, 2018 (2) Division 1 Direct Current battery on August 20, 2018

(3) Standby liquid control subsystem B on September 6, 2018 (4) High pressure core spray on September 25, 2018 Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the residual heat removal subsystem B on August 29, 2018.

71111.05AQFire Protection Annual/Quarterly Quarterly Inspection (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Lower cable spreading room, Fire Area 42, Zone OC402, on July 6, 2018 (2) Turbine building elevation 113 feet due to welding modification, Zone 1T108, on July 16, 2018 (3) Main control room due to excessive storage in Unit 2, Fire Area 50, Zone OC503, on July 31, 2018 (4) Emergency diesel breezeway due to deluge valve work, Fire Area 60, Zone 1D301, on August 16, 2018 (5) Division 1 battery room and switchgear room, Fire Area 31, Zone OC202, on September 11, 2018 Annual Inspection (1 Sample)

The inspectors evaluated fire brigade performance on August 24, 2018.

71111.06Flood Protection Measures Internal Flooding (2 Samples)

The inspectors evaluated internal flooding mitigation protections in:

(1) Residual heat removal pump room B on September 5, 2018 (2) High pressure core spray pump room on September 25, 2018 71111.11Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification (1 Sample)

The inspectors observed and evaluated a simulated anticipated transient without scram and simulated auxiliary building flooding due to fire water piping break on August 9, 2018.

Operator Performance (2 Samples)

The inspectors observed and evaluated operator performance in the control room on:

(1) Reactor recirculation pump upshift on August 1, 2018 (2) Reactor startup and control rod withdrawal following forced outage due to manual reactor scram on September 18, 2018 71111.12Maintenance Effectiveness Routine Maintenance Effectiveness (2 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) T46 emergency safeguard feature switchgear room cooling system on September 30, 2018 (2) T51 emergency pump room ventilation system on September 30, 2018 Quality Control (1 Sample)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issues:

(1) Reactor core isolation cooling turbine oil commercial grade dedication and condition monitoring as a result of out of specification oil sample results on September 10, 2018 71111.13Maintenance Risk Assessments and Emergent Work Control (3 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Elevated risk due to residual heat removal A heat exchanger bypass valve failure on August 24, 2018 (2) Elevated Yellow risk due to planned standby service water outage on August 15, 2018 (3) Feedwater heater 6A level transmitter calibration on September 24, 2018 71111.15Operability Determinations and Functionality Assessments (4 Samples)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Reactor core isolation cooling outboard isolation valve 1E51F064 operability with missing pipe insulation, Condition Report CR-GGN-2018-08565, on August 2, 2018 (2) Scaffolding not meeting procedural rattle space requirement, Condition Report CR-GGN-2018-09366, on August 15, 2018

(3) Residual heat removal A flow element 1E12N014A bolts over torqued, Condition Report CR-GGN-2018-06882, on August 17, 2018 (4) Out of specification reactor core isolation cooling turbine oil sample results, Condition Report CR-GGN-2018-10179, on September 10, 2018 71111.18Plant Modifications (1 Sample)

The inspectors evaluated the following permanent modification:

(1) Weld repair to high pressure turbine drain on August 1, 2018 71111.19Post Maintenance Testing (3 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Standby service water B following planned maintenance outage on August 14, 2018 (2) Residual heat removal A heat exchanger bypass valve E12F034A stem nut replacement on August 27, 2018 (3) Division 1 emergency diesel generator governor replacement on August 27, 2018 71111.22Surveillance Testing The inspectors evaluated the following surveillance tests:

Routine (3 Samples)

(1) Reactor recirculation pump surveillance on July 27, 2018 (2) Reactor recirculation jet pump surveillance on July 27, 2018 (3) Intermediate range Channel B calibration on August 17, 2018 In-service (1 Sample)

(1) Residual heat removal A heat exchanger bypass valve inservice testing following maintenance on August 27, 2018 OTHER ACTIVITIES - BASELINE 71151Performance Indicator Verification (1 Sample)

The inspectors verified the licensee performance indicator submittal listed below:

(1) BI02: Reactor Coolant System Leak Rate Sample (10/01/2017-06/30/2018)

71152Problem Identification and Resolution Annual Follow-up of Selected Issues (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issue:

(1) Review of Division 2 battery inverter high frequency on September 11, 2018 71153Follow-up of Events and Notices of Enforcement Discretion Events (3 Samples)

The inspectors evaluated:

(1) Recirculation pump downshift to slow speed on July 30, 2018 (2) Plant and operator response to feedwater heater 5A isolation on August 21, 2018 (3) Plant and operator response to manual reactor scram due to partial loss of feedwater on September 14, 2018 INSPECTION RESULTS Failure to Develop Adequate Work Instructions Cornerstone Significance Cross-cutting Inspection Aspect Procedure Mitigating Systems Green H.9 - Human 71111.13 -

FIN 05000416/2018003-01 Performance, Maintenance Closed Training Risk Assessments and Emergent Work Control A self-revealed, Green finding was identified when feedwater heater drain tank oscillations caused a feedwater perturbation which required a manual reactor scram. Specifically, the licensee failed to develop appropriate work instructions for filling and venting the feedwater heater 6A level transmitters.

Description: On September 14, 2018, maintenance personnel were backfilling the feedwater heater (FWH) 6A level transmitters 1N23N059A and 1N23N061A under Work Order 486066 to troubleshoot feedwater heater level oscillations.

At the digital feedwater control (INFI-90) control panel, maintenance personnel toggled the N059A transmitter out of service. Because of the troubleshooting, the 6A FWH level was being maintained at 0 inches, which caused the N061A transmitter to read downscale. As a result, the INFI-90 logic determined that the N061A transmitter input was of bad quality.

INFI-90 compared the N059A and N061A values to determine which transmitter to use. The N059A transmitter was being backfilled at the time, and was indicating approximately 15 inches.

In accordance with system design, because of the difference in values between the two transmitters, INFI-90 determined that the N061A had failed and auto swapped to the N059A transmitter, which was toggled out of service and was indicating a higher than actual level. With the level controller in automatic and set to 3 inches, and detecting a level of 15 inches as indicated by N059A, the FWH 6A drain valve fully opened in an attempt to restore level. Heater drain tank level began oscillating, resulting in a trip of condensate booster pump A and a subsequent main feedwater pump A trip. With the feed pump tripped, reactor water level began lowering. When reactor water level reached 13 inches and continued lowering, operators initiated a manual reactor scram prior to water level reaching

the Level 3 automatic scram setpoint (11.4 inches). Water level subsequently stabilized in the normal level band. All safety systems functioned as designed.

Plant personnel were unaware that the INFI-90 system would function in this manner.

Consequently, the work order lacked sufficient controls to ensure that a feedwater transient would not be caused by an automatic swap over to the transmitter being worked on.

Corrective Actions: Licensee corrective actions included tuning the feedwater heater and feedwater heater drain tank level control valves and initiating a root cause evaluation of the event.

Corrective Action Reference: The licensee entered the issue into their corrective action program as Condition Report CR-GGN-2018-10441.

Performance Assessment:

Performance Deficiency: The failure to provide adequate instructions in Work Order 486066 to prevent a feedwater transient and subsequent scram was a performance deficiency. As required by licensee Procedure EN-WM-105, Planning, Revision 23, step 1.1, a minimum level of direction and instruction must be provided for successful completion of the work to prevent unexpected plant reactions. This was within the licensees ability to foresee and correct because the licensee possessed the documented basis for the applicable operational characteristics of the INFI-90 system prior to conducting maintenance activities.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the procedure quality attribute of the Initiating Events Cornerstone and adversely affected the objective to limit the likelihood of events that upset plant stability. Specifically, the performance deficiency contributed to the need for operators to initiate a plant scram.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, Exhibit 1, Section B. Since the finding did not cause the loss of mitigation equipment relied upon to transition the plant from the onset of the scram to a stable shutdown condition, the finding was determined to be of very low safety significance (Green). Specifically, the finding did not cause a complete loss of feedwater.

Cross-cutting Aspect: The finding had a cross-cutting aspect in the area of human performance associated with training, because the licensee failed to ensure knowledge transfer to maintain a knowledgeable, technically competent workforce with regards to the operation of the INFI-90 digital feedwater control system.

Enforcement: Inspectors did not identify a violation of regulatory requirements associated with this finding.

Minor Violation 71151 -

Performance Indicator Verification Minor Violation: The licensee did not include any unplanned power changes as inputs for the Unplanned Power Changes per 7,000 Critical Hours performance indicator (PI) that was reported to the NRC for the second quarter 2016. Based on a plant event that took place on June 17, 2016, the inspectors noted that the PI data submitted by the licensee may not have been accurate. In response, the licensee submitted frequently asked question (FAQ) 17-01 to the reactor oversight process working group. This FAQ resulted in the determination that three unplanned power changes should have been reported associated with the event in question. Following resolution of the FAQ, the licensee reported the associated PI data.

As required by 10 CFR 50.9, Completeness and accuracy of information, information provided to the NRC by a licensee shall be complete and accurate in all material respects.

Contrary to the above, from July 2016 through May 2017, information provided to the NRC by the licensee was not complete and accurate in all material respects. Specifically, the data for the Unplanned Power Changes per 7,000 Critical Hours PI did not include any unplanned power changes for the second quarter 2016.

Screening: The inspectors determined that this violation was of minor significance in accordance with the NRC Enforcement Policy, Section 6.9.d.11, since the PI data in question did not ultimately result in the PI changing from Green to White.

Enforcement: The licensee entered this issue into their corrective action program as Condition Report CR-GGN-2016-06028. The licensee took action to restore compliance by submitting an appropriate correction to the PI data. This failure to comply with 10 CFR 50.9 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

The disposition of this violation closes URI 05000416/2017001-02, Grand Gulf Unplanned Power Changes per 7000 Critical Hours Performance Indicator.

EXIT MEETINGS AND DEBRIEFS On October 18, 2018, the inspectors presented the quarterly resident inspector inspection results to Mr. R. Franssen, General Manager Plant Operations, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

ML18317A240 SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: JWK Yes No Publicly Available Sensitive NRC-002 OFFICE SRI:DRP/C RI:DRP/C BC:DRS/EB1 BC:DRS/EB2 BC:DRS/OB BC:DRS/PSB2 NAME TSteadham NDay TFarnholtz GWerner VGaddy HGepford SIGNATURE TCS NHD TRF GEW vgg hjg DATE 11/02/2018 11/02/2018 10/30/2018 10/30/2018 10/31/18 10/30/18 OFFICE TL:DRS/IPAT SPE:DRP/C BC:DRP/C NAME GMiller CYoung JKozal SIGNATURE gbm CHY JWK DATE 10/31/18 10/30/2018 11/13/2018