IR 05000416/2018040

NRC Supplemental Inspection Report 05000416/2018040 and Assessment Follow-Up Letter

ML18211A174
Person / Time
Site:	Grand Gulf
Issue date:	08/01/2018
From:	Anton Vegel NRC/RGN-IV/DRP
To:	Emily Larson Entergy Operations
Kozal J
References
EA-17-184 IR 2018040
Download: ML18211A174 (17)

Text

ust 1, 2018

SUBJECT:

GRAND GULF NUCLEAR STATION - NRC SUPPLEMENTAL INSPECTION REPORT 05000416/2018040 AND ASSESSMENT FOLLOW-UP LETTER

Dear Mr. Larson:

On June 28, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a supplemental inspection at your Grand Gulf Nuclear Station using Inspection Procedure 95001, Supplemental Inspection Response to Action Matrix Column 2 Inputs. On the same date, the NRC inspectors discussed the results of this inspection with you and other members of your staff. On July 24, 2018, the NRC discussed the implementation of your corrective actions with Robert Franzen, General Manager Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC performed this inspection to review your stations actions in response to a White Unplanned Scrams per 7000 Critical Hours (Initiating Events Cornerstone) performance indicator (PI), which you reported for the third quarter 2016.

An earlier 95001 inspection conducted to review the performance issues that led to the White PI (reference Inspection Report 05000416/2017013, dated December 6, 2017, Agencywide Documents Access and Management System (ADAMS) Accession No. ML17342B130)

concluded that your staffs cause evaluations were not performed to the depth and breadth described in Inspection Procedure 95001. Specifically, two significant weaknesses and five general weaknesses were identified. Accordingly, the NRC issued a White parallel PI inspection finding and identified the need to conduct a follow-up supplemental inspection after your staff took actions to correct the identified weaknesses and informed the staff of your readiness for reinspection.

On May 8, 2018, you informed the NRC that your station was ready for the follow-up supplemental inspection. During the inspection, the inspectors noted that your staffs actions to address the seven identified weaknesses identified additional organizational weaknesses that resulted in changes to previous casual factors, new corrective actions, extent of condition and extent of cause reviews, prudent actions, and identification of several missed opportunities.

The NRC inspectors did not identify any finding or violation of more than minor significance. After final review of your actions to address the performance issues that led to the White PI, the NRC concluded that your actions were sufficient to meet the supplemental inspection objectives. Therefore, in accordance with the guidance in Inspection Manual Chapter (IMC) 0305, Operating Reactor Assessment Program, the White parallel PI inspection finding is closed and will not be considered as an Action Matrix input after the end of the second quarter of 2018. As a result, the NRC determined the performance at Grand Gulf Nuclear Station to be in the Licensee Response Column of the Reactor Oversight Process (ROP) Action Matrix as of the date of this letter.

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.

Please contact Mr. Jason Kozal at 817-200-1144 with any question you have regarding this letter.

Sincerely,

/RA/

Anton Vegel, Director Division of Reactor Projects Docket No. 50-416 License No. NPF-29 Enclosure:

Inspection Report 05000416/2018002 w/ Attachment: Documents Reviewed

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000416 License Number: NPF-29 Report Number: 05000416/2018040 EA Number: EA-17-184 Enterprise Identifier: I-2018-040-005 Licensee: Entergy Operations, Inc.

Facility: Grand Gulf Nuclear Station, Unit 1 Location: 7003 Baldhill Road Port Gibson, MS 39150 Inspection Dates: June 25, 2018 to June 28, 2018 Inspectors: C. Newport, Senior Resident Inspector J. Josey, Senior Resident Inspector A. Athar, Inspector (training)

Approved By: Jason W. Kozal, Chief Project Branch C Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a follow-up supplemental inspection - Inspection Procedure 95001 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. Findings and violations being considered in the NRCs assessment are summarized in the table below.

The NRC inspectors performed a follow-up supplemental inspection in accordance with Inspection Procedure 95001, Supplemental Inspection Response to Action Matrix Column 2 Inputs, to assess the licensees actions to address the performance issues associated with a White performance indicator (PI) for Unplanned Scrams per 7000 Critical Hours. Specifically, this supplemental inspection was performed to assess the licensees actions to address weaknesses identified in the previous 95001 inspection efforts in which a White parallel PI finding was identified.

After review of revisions made by the licensee to the root cause evaluations (RCEs) following the initial 95001 inspection and in response to deficiencies identified by the inspectors during this reinspection, the inspectors concluded that changes to the licensees RCEs were thorough and self-critical. Additionally, the licensees evaluation of the extent of condition and extent of cause was comprehensive. The licensees additional analysis identified a number of station-wide weaknesses in the areas of oversight, procedure adherence, and work control requiring broad corrective actions to improve overall station performance. The inspectors concluded that the licensees corrective actions have appropriately addressed the identified root and contributing causes, and that they have been properly prioritized, scheduled, and implemented commensurate with their safety significance.

List of Findings and Violations No findings were identified.

Additional Tracking Items Type Issue number Title Report Section Status FIN 05000416/2017013-03 Parallel White Unplanned 95001 - Closed Scrams per 7000 Critical Supplemental Hours PI Finding Inspection Response to Action Matrix Column 2 Inputs

INSPECTION SCOPE

Inspections were conducted using the inspection procedure (IP) 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. Documents reviewed by the inspectors are listed in the documents reviewed section of this report. The inspectors used the Commissions rules and regulations as the criteria for determining compliance along with established licensee standards as the criteria for assessing licensee performance.

This follow-up supplemental inspection was conducted in accordance with Inspection Procedure 95001, Supplemental Inspection Response to Action Matrix Column 2 Inputs. The inspection assessed the licensees actions to address significant weaknesses in their RCEs identified by the NRC staff during the earlier 95001 supplemental inspection documented in Inspection Report 05000416/2017013, dated December 6, 2017, (ADAMS Accession No. ML17342B130). The inspectors reviewed changes in the licensees causal evaluations and corrective actions to ensure the causes of the performance issues were correctly identified and appropriate corrective actions are in place to preclude repetition of the significant performance issues associated with the White performance indicator.

The unsatisfied requirements of the earlier 95001 inspection were the primary scope of this follow-up inspection. The inspection objectives were to:

• provide assurance that changes made to the cause evaluations were appropriate and to a level of detail commensurate with the White performance indicator;

• provide assurance that the licensee identified the extent of condition and extent of cause of significant performance issues; and

• provide assurance the licensee has taken or planned corrective actions sufficient to address changes to the root and contributing causes and to prevent recurrence of the associated performance issues.

The licensee entered the Regulatory Response Column of the NRCs Reactor Oversight Process (ROP) Action Matrix in the third quarter of 2016 and remained in the Regulatory Response Column (Column 2) of the NRCs Action Matrix through the second quarter of 2018, as a result of one White Unplanned Scrams per 7000 Critical Hours (Initiating Events Cornerstone) performance indicator.

On May 8, 2018, the licensee informed the NRC that they were ready for the follow-up supplemental inspection. In preparation for the inspection, the licensee completed revisions to three of the RCEs in the scope of the original 95001 inspection. A brief summary of each RCE evaluation within the scope of the reinspection and the changes made as a result of the weaknesses identified in the original 95001 inspection follows.

(1) CR-GGN-2016-02950, Startup From RF20 B Phase Current Differential Relay Scram, Revision 2 (Unplanned Scram on March 29, 2016)

On March 29, 2016, during a power ascension for a unit startup following a refueling outage, a main generator lockout was received followed by a turbine control valve fast closure, which resulted in an uncomplicated reactor scram. The main generator lockout was the result of the B main transformer current differential relay trip being actuated.

Subsequent licensee investigation determined the direct cause of the event to be a mis-wiring of the B main transformer current transformer as a result of work performed during the refueling outage.

RCE CR-GGN-2016-02950 was revised to eliminate one of the two root causes, to expand the remaining root cause, and to add an additional contributing cause.

(2) CR-GGN-2016-04766, Unintended Oscillating Power Range Monitor (OPRM) Reactor SCRAM due to Reactor Pressure and Power Oscillations, Equipment Failure Evaluation, Revision 2 (Unplanned Scram on June 17, 2016)

On June 17, 2016, during planned main turbine stop and control valve surveillance testing, the B turbine stop valve was fast closed as procedurally directed. While attempting to reset the B turbine stop valve, the D turbine stop valve unexpectedly closed resulting in a Division 2 reactor protection system half scram. Due to the inability of the remaining two functional turbine control valves to control turbine load; reactor pressure, water level, and power began to oscillate.

Reactor pressure oscillated 20 psig peak-to-peak and reactor power oscillated 10-20 percent peak-to-peak. The oscillations lasted for approximately 39 minutes prior to a neutron monitoring system OPRM trip occurring, resulting in a reactor scram.

Subsequent licensee investigation determined the direct cause of the closure of the D turbine stop valve to be a reset solenoid valve within the turbine control system sticking in a position that opened a drain path allowing the depressurization of the trip fluid supply header.

RCE CR-GGN-2016-04766 was revised to change the root cause, to expand the extent of condition and extent of cause reviews, and to change the effectiveness review assigned to the root cause and associated Corrective Action to Prevent Recurrence (CAPR).

(3) CR-GGN-2016-04834, OPRM Reactor SCRAM, Operator Response to Equipment Failure Evaluation, Revision 3 (Unplanned Scram on June 17, 2016)

On June 17, 2016, during main turbine stop valve testing, reactor power, pressure, and level oscillations occurred for approximately 39 minutes without operator action until an automatic OPRM initiated reactor scram occurred arresting the oscillations. The operations shift crew did not manually scram the reactor when reactor power, pressure, and level were oscillating abnormally, resulting in an automatic scram.

RCE CR-GGN-2016-04834 was revised to reperform the internal and external operating experience reviews and to appropriately perform and document completion of a number of corrective actions (CAs) found to be deficient during the original 95001 inspection.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 95001Supplemental Inspection Response to Action Matrix Column 2 Inputs Inspectors reviewed the licensees root causes, contributing causes, extent of condition, and extent of cause determinations. Inspectors assessed whether the licenses corrective actions to address the root and contributing causes were sufficient to prevent recurrence. The highlights of the performance review and NRCs assessment are documented below.

(1) Problem Identification a) Determine that the evaluation documented who identified the issue and under what conditions the issue was identified.

Each of the events within the scope of the inspection were the result of self-revealed issues. The inspectors determined that the licensees evaluations documented who identified the issues and under what conditions the issues were identified.

This 95001 inspection requirement was closed by previous inspection.

b) Determine the evaluation documented how long the issue existed and prior opportunities for identification.

The licensees evaluations of the events documented when the issues originated, documented the circumstances in which each issue could have been previously identified, and documented the conditions, when applicable, involving similar events that had occurred at the station. The inspectors determined that the licensees evaluations were adequate with respect to identifying how long the issues existed and if there were any prior opportunities for identification.

This 95001 inspection requirement was closed by previous inspection.

c) Determine that the evaluation documented significant plant-specific consequence, as applicable, and compliance concerns associated with the issue.

The licensees evaluations included a plant-specific, risk-informed safety significance evaluation of the issues. In each safety evaluation, the licensee discussed the consequences of each event with respect to the plant, as well as the consequences to the general publics safety, nuclear safety, industrial safety, and radiological safety. The inspectors concluded that the licensee appropriately documented the risk consequences and compliance concerns associated with each issue.

This 95001 inspection requirement was closed by previous inspection.

(2) Root Cause, Extent-of-Condition, and Extent-of-Cause Evaluation a) Determine that the problem was evaluated using a systematic methodology to identify the root and contributing causes.

During the initial 95001 inspection, the NRC supplemental inspection team determined that for RCE CR-GGN-2016-04766, the licensee did not identify, understand, or adequately evaluate a root cause. Additionally, Entergy Procedure EN-LI-118, Cause Evaluation Process, Revision 26, which requires that a root cause represent the most basic reason for the failure, problem, or deficiency which, if corrected, would preclude repetition, was not satisfied (Significant Weakness 1).

In order to address this deficiency, Entergy reevaluated the root cause and developed two new root causes. Root Cause 1 determined that the procedure review process in place at the time of the development of the procedure used to carry out the turbine testing did not adequately describe attributes of a technical review. Additionally, Root Cause 1 determined that work instructions lacked clarity the work instructions did not include, within the body of the work instruction package, guidance for documenting the installation and removal of jumpers (lifted/landed lead sheets). This was due to a failure of the work instruction planner to follow established guidance and instructions.

The inspectors determined that identifying the procedure review process as a root cause satisfied the intent of the 95001 inspection objective and the requirements of Procedure EN-LI-118. However, the inspectors questioned the identification of a personnel error, failure of a work instruction planner to follow established guidance and instructions, as a root cause.

The cause of the inadequate work instruction was attributed to the failure of the work planner to follow relevant guidance documents during planning. The inspectors determined that the procedural changes made to Procedure EN-WM-105,Planning, Revision 20, and credited as the CAPR did not meet the intent of a CAPR. The changes to Procedure EN-WM-105, a fleet procedure, were similar in nature to, but less restrictive than, requirements already contained in several site level procedures in place at the time.

The inspectors also questioned whether the identified root cause (work instructions lacked clarity due to a failure of a planner to follow established guidance and procedures) would be more appropriately categorized as a contributing cause, as suggested in General Weakness 1 of the original 95001 inspection.

After review of the NRC identified deficiencies, Entergy revised the root cause, eliminating the one-time work planning human performance error as a root cause and adding the following contributing cause:

The planner did not properly revise the work instructions in accordance with EN-WM-105, Planning, when it was evident that the work instructions required a revision. Additionally, work instructions did not include, within the body of the work instruction package, guidance for documenting the installation and removal of jumpers.

In addition to the previously assigned CA (revise EN-WM-105, Planning), a new CA was assigned that requires increased planning supervision review and concurrence for critical maintenance and Level 1 work order (WO) instruction revisions (CR-GGN-2018-07510). After review of the changes, the inspectors determined that the licensees efforts to identify the root and contributing causes met the objectives of the 95001 inspection procedure.

This 95001 inspection requirement is closed.

b) Determine that the root cause evaluation was conducted to a level of detail commensurate with the significance of the problem.

The licensees RCEs included sufficient information for each event regarding event timelines, event descriptions, previous occurrences, missed opportunities, and analysis discussion. Each RCE used multiple evaluation methodologies to ensure the level of detail matched the significance of each event. The inspectors determined that the RCEs were conducted to a level of detail commensurate with the significance of the problems discussed.

This 95001 inspection requirement was closed by previous inspection.

c) Determine that the root cause evaluation included a consideration of prior occurrences of the problem and knowledge of prior operating experience.

During the initial 95001 inspection, a general weakness was documented identifying deficiencies in Entergys internal and external operating experience reviews associated with CR-GGN-2016-04834 (General Weakness 2). Entergy revised their evaluation and expanded the operating experience search criteria in consultation with outside experts. The expanded search yielded two additional CRs related to the RCE that were incorporated into the review. No deficiencies were noted by the inspectors with the actions taken by the licensee to address the general weakness.

This 95001 inspection requirement is closed.

d) Determine that the root cause evaluation addressed the extent of condition and the extent of cause of the problem.

During the initial 95001 inspection, the inspectors identified that the extent of cause evaluation performed as part of RCE CR-GGN-2016-04766 was inadequate. The RCE determined the extent of cause to be instructions were developed allowing the use of a force amplifying tool to manually operate automatic turbine test solenoid valves. The adverse effect of tool usage on the solenoid valve and alternate manual testing methods, where use of the tool was not required, were not considered.

When the extent of cause evaluation was performed, only the use of nonstandard tools on plant equipment that can affect reactor pressure, level, and power was extended. The inspection team concluded that this was an inappropriately narrow extent of cause. A more appropriate bounding condition could serve to identify instances of nonstandard tools on other equipment with safety and/or risk significance outside of equipment only impacting reactor pressure, level, and power.

As a result of the identified general weakness (General Weakness 3), Entergy revised RCE CR-GGN-2016-04766 and, in part, reperformed the extent of cause evaluation resulting in a new extent of cause that was broader in scope and included risk significant safety systems as well as plant transient initiators. After review of the changes, the inspectors determined that Entergys revised extent of cause evaluation adequately addressed the extent of cause of the identified root causes. No deficiencies were noted with the actions taken by the licensee to address the general weakness.

This 95001 inspection requirement is closed.

e) Determine that the root cause, extent of condition, and extent of cause evaluation appropriately considered the safety culture traits in NUREG-2165, Safety Culture Common Language, referenced in IMC 0310, Aspects within Cross-Cutting Areas.

The licensees RCEs included a review of whether a weakness in any safety culture component contributed to the issues. The licensees evaluations identified weaknesses in safety culture components that were related to the identified root causes and contributing causes. The licensee established adequate corrective actions to address the safety culture weaknesses that were identified. The inspectors concluded that the licensees evaluation appropriately considered safety culture components.

This 95001 inspection requirement was closed by previous inspection.

f) Examine the common cause analyses for potential programmatic weaknesses in performance when a licensee has a second White input in the same cornerstone.

The licensee does not have a second White input in the same cornerstone; therefore, this inspection objective is not applicable.

(3) Corrective Actions a) Determine that appropriate corrective actions are specified for each root and contributing cause or that the licensee has an adequate evaluation for why no corrective actions are necessary.

The licensees RCEs identified corrective actions to address root and contributing causes. The inspectors reviewed each of the corrective actions and determined they adequately addressed the identified root and contributing causes.

This 95001 inspection requirement was closed by previous inspection.

b) Determine that the corrective actions have been prioritized with consideration of significance and regulatory compliance.

The licensees immediate corrective actions following each event restored the impacted systems to an operable and/or functional condition in order to restore compliance with plant technical specifications and applicable procedures. The inspectors reviewed the prioritization of the corrective actions and verified that actions of a generally higher priority were scheduled for completion ahead of those of a lower priority. Additionally, the inspectors determined that the licensees evaluations addressed regulatory compliance issues. The inspectors concluded that the licensee adequately prioritized the corrective actions with consideration of the risk significance and regulatory compliance.

This 95001 inspection requirement was closed by previous inspection.

c) Determine that corrective actions taken to address and preclude repetition of significant performance issues are prompt and effective.

The initial 95001 inspection identified a significant weakness associated with RCE CR-GGN-2016-02950. The RCE the licensee staff performed as a result of the event did not generate corrective actions that were adequate to preclude repetition of the event, which the licensee determined to be caused by inadequacies in supervision and work instruction use and adherence by supplemental personnel (Significant Weakness 2).

The assigned CAPR for RCE CR-GGN-2016-02950 included revising Procedure EN-MA-100, Maintenance Fundamentals Program, Revision 4, to include an attachment defining the essential knowledge, skills, behaviors, and practices personnel need to apply to conduct their work properly.

The intent of the CAPR included, ensuring that maintenance personnel, supplemental personnel, and oversight and supervisors are aware of and execute the requirements found in Procedure EN-MA-100, as well as to, ensure supervisors and supplemental oversight personnel for electrical or instrumentation and control maintenance are cognizant and proficient with reinforcing the skills and behaviors regarding the fundamentals for lifting and landing of leads and configuration control.

Assigned corrective actions associated with the CAPRs included generating a case study to be presented on a one time basis to personnel and supervisors on site, as well as holding a one-time site-wide mandatory briefing for personnel on site. The inspectors noted that the one-time site-wide briefing did not address the root causes of inadequacies in supervision and work instruction use and adherence. This was because the briefing contained superseded root causes from a previous revision to RCE CR-GGN-2016-02950.

The inspectors also questioned the adequacy of solely adding an attachment to Procedure EN-MA-100, to prevent work instruction use and adherence deficiencies.

The inspectors did not identify any corrective actions serving to make nonsupervisory personnel aware of the addition. It was also unclear to the inspectors how this case study would be presented, if at all, to supplementary supervision temporarily on site during refueling outages and other maintenance activities.

After review of Entergys revised RCEs, the inspectors were unable to identify any changes that would serve to resolve the concerns identified in Significant Weakness 2.

After review of the NRC-identified deficiency during the reinspection, Entergy revised the RCE, crediting actions previously put in place for a different but similar event and creating new actions. Assigned actions included highlighting procedure compliance requirements during supplemental worker in-processing, revising the supervisor oral board process to ensure maintenance fundamentals and the role of the supervisor are adequately addressed, conducting a training needs analysis to ensure existing maintenance fundamental training is analyzed and revised as appropriate to address the CAPR, and verifying actions being tracked outside of the corrective action program (training needs analysis, develop maintenance fundamental training for craft, deliver maintenance fundamental training) have been closed with rigor and quality (CR-GGN-2018-07525). The inspectors reviewed these changes and determined that they satisfied the inspection objectives.

This 95001 inspection requirement is closed.

d) Determine that each Notice of Violation (NOV) related to the supplemental inspection is adequately addressed, either in corrective actions taken or planned.

No NOV was issued related to this supplemental inspection; therefore, this inspection item was not applicable.

(4) Corrective Action Plans a) Determine that appropriate corrective action plans are specified for each root and contributing cause or that the licensee has an adequate evaluation for why no corrective actions are necessary. Determine that the corrective action plans have been prioritized with consideration of significance and regulatory compliance.

The initial 95001 inspection determined that several CAs associated with RCE CR-GGN-2016-04834 had responses that were not sufficient or did not meet the intent statement in the CA (General Weakness 4). These included CAs related to training requirements, an engineering self-assessment, and procedures. The licensee took robust corrective actions for several of the CAs - these included procedural revisions, a formal engineering self-assessment, training needs assessments, and additional requirements in the long-range training plan. The inspectors determined that these corrective actions were sufficient to meet the intent statement in the CAs. The inspectors reviewed the changes and determined that they satisfied the inspection objectives.

This 95001 inspection requirement is closed.

b) Determine that corrective plans direct prompt actions to effectively address and preclude repetition of significant performance issue.

The licensees RCEs included numerous corrective action plans to ensure that significant performance issues are effectively addressed. These corrective action plans included multiple CAPRs. The inspectors reviewed the CAPRs and other corrective action plans and determined that the licensee established a formal tracking mechanism for each specific open corrective action. When establishing and prioritizing corrective action plans, the licensee considered the significance assessment results of the different performance issues. As a result, the inspectors determined that the corrective action plans directed prompt actions to effectively address and preclude repetition of significant performance issues.

This 95001 inspection requirement was closed by previous inspection.

c) Determine that appropriate quantitative or qualitative measures of success have been developed for determining the effectiveness of planned and completed corrective actions.

The initial 95001 inspection determined that the effectiveness review criteria developed for the corrective actions taken for RCE CR-GGN-2016-04766 were not adequate (General Weakness 5). The licensee had developed one measure of success to determine the effectiveness of completed corrective actions. The attribute to measure was, nonstandard tool use to operate plant equipment causing plant transient greater than 5 percent, with a success criteria of, No occurrences of plant transient greater than 10 percent caused by use of a nonstandard tool to operate plant equipment. This was to be assessed for 12 months. The inspectors considered this effectiveness measure to be too narrowly focused, given that the intent of the corrective actions was to eliminate or assess the use of non-standard tools in plant procedures. Further, it is unclear why additional instance(s) of nonstandard tool use resulting in plant transients would be acceptable (i.e., meet the success criteria for this effectiveness measure) as long as the transient was below 10 percent.

As a result of the weakness identified in the original 95001 inspection, the inspectors noted that RCE CR-GGN-2016-04766 identified two new root causes. Root Cause 1 states that, the procedure revision procedure (01-S-02-3) was inadequate in that it did not adequately describe attributes of a technical review. This allowed a procedure revision that introduced the use of a new tool to perform actions of the procedure without considering the adverse consequences. Entergy considered this to be a latent condition, and as such, did not assign an effectiveness review.

Root Cause 2 states, excessive force applied to the reset solenoid valvecaused the valve to move to an overtravel position resulting in... the unanticipated closure of a second stop valve. The assigned effectiveness measure addressing this root causes CAPRs was performance of Main Turbine Stop/Control valve testing does not adversely impact plant operation with a success criteria of no unexpected valve motion or RPS actuation during performance of tests for a period of four surveillance intervals.

Procedure EN-LI-118, Cause Evaluation Process, Revision 26, Section 5.7, states effectiveness review plans are required for CAPRs and optional for other types of corrective actions. The inspectors noted that an effectiveness review was not performed for the CAPRs credited to Root Cause 1. Despite Root Cause 1 and its CAPRs being identified as a latent condition, Procedure EN-LI-118 requires that an effectiveness review be performed. An appropriate effectiveness review, such as validating that no plant transients or impacts on risk significant equipment were caused by the usage on nonstandard tools, would serve to validate the CAPRs.

After reviewing the NRC-identified deficiency, Entergy revised the root cause during the reinspection. An effectiveness review was added to Root Cause 1: Non-standard tool usage does not impact plant operation or safety system function with a success criteria of no transient or safety system functional failure attributed to non-standard tool usage during operating cycle 22. (CR-GGN-2018-07452). After review of the revised RCE, the inspectors determined that the appropriate quantitative or qualitative measures of success have been developed for determining the effectiveness of planned and completed corrective actions.

This 95001 inspection requirement is closed.

d) Determine that each Notice of Violation (NOV) related to the supplemental inspection is adequately addressed in corrective actions taken or planned.

As discussed in Section 3.d (above), no NOV was issued related to this supplemental inspection; therefore, this inspection item was not applicable.

(5) Evaluation of IMC 0305 Criteria for Treatment of Old Design Issues.

Not applicable; the performance deficiency associated with the White performance indicator does not warrant treatment as an old design issue.

This 95001 inspection requirement was closed by previous inspection.

EXIT MEETINGS AND DEBRIEFS

On June 28, 2018, the inspectors presented the supplemental inspection results to Mr. E. Larson, Site Vice President, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

DOCUMENTS REVIEWED

95001: Supplemental Inspection Response to Action Matrix Column 2 Inputs

Miscellaneous Documents

Number Title Revision

2017-2019 License Operator Requalification Long Range Training Plan

GSMS-LOR- Bypass Valve Inop / 6A Feedwater Heater Tube Leak / Loss 4

247 of Feedwater Heating / LOCA / EP-2A Loss of Level

Indication

Procedures

Number Title Revision

01-S-02-3 Authors Guide 121

EN-FAP-OU-111 Critical Maintenance Identification 6

EN-LI-102 Corrective Action Program 24

EN-LI-104 Self-Assessment and Benchmark Process 14

EN-LI-118 Cause Evaluation Process 26

EN-LI-121 Trend Codes 26

EN-MA-101 Conduct of Maintenance 26

EN-MA-126 Management and Oversight of Supplemental Personnel 6

EN-TQ-119 Maintenance Training Program 11

EN-WM-105 Planning 20

Condition Reports (CRs)

CR-GGN-2015-02061 CR-GGN-2016-00859 CR-GGN-2016-02950 CR-GGN-2016-04766

CR-GGN-2016-04834 CR-GGN-2017-00486 CR-GGN-2017-08253 CR-GGN-2018-00918

CR-GGN-2018-04934 CR-GGN-2018-05485 CR-GGN-2018-07452

LIST OF ACRONYMS

ADAMS Agencywide Document Access and Management System

CA Corrective Action

CAPR Corrective Action to Prevent Recurrence

CFR Code of Federal Regulations

IMC Inspection Manual Chapter

LIST OF ACRONYMS

IP Inspection Procedure

PI Performance Indicator

NOV Notice of Violation

NRC Nuclear Regulatory Commission

OPRM Oscillating Power Range Monitor

RCE Root Cause Evaluation

ROP Reactor Oversight Process

WO Work Order

ML18211A174

SUNSI Review Non-Sensitive Publicly Available Keyword:

By: CHY/rdr Sensitive Non-Publicly Available NRC-002

OFFICE SRI:DRP/A SRI:DRP/A PE:DRP/A SPE:DRP/C BC:DRP/C D:DRP

NAME CNewport JJosey AAthar CYoung JKozal TVegel

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 7/19/2018 7/23/2018 7/20/2018 7/18/2018 7/26/2018 8/1/18