Text

IR 05000416-11-002; on 01/21/2011 03/27/2011; Grand Gulf Nuclear Station, Integrated Resident and Regional Report; Fire Protection, Maintenance Effectiveness, Radiological Hazard Assessment and Exposure Controls, and Event Follow-Up
	ML111300462
Person / Time
Site:	Grand Gulf
Issue date:	05/10/2011
From:	Vincent Gaddy; NRC/RGN-IV/DRP/RPB-C
To:	Mike Perito; Entergy Operations
References
	IR-11-002
	Download: ML111300462 (61)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGI ON I V

612 EAST LAMAR BLVD, SUITE 400

ARLINGTON, TEXAS 76011-4125

May 10, 2011

Mr. Mike Perito

Vice President Operations

Entergy Operations, Inc.

Grand Gulf Nuclear Station

P.O. Box 756

Port Gibson, MS 39150

Subject: GRAND GULF NRC INTEGRATED INSPECTION REPORT NUMBER

05000416/2011002

Dear Mr. Perito:

On March 27, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Grand Gulf Nuclear Station. The enclosed integrated inspection report documents the

inspection findings, which were discussed on April 14, 2011, with Mike Perito, Vice President

Operations, and other members of your staff.

The inspections examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

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

personnel.

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

violation of NRC requirements occurred. The NRC has also identified five issues that were

evaluated under the risk significance determination process as having very low safety

significance (Green). The NRC has determined that four of these findings have violations

associated with these issues. Additionally, one licensee-identified violation, which was

determined to be of very low safety significance, is listed in this report. However, because of

their very low safety significance and because they were entered into your corrective action

program, the NRC is treating these findings as noncited violations, consistent with Section 2.3.2

of the NRC Enforcement Policy.

If you contest the significance of the noncited violations, you should provide a response within

30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with

copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV,

612 E. Lamar Blvd, Suite 400, Arlington, Texas, 76011-4125; the Director, Office of

Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the

NRC Resident Inspector at the facility. In addition, if you disagree with the cross-cutting aspect

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

Entergy Operations, Inc. -2-

of this inspection report, with the basis for your disagreement, to the Regional Administrator,

Region IV, and the NRC Resident Inspector at the facility.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosures, and your response, if you choose to provide one, will be made available

electronically for public inspection in the NRC Public Document Room or from the NRC's

document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html. To the extent possible, your response should not include any personal privacy

or proprietary, information so that it can be made available to the Public without redaction.

Sincerely,

/RA/

Vincent Gaddy, Chief

Project Branch C

Division of Reactor Projects

Docket: 50-416

License: NPF-29

Enclosed: NRC Inspection Report 05000416/2011002

w/Attachment: Supplemental Information

Distribution via ListServe

Entergy Operations, Inc. -3-

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

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

DRP Director (Kriss.Kennedy@nrc.gov)

DRP Deputy Director (Troy.Pruett@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

Senior Resident Inspector (Rich.Smith@nrc.gov)

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

Senior Project Engineer, DRP/C (Bob.Hagar@nrc.gov)

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

GG Administrative Assistant (Alley.Farrell@nrc.gov)

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

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

Project Manager (Alan.Wang@nrc.gov)

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

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

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

RIV OEDO/ETA (Stephanie Bush-Goddard@nrc.gov)

OEMail Resource

ROP Reports

File located: R:\_REACTORS\_GG\GG 2011002 RP-RLS-vgg.docx

SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials VGG

Publicly Avail Yes No Sensitive Yes No Sens. Type Initials VGG

SRI:DRP/PBC SPE:DRP/PBC C:DRS/EB1 C:DRS/EB2

RLSmith BHagar TRFarnholtz NFOKeefe

/RA/RCHagar for /RA/ /RA/ /RA/

5/4/2011 5/4/2011 4/21/2011 4/15/2011

C:DRS/OB C:TSS C:DRS/PSB1 C:DRS/PSB2 C:ACES/SAC

MHaire MHay MPShannon GEWerner NTaylor

/RA/ /RA/ /RA/ /RA/ /RA/

4/15/2011 4/18/2011 4/18/2011 4/15/2011 4/18/2011

C:DRP/C

VGaddy

/RA/

5/10/11

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000416

License: NPF-29

Report: 05000416/2011002

Licensee: Entergy Operations, Inc.

Facility: Grand Gulf Nuclear Station

Location: 7003 Baldhill Road

Port Gibson, MS 39150

Dates: January 21, 2011, through March 27, 2011

Inspectors: R. Smith, Senior Resident Inspector

M. Baquera, Resident Inspector, Palo Verde

A. Fairbanks, Reactor Inspector

C. Graves, Health Physicist

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

E. Uribe, Reactor Inspector

Approved By: Vincent Gaddy, Chief, Project Branch C

Division of Reactor Projects

-1- Enclosure

SUMMARY OF FINDINGS

IR 05000416/2011002; 1/1/2011 - 3/27/2011; Grand Gulf Nuclear Station, Integrated Resident

and Regional Report; Fire Protection, Maintenance Effectiveness, Radiological Hazard

Assessment and Exposure Controls, and Event Follow-Up.

The report covered a 3-month period of inspection by resident inspectors and an announced

baseline inspection by region-based inspectors. Five Green noncited violations of significance

were identified and one Green finding of significance was identified. The significance of most

findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual

Chapter 0609, Significance Determination Process. The cross-cutting aspect is determined

using Inspection Manual Chapter 0310, Components Within the Cross Cutting Areas. Findings

for which the significance determination process does not apply may be Green or be assigned a

severity level after NRC management review. The NRC's program for overseeing the safe

operation of commercial nuclear power reactors is described in NUREG-1649, Reactor

Oversight Process, Revision 4, dated December 2006.

A. NRC-Identified Findings and Self-Revealing Findings

Cornerstone: Mitigating Systems

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

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

months, to reflect changes made in the facility or procedures described in the

final safety analysis report. Licensee personnel failed to update the original

revision of the final safety analysis report to reflect the actual number of low

pressure coolant injection loops available for automatic initiation during shutdown

cooling operations in Mode 3. The licensee plans to update the final safety

analysis report at the next scheduled revision. This finding was entered into the

licensees corrective action program as condition report CR-GGN-2011-01631.

The failure of licensing personnel to update the final safety analysis report to

reflect the available low pressure coolant injection loops for automatic initiation

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

This finding was evaluated using traditional enforcement because it had the

potential for impacting the NRCs ability to perform its regulatory function. The

inspectors used the NRC Enforcement Policy, dated September 30, 2010, to

evaluate the significance of this violation. Consistent with the NRC Enforcement

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

Green. The inspectors identified a noncited violation of 10 CFR Part 50.65(a)(2)

for the licensees failure to demonstrate that the performance of the train B

control room air conditioner was being effectively controlled through the

performance of appropriate preventive maintenance. Engineering did not

properly evaluate maintenance rule functional failures resulting in the system

remaining in an a(2) status instead of an a(1) status. As corrective action, the

-2- Enclosure

train B control room air conditioner was moved into an a(1) status. The licensee

entered this issue into their corrective action program as Condition Report

CR-GGN-2011-01623.

The finding was more than minor because it was associated with the equipment

performance attribute of the Mitigating Systems Cornerstone and adversely

affected the cornerstone objective to ensure the availability, reliability, and

capability of systems that respond to initiating events to prevent undesirable

consequences. Inspectors performed a Phase 1 screening, in accordance with

Inspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and

Characterization of Findings, and determined that the finding was of very low

safety significance (Green) because the maintenance rule aspect of the finding

did not cause an actual loss of safety function of the system nor did it cause a

component to be inoperable. As corrective action, the train B control room air

conditioner was moved into an (a)(1) status. This finding had a crosscutting

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

component because licensee personnel failed to make appropriate safety-

significant or risk-significant decisions to address the multiple failures of the train

B control room air conditioner compressor. H.1(a) (Section 1R12.b.2)

Green. The inspectors reviewed a self-revealing noncited violation of 10 CFR

Part 50, Appendix B, Criterion XVI, Corrective Action, after the licensee failed to

determine the cause and prevent recurrence of a significant condition adverse to

quality associated with the train B control room air conditioner compressor

tripping due to low oil pressure. Specifically, on December 13, 2010, the train B

control room air conditioner compressor tripped on low oil pressure after the

licensee had performed a root cause analysis to identify the cause and prevent

recurrence of a similar compressor trip on October 14, 2010. As immediate

corrective action, the licensee installed an inline suction filter. No additional

failures have occurred since its installation. The finding was entered into the

licensees corrective action program as Condition Report CR-GGN-2010-07315.

This finding was more than minor because it was associated with the equipment

performance attribute of the Mitigating Systems Cornerstone and adversely

affected the cornerstone objective to ensure the availability, reliability, and

capability of systems that respond to initiating events to prevent undesirable

consequences. Using Inspection Manual Chapter 0609, "Significance

Determination Process," Phase 1 worksheets, the inspectors determined that a

Phase 2 analysis was required because the finding represented a loss of system

safety function. The plant-specific risk informed notebook does not include the

evaluation of risk caused by the loss of cooling to the main control room.

Therefore, the senior reactor analyst conducted a Phase 3 analysis. Based on

the bounding analysis, the analyst determined that the change in core damage

frequency result was 5.9 x 10-7. This noncited violation was therefore determined

to be of very low safety significance (Green). This finding had a crosscutting

aspect in the area of problem identification and resolution associated with the

corrective action program component because licensee personnel failed to

-3- Enclosure

thoroughly evaluate the multiple failures of the train B control room air conditioner

compressor. P.1(c) (Section 4OA3.1.b)

Cornerstone: Barrier Integrity

Green. The inspectors identified a noncited violation of Facility Operating License

Condition 2.C(41), involving the failure to ensure that transient combustible were

not stored in the fire exclusion zone near the independent spent fuel storage

installation. The inspectors performed a quarterly fire protection inspection of

independent spent fuel storage installation and identified a large air conditioner

with combustible material covering it located in the fire exclusion zone that was

within 60 feet of the dry fuel storage pad. The inspectors determined through

interviews that the material had been placed there the previous day by the

maintenance department. As immediate corrective action the licensee removed

the combustible material from the area. The finding was entered into the

licensees corrective action program as Condition Report CR-GGN-2011-00455.

This finding was more than minor because it was associated human performance

attribute of the Barrier Integrity Cornerstone to provide reasonable assurance

that physical design barriers protect the public from radionuclide releases caused

by accidents or events. Using Manual Chapter 0609, Appendix F, Fire

Protection Significance Determination Process, the inspectors determined that

the finding impacted the fire prevention and administrative controls category.

The inspectors assigned a low degradation rating due to the fact that the amount

of combustible material in the area was minimal. The inspectors concluded that

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

no fire ignition sources in the area. The cause of this finding has a crosscutting

aspect in the area of human performance associated with the work practices

component because the licensee failed to effectively communicate expectations

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

(Section 1R05.1.b)

Green. The inspectors reviewed a self-revealing, Green finding of EN-DC-115,

Engineering Change Process, involving the failure to maintain adequate design

control measures associated with the installation of the mitigation monitoring

system. On November 8, 2010, a reactor coolant pressure boundary failure

occurred at the skid mounted Online Noble Chemical - Mitigation Monitoring

System pump inside primary containment. The positive displacement sample

pump ejected the pump piston from the housing, resulting in an approximate

7 gpm leak of reactor coolant. The steam leak resulted in a reactor recirculation

system flow control valve lockup (due to hydraulic power unit motor failure) and

approximately 15,000 square feet of contaminated area in the primary

containment structure. The licensee failed to ensure proper validation testing for

the pump prior to installation. Specifically, the licensee did not ensure that the

pump could withstand the operating pressures and temperatures of the system in

-4- Enclosure

which it was installed. The licensee removed the mitigation monitoring system

from service and isolated the skid from the reactor water cleanup system. This

finding was entered into the licensees corrective action program as Condition

Report CR-GGN-2010-07852.

The finding is more than minor because it affects the design control attribute of

the Barrier Integrity Cornerstone to provide reasonable assurance that physical

design barriers protect the public from radionuclide releases caused by accidents

or events. Therefore, using inspection Manual Chapter 0609, "Significance

Determination Process," Phase 1 Worksheet for LOCA initiators, the inspectors

concluded that the finding was of very low safety significance (Green) because

the failure of the mitigation monitoring system would not have exceeded technical

specifications limits for identified leakage in the reactor coolant system. This

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

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

of the mitigation monitoring system such that nuclear safety is supported. H.4(c)

(Section 4OA3.2.b)

Cornerstone: Occupational Radiation Safety

Green. The inspectors identified a noncited violation of Technical Specification 5.7.2, resulting from the licensees failure to use a qualified radiation protection

technician to provide direct continuous coverage of work in a locked high

radiation area. The finding was placed into the corrective action program as

Condition Report CR-GGN-2011-01045, and corrective action was being

evaluated.

The failure to use a qualified radiation protection technician to provide direct

continuous coverage of work in a locked high radiation area is a performance

deficiency. The finding was more than minor because it was associated with the

Occupational Radiation Safety Cornerstone attribute (exposure control) of

program and process and affected the cornerstone objective, in that, the failure

to use qualified radiation protection technicians to provide job coverage in a high

radiation area with dose rates in excess of 1000 mrem/hr had the potential to

increase personnel dose. Using the Occupational Radiation Safety Significance

Determination Process, the inspectors determined the finding to have very low

safety significance because: (1) it was not associated with ALARA planning or

work controls, (2) there was no overexposure, (3) there was no substantial

potential for an overexposure, and (4) the ability to assess dose was not

compromised. (Section 2RS01.b)

B. Licensee-Identified Violations

Violations of very low safety significance, which were identified by the licensee, have

been reviewed by the inspectors. Corrective actions taken or planned by the licensee

have been entered into the licensees corrective action program. These violations and

corrective action tracking numbers (condition report numbers) are listed in

Section 4OA7.

-5- Enclosure

REPORT DETAILS

Summary of Plant Status

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

9, 2011, operators reduced power to 68 percent for a planned control rod sequence exchange

and isolation of the moisture separator reheaters (MSRs) second stage steam to both the A

and B MSRs due to tube leaks in the A MSR. The plant was returned to 96 percent power on

January 10, 2011, which was maximum power level allowed with MSR second stage steam

isolated. On February 18, 2011, operators reduced power to 77 percent for monthly control rod

testing, turbine testing, and to remove B heater drain pump from service in an attempt to repair

a steam leak on the heater drain pump B discharge flange. The plant was returned to 96

percent power on February 19, 2011. On March 11, 2011, operators reduced power to 84

percent power for a planned control rod testing and to remove B heater drain pump from

service in another attempt to repair a steam leak on the heater drain pump B discharge flange.

The plant was returned to 96 percent power on March 12, 2011. On March 23, 2011, operators

reduced power to 93 percent power to remove the B heater drain pump from service again in

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

The plant was returned to 96 percent power on March 12, 2011. The plant remained at 96

percent power for the remainder of the inspection period.

1. REACTOR SAFETY

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

Emergency Preparedness

1R01 Adverse Weather Protection (71111.01)

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors performed a review of the adverse weather procedures for seasonal

extreme low temperatures. The inspectors verified that weather-related equipment

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

seasonal extremes, and evaluated the implementation of the adverse weather

preparation procedures and compensatory measures for the affected conditions before

the onset of, and during, the adverse weather conditions.

During the inspection, the inspectors focused on plant-specific design features and the

procedures used by plant personnel to mitigate or respond to adverse weather

conditions. Additionally, the inspectors reviewed the updated final safety analysis report

and performance requirements for systems selected for inspection and verified that

operator actions were appropriate as specified by plant-specific procedures. Specific

documents reviewed during this inspection are listed in the attachment. The inspectors

also reviewed corrective action program items to verify that plant personnel were

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

-6- Enclosure

their corrective action program in accordance with station corrective action procedures.

The inspectors reviews focused specifically on the following plant systems:

Standby service water

Emergency diesel generators

Plant service water

Fire water pumps and tanks

These activities constitute completion of one readiness for seasonal adverse weather

sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

Since extreme cold conditions and icing were forecast in the vicinity of the facility for

January 9, 2011, the inspectors reviewed overall preparations/protection for the

expected weather conditions. On January 7, 2011, the inspectors inspected the standby

service water towers because their safety-related functions could be affected as a result

of the extreme cold and icing conditions forecast for the facility. The inspectors observed

space heater operation and weatherized enclosures to ensure operability of affected

systems. The inspectors reviewed licensee procedures and discussed potential

compensatory measures with control room personnel. The inspectors focused on plant

managements actions for implementing the stations procedures for ensuring adequate

personnel for safe plant operation and emergency response would be available.

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

These activities constitute completion of one readiness for impending adverse weather

condition sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings were identified.

1R04 Equipment Alignments (71111.04)

.1 Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant

systems:

Division II standby service water system during Division I maintenance outage

-7- Enclosure

Residual heat removal system B during residual heat removal system A

maintenance outage

Residual heat removal system C during residual heat removal system A

maintenance outage

Division II standby diesel generator system during Division I maintenance outage

Standby liquid control system A during standby liquid control system B

maintenance outage

The inspectors selected these systems based on their risk significance relative to the

reactor safety cornerstones at the time they were inspected. The inspectors attempted

to identify any discrepancies that could affect the function of the system, and, therefore,

potentially increase risk. The inspectors reviewed applicable operating procedures,

system diagrams, UFSAR, technical specification requirements, administrative technical

specifications, outstanding work orders, condition reports, and the impact of ongoing

work activities on redundant trains of equipment in order to identify conditions that could

have rendered the systems incapable of performing their intended functions. The

inspectors also inspected accessible portions of the systems to verify system

components and support equipment were aligned correctly and operable. The

inspectors examined the material condition of the components and observed operating

parameters of equipment to verify that there were no obvious deficiencies. The

inspectors also verified that the licensee had properly identified and resolved equipment

alignment problems that could cause initiating events or impact the capability of

mitigating systems or barriers and entered them into the corrective action program with

the appropriate significance characterization. Specific documents reviewed during this

inspection are listed in the attachment.

These activities constitute completion of five partial system walkdown samples as

defined in Inspection Procedure 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection (71111.05)

Quarterly Fire Inspection Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns that were focused on availability,

accessibility, and the condition of firefighting equipment in the following risk-significant

plant areas:

Division II diesel generator room (1D303)

-8- Enclosure

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

Residual heat removal pump and heat exchanger rooms B (1A105 and 1A106)

Reactor Core Isolation Pump Room (1A104)

Dry fuel storage pad area (Area 59 the Yard)

The inspectors reviewed areas to assess if licensee personnel had implemented a fire

protection program that adequately controlled combustibles and ignition sources within

the plant; effectively maintained fire detection and suppression capability; maintained

passive fire protection features in good material condition; and had implemented

adequate compensatory measures for out of service, degraded or inoperable fire

protection equipment, systems, or features, in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk

as documented in the plants Individual Plant Examination of External Events with later

additional insights, their potential to affect equipment that could initiate or mitigate a

plant transient, or their impact on the plants ability to respond to a security event. Using

the documents listed in the attachment, the inspectors verified that fire hoses and

extinguishers were in their designated locations and available for immediate use; that

fire detectors and sprinklers were unobstructed; that transient material loading was

within the analyzed limits; and fire doors, dampers, and penetration seals appeared to

be in satisfactory condition. The inspectors also verified that minor issues identified

during the inspection were entered into the licensees corrective action program.

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

These activities constitute completion of five quarterly fire-protection inspection samples

as defined in Inspection Procedure 71111.05-05.

b. Findings

Introduction. The inspectors identified a Green noncited violation of Facility Operating

License Condition 2.C(41), involving the failure to ensure that transient combustible were

not stored in the fire exclusion zone near the independent spent fuel storage installation.

Description. On January 24, 2011, the inspectors performed a quarterly fire protection

inspection of independent spent fuel storage installation. The inspectors identified a

large air conditioner with combustible material covering it located in the fire exclusion

zone that appeared to be within 60 feet of the dry fuel storage pad. The inspectors

brought this to the attention of the work center senior reactor operator. The work center

senior reactor operator contacted the site fire engineer, who walked down the fire

exclusion zone and determined that the combustible material covering the air conditioner

was within the 60 feet of the dry fuel storage pad, which is in violation of plant procedural

requirements. The inspectors determined through interviews that the material had been

placed there the day before by the maintenance department. The site had the air

conditioner and the covering material removed from the fire exclusion zone to restore

compliance.

The licensee documented this violation in Condition Report CR-GGN-2011-00455. Its

short-term corrective actions included removing the combustible material from the area.

-9- Enclosure

Analysis. The inspectors determined that the failure to follow fire protection procedures

developed for control of transient combustible material stored near the dry spent fuel

storage pad was a performance deficiency. This finding was more than minor because it

was associated human performance attribute of the Barrier Integrity Cornerstone to

provide reasonable assurance that physical design barriers protect the public from

radionuclide releases caused by accidents or events. Using Manual Chapter 0609,

Appendix F, Fire Protection Significance Determination Process, the inspectors

determined that the finding impacted the fire prevention and administrative controls

category. The inspectors assigned a low degradation rating due to the fact that the

amount of combustible material in the area was minimal. The inspectors concluded that

the finding was of very low safety significance (Green) due to the fact there were no fire

ignition sources in the area. The finding has a crosscutting aspect in the area of human

performance associated with the work practices component because the licensee failed

to effectively communicate expectations regarding storage of combustible material near

the dry fuel storage pad. H.4(b)

Enforcement. Grand Gulf Nuclear Station Facility Operating License Condition 2.C(41)

states, in part, that the plant shall implement and maintain in effect all provisions of the

Fire Protection Program as described in the UFSAR. UFSAR Section 9B,

Administrative Controls, section 9B.6.a, governs the handling and limits the use of

ordinary combustible materials in safety related areas. Fire area 59, defined as the yard,

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

of any combustible material in this area. Contrary to this, on January 23, 2011, the

licensee stored combustible material inside the transient combustible exclusion zone

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

material from the area on January 25, 2011. Because the finding was of very low safety

significance (Green) and was documented in the licensees corrective action program as

CR-GGN-2011-0455, this finding is being treated as a noncited violation (NCV)

consistent with Section VI.A of the NRC Enforcement Policy:

NCV 05000416/2011002-01; Transient Combustible Stored in the Fire Exclusion Zone

Near the Independent Spent Fuel Storage Installation.

1R06 Flood Protection Measures (71111.06)

a. Inspection Scope

The inspectors reviewed the flooding analysis, and plant procedures to assess seasonal

susceptibilities involving internal flooding; reviewed the Updated Final Safety Analysis

Report and corrective action program to determine if licensee personnel identified and

corrected flooding problems; inspected underground bunkers/manholes to verify the

adequacy of sump pumps, level alarm circuits, cable splices subject to submergence,

and drainage for bunkers/manholes; subject to flooding that contain cables whose failure

could disable risk-significant equipment. The inspectors walked down the areas listed

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

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

- 10 - Enclosure

These activities constitute completion of one bunker/manhole sample as defined in

Inspection Procedure 71111.06-05.

b. Findings

No findings were identified.

1R07 Heat Sink Performance (71111.07)

a. Inspection Scope

The inspectors reviewed licensee programs, verified performance against industry

standards, and reviewed critical operating parameters and maintenance records for the

Division 1 emergency diesel generator jacket water and lube oil heat exchangers. The

inspectors verified that performance tests were satisfactorily conducted for heat

exchangers/heat sinks and reviewed for problems or errors; the licensee utilized the

periodic maintenance method outlined in EPRI Report NP 7552, Heat Exchanger

Performance Monitoring Guidelines; the licensee properly utilized biofouling controls;

the licensees heat exchanger inspections adequately assessed the state of cleanliness

of their tubes; and the heat exchanger was correctly categorized under 10 CFR 50.65,

Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power

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

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

Inspection Procedure 71111.07-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program (71111.11)

a. Inspection Scope

On January 31, 2011, the inspectors observed a crew of licensed operators in the plants

simulator to verify that operator performance was adequate, evaluators were identifying

and documenting crew performance problems and training was being conducted in

accordance with licensee procedures. The inspectors evaluated the following areas:

Licensed operator performance

Crews clarity and formality of communications

Crews ability to take timely actions in the conservative direction

Crews prioritization, interpretation, and verification of annunciator alarms

Crews correct use and implementation of abnormal and emergency procedures

- 11 - Enclosure

Control board manipulations

Oversight and direction from supervisors

Crews ability to identify and implement appropriate technical specification

actions and emergency plan actions and notifications

The inspectors compared the crews performance in these areas to preestablished

operator action expectations and successful critical task completion requirements.

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

These activities constitute completion of one quarterly licensed-operator requalification

program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk

significant systems:

Appendix R emergency lighting units (Z92)

Control room air conditioning (Z51)

Residual heat removal (E12)

The inspectors reviewed events such as where ineffective equipment maintenance has

resulted in valid or invalid automatic actuations of engineered safeguards systems and

independently verified the licensee's actions to address system performance or condition

problems in terms of the following:

Implementing appropriate work practices

Identifying and addressing common cause failures

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

Characterizing system reliability issues for performance

Charging unavailability for performance

Trending key parameters for condition monitoring

- 12 - Enclosure

Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)

Verifying appropriate performance criteria for structures, systems, and

components classified as having an adequate demonstration of performance

through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as

requiring the establishment of appropriate and adequate goals and corrective

actions for systems classified as not having adequate performance, as described

in 10 CFR 50.65(a)(1)

The inspectors assessed performance issues with respect to the reliability, availability,

and condition monitoring of the system. In addition, the inspectors verified maintenance

effectiveness issues were entered into the corrective action program with the appropriate

significance characterization. Specific documents reviewed during this inspection are

listed in the attachment.

These activities constitute completion of three quarterly maintenance effectiveness

samples as defined in Inspection Procedure 71111.12-05.

b. Findings

.1 Failure to Update Available Low Pressure Cooling Injection Loops in the Updated Final

Safety Analysis Report

Introduction. Inspectors identified a Severity Level IV, noncited violation for the

licensees failure to update the final (updated) safety analysis report in accordance with

10 CFR 50.71(e)(4). Specifically, the licensee failed to update Section 6.3, Emergency

Core Cooling Systems, to appropriately reflect the available emergency core cooling

equipment during shutdown cooling operations in Mode 3.

Description. On February 28, 2011, while reviewing the updated final safety analysis

report for a maintenance effectiveness inspection of the residual heat removal system,

the inspectors determined that Section 6.3.1.1.1.e, Emergency Core Cooling Systems,

states, The ECCS is designed to satisfy all criteria specified in Section 6.3 for any

normal mode of reactor operation. Additionally, Section 6.3.1.1.2.d states, In the event

of a break in a pipe that is part of the reactor coolant pressure boundary, no single active

component failure in the emergency core cooling system shall prevent automatic

initiation and successful operation of less than the following combination of emergency

core cooling system equipment: 1) Three low pressure coolant injection loops, the low

pressure core spray and the automatic depressurization system (i.e., high pressure core

spray failure); 2) Two low pressure coolant injection loops, the high pressure core spray

and the automatic depressurization system (i.e., low pressure core spray diesel

generator failure); and 3) One low pressure coolant injection loop, the low pressure core

spray, the high pressure core spray and automatic depressurization system (i.e., low

pressure coolant injection diesel generator failure).

Procedure 03-1-01-3, Plant Shutdown, Revision 118, Section 6.14 states, When

shutdown cooling is placed in service at less than 135 psig, then the associated

containment spray and low pressure coolant injection systems may be considered

- 13 - Enclosure

operable if capable of being manually realigned and not otherwise inoperable.

Inspectors noted that because the residual heat removal system that provides shutdown

cooling in Mode 3 is not available for automatic initiation (must be manually realigned) of

low pressure coolant injection, in the event of a reactor coolant system pipe break, that

the aforementioned statements in Section 6.3 did not appropriately reflect the available

emergency core cooling equipment during shutdown cooling operations. In other words,

the combinations of emergency core cooling equipment available for automatic initiation

would include one less low pressure coolant injection loop.

The licensee entered this issue into their corrective actions program as Condition Report

CR-GGN-2011-01631. The licensee planned to take actions to update the updated final

safety analysis report at the next scheduled revision.

Analysis. The failure of licensing personnel to update the final safety analysis report to

reflect the available low pressure coolant injection loops for automatic initiation during

shutdown cooling operations in Mode 3 was a performance deficiency. This finding was

evaluated using traditional enforcement because it had the potential for impacting the

NRCs ability to perform its regulatory function. The inspectors used the NRC

Enforcement Policy, dated September 30, 2010, to evaluate the significance of this

violation. Consistent with the NRC Enforcement Policy, this finding was determined to

be a Severity Level IV noncited violation. This finding had no crosscutting aspect as it

was associated with a traditional enforcement violation.

Enforcement. Title 10 CFR 50.71(e)(4) requires the final safety analysis report be

updated, at intervals not exceeding 24 months, and states in part, the revisions must

reflect all changes made in the facility or procedures described in the FSAR. Contrary

to the above, licensing personnel failed to update the original revision of the final safety

analysis report to reflect the actual number of low pressure coolant injection loops

available for automatic initiation during shutdown cooling operations in Mode 3.

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

corrective action program as Condition Report CR-GGN-2011-01631, this violation is

being treated as a noncited violation consistent with the NRC Enforcement Policy:

NCV 0500416/20011002-02, "Failure to Update Available Low Pressure Coolant

Injection Loops in the Updated Final Safety Analysis Report."

.2 Failure to Demonstrate Maintenance Effectiveness of Train B Control Room Air

Conditioner

Introduction. The inspectors identified a Green noncited violation of 10 CFR Part

50.65(a)(2) for the failure to demonstrate that the performance of the train B control

room air conditioner was being effectively controlled through the performance of

appropriate preventive maintenance.

Description. On March 2, 2011, the inspectors performed a maintenance effectiveness

inspection of the control room air conditioning system. Inspectors determined that on

February 3, 2010, the train B control room air conditioner compressor was replaced with

a remanufactured compressor as part of annual preventative maintenance of the

system. On March 27, 2010, the control room air conditioner compressor tripped on low

- 14 - Enclosure

usable oil pressure. The licensees investigation revealed that the compressor pencil

strainer was approximately fifty percent covered with unidentified contaminants. Similar

contaminants were identified on the oil sump strainer. The licensee concluded that the

compressor had been installed with contaminants inside the lower half of the

compressor, and subsequently replaced the remanufactured compressor on April 1,

2010, with a newly rebuilt compressor. System engineering did not classify this event as

a maintenance rule functional failure even though operations had declared the train

inoperable and also stated in their operability determination that it could not meet its 30

day mission time.

The train B control room air conditioner compressor subsequently either tripped or failed

to properly cool the control room, due to low usable oil pressure, on three separate

occasions (once in April, once May, and once in June). In response to the June failure,

the licensee performed extensive maintenance on the train B control room air

conditioner compressor, which included installing a five micron suction line filter in the

system. Additionally, all three events were identified as maintenance rule functional

failures attributed to foreign material fouling in the system, which would have resulted in

the performance criteria being exceeded (less than or equal to two maintenance rule

functional failure events or as a repeat functional failure). However, the sites

maintenance rule coordinator informed the inspectors that the first two events in April

and May were not counted toward the criteria because they were from the same cause

as the June event and; therefore, they would all be counted as one failure even thought

the train was returned to service each time after corrective maintenance was performed

and declared operable by operations. Additionally, on June 22, 2010, the train was

declared inoperable due to multiple Freon leaks and was classified as another

maintenance rule functional failure for the train. On August 10, 2010, the licensee

performed a Maintenance Rule (a)(1) evaluation for the subject system and, based on

the presentation to the expert panel by system engineering, the panel only considered

two events as maintenance rule functional failures. System engineering did not count

the one failure in March or consider the two failures in April or May. The expert panel

only considered the failures in June due to low oil pressure and Freon leaks. Therefore

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

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

of effective corrective actions had been identified and implemented and additional

corrective actions were not necessary; therefore, the subject system was allowed to

retain its (a)(2) status.

The train B control room air conditioner compressor subsequently either tripped or failed

to properly cool the control room, due to low usable oil pressure, on two separate

occasions (once in September and once in October). The October trip of the subject

system compressor occurred while the train A control room air conditioner was out of

service for routine maintenance. The compressor pencil strainer and sump strainer were

again identified with contaminants on them. The licensee was required to make an

eight-hour report to the NRC and submit a licensee event report due to both trains of

control room air conditioner being inoperable. The licensees root cause analysis failed

to identify that the train B control room air conditioner performance had not been

demonstrated through the performance of appropriate preventative maintenance; nor did

the root cause identify that the licensee failed to set goals and monitor the system as

- 15 - Enclosure

required by 10 CFR 50.65(a)(1). The train B control room air conditioner was ultimately

moved into (a)(1) status on February 4, 2011, after the subject compressor again tripped

due to low oil pressure on December 13, 2010. After this trip and upon further

evaluation, the licensee performed an additional corrective action that installed an in line

suction filter with smaller filtering diameter and larger surface area to remove foreign

material from the system. They also modified the operator rounds to obtain daily

readings of differential pressure across this new filter and through calculation,

determined a differential pressure necessary for the filter to be changed out and the unit

to be inspected for foreign materials.

The licensee entered this issue into their corrective actions program as Condition Report

CR-GGN-2011-01623. From installation of the new inline suction filter to the conclusion

of the inspection period, no additional trips of train B control room air conditioning have

occurred.

Analysis. The inspectors determined that the failure to demonstrate that the

performance of the train B control room air conditioner was being effectively controlled

through the performance of appropriate preventive maintenance was a performance

deficiency. The finding was more than minor because it was associated with the

equipment performance attribute of the Mitigating Systems Cornerstone and adversely

affected the cornerstone objective to ensure the availability, reliability, and capability of

systems that respond to initiating events to prevent undesirable consequences.

Inspectors performed a Phase 1 screening, in accordance with Inspection Manual

Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of

Findings, and determined that the finding was of very low safety significance (Green)

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

air conditioner remained operable. This finding had a crosscutting aspect in the area of

human performance associated with the decision making component because licensee

personnel failed to make appropriate safety-significant or risk-significant decisions to

address the multiple failures of the train B CRAC compressor. H.1(a)

Enforcement. Title 10 CFR 50.65(a)(2), states, in part, that monitoring as specified in

paragraph (a)(1) of this section is not required where it has been demonstrated that the

performance or condition of a structure, system, or component is being effectively

controlled through the performance of appropriate preventative maintenance, such that

the structure, system, or component remains capable of performing its intended

function. Contrary to the above, from March 2010 to February 2011, the licensee failed

to demonstrate that the performance of the train B control room air conditioning system

was effectively controlled through the performance of appropriate preventative

maintenance. This finding was entered into the licensees corrective action program as

Condition Report CR-GGN-2011-01623. Because this finding was determined to be of

very low safety significance and was entered into the licensees corrective action

program, this violation is being treated as a noncited violation consistent with the NRC

Enforcement Policy: NCV 05000285/2011002-03, Failure to Demonstrate Maintenance

Effectiveness of Train B Control Room Air Conditioner.

- 16 - Enclosure

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

a. Inspection Scope

The inspectors reviewed licensee personnel's evaluation and management of plant risk

for the maintenance and emergent work activities affecting risk-significant and safety-

related equipment listed below to verify that the appropriate risk assessments were

performed prior to removing equipment for work:

On January 9, 2011, during an ice storm requiring the plant to enter a yellow risk

condition and enter their off normal event procedure for severe weather.

On February 3, 2011, during an ice storm requiring the plant to enter a yellow risk

condition and enter their off normal event procedure for severe weather. The

weather required the site to cancel work and monitor their safety related standby

service water system for icing conditions.

On February 9, 2011, during a winter storm, while a divisions 1 diesel generator

and residual heat removal A were out for planned maintenance outage requiring

the plant to enter orange risk.

On February 28, 2011, during the accidental unearthing of energized plant

service water pump cables, no consequence to the plant but resulted in work

stoppage and evaluation of risk status for the site.

On March 8-9, 2011, with an emergent issue with the division 1 diesel generator

and a tornado watch issued for the area requiring the plant to enter yellow risk.

The site entered their severe weather off normal procedure; this procedure

required the site to secure from half scram surveillances.

The inspectors selected these activities based on potential risk significance relative to

the reactor safety cornerstones. As applicable for each activity, the inspectors verified

that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)

and that the assessments were accurate and complete. When licensee personnel

performed emergent work, the inspectors verified that the licensee personnel promptly

assessed and managed plant risk. The inspectors reviewed the scope of maintenance

work, discussed the results of the assessment with the licensee's probabilistic risk

analyst or shift technical advisor, and verified plant conditions were consistent with the

risk assessment. The inspectors also reviewed the technical specification requirements

and inspected portions of redundant safety systems, when applicable, to verify risk

analysis assumptions were valid and applicable requirements were met. Specific

documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five emergent work control inspection samples

as defined in Inspection Procedure 71111.13-05.

- 17 - Enclosure

b. Findings

No findings were identified.

1R15 Operability Evaluations (71111.15)

a. Inspection Scope

The inspectors reviewed the following issues:

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

switch fluctuating

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

missing brass bolts

Train A standby service water valve P41-F299A flange degradation

Residual heat removal equipment area temperature high/inoperable due to

temperature switch

Site fire truck inoperable

Division 1 diesel generator auxiliary oil pump not obtaining procedural pressures

during pre-lube prior to surveillance run

The inspectors selected these potential operability issues based on the risk significance

of the associated components and systems. The inspectors evaluated the technical

adequacy of the evaluations to ensure that technical specification operability was

properly justified and the subject component or system remained available such that no

unrecognized increase in risk occurred. The inspectors compared the operability and

design criteria in the appropriate sections of the technical specifications and UFSAR to

the licensee personnels evaluations to determine whether the components or systems

were operable. Where compensatory measures were required to maintain operability,

the inspectors determined whether the measures in place would function as intended

and were properly controlled. The inspectors determined, where appropriate,

compliance with bounding limitations associated with the evaluations. Additionally, the

inspectors also reviewed a sampling of corrective action documents to verify that the

licensee was identifying and correcting any deficiencies associated with operability

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

attachment.

These activities constitute completion of six operability evaluations inspection samples

as defined in Inspection Procedure 71111.15-04

- 18 - Enclosure

b. Findings

No findings were identified.

1R18 Plant Modifications (71111.18)

a. Inspection Scope

To verify that the safety functions of important safety systems were not degraded, the

inspectors reviewed the following temporary modifications:

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

Temporary Modification to install bypass signals for B first stage Pressure

Sensor (EC22768)

The inspectors reviewed the temporary modifications and the associated safety-

evaluation screening against the system design bases documentation, including the

updated final safety analysis report and the technical specifications, and verified that the

modification did not adversely affect the system operability/availability. The inspectors

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

documents and that configuration control was adequate. Additionally, the inspectors

verified that the temporary modification was identified on control room drawings,

appropriate tags were placed on the affected equipment, and licensee personnel

evaluated the combined effects on mitigating systems and the integrity of radiological

barriers.

These activities constitute completion of two samples for temporary plant modifications

as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings were identified.

1R19 Postmaintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed the following postmaintenance activities to verify that

procedures and test activities were adequate to ensure system operability and functional

capability:

For standby liquid B after a maintenance outage

For reactor protection motor generator B after required maintenance

For residual heat removal system A after a maintenance outage

- 19 - Enclosure

For standby service water system A after a maintenance outage

For division 1 diesel generator after a maintenance outage

For high pressure core spray minimum flow valve 1E22-F012 after corrective

maintenance

The inspectors selected these activities based upon the structure, system, or

component's ability to affect risk. The inspectors evaluated these activities for the

following (as applicable):

The effect of testing on the plant had been adequately addressed; testing was

adequate for the maintenance performed

Acceptance criteria were clear and demonstrated operational readiness; test

instrumentation was appropriate

The inspectors evaluated the activities against the technical specifications, the UFSAR,

10 CFR Part 50 requirements, licensee procedures, and various NRC generic

communications to ensure that the test results adequately ensured that the equipment

met the licensing basis and design requirements. In addition, the inspectors reviewed

corrective action documents associated with postmaintenance tests to determine

whether the licensee was identifying problems and entering them in the corrective action

program and that the problems were being corrected commensurate with their

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

the attachment.

These activities constitute completion of six postmaintenance testing inspection samples

as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors reviewed the UFSAR, procedure requirements, and technical

specifications to ensure that the surveillance activities listed below demonstrated that the

systems, structures, and/or components tested were capable of performing their

intended safety functions. The inspectors either witnessed or reviewed test data to

verify that the significant surveillance test attributes were adequate to address the

following:

Preconditioning

- 20 - Enclosure

Evaluation of testing impact on the plant

Acceptance criteria

Test equipment

Procedures

Test data

Testing frequency and method demonstrated technical specification operability

Test equipment removal

Restoration of plant systems

Updating of performance indicator data

Engineering evaluations, root causes, and bases for returning tested systems,

structures, and components not meeting the test acceptance criteria were correct

Reference setting data

Annunciators and alarms setpoints

The inspectors also verified that licensee personnel identified and implemented any

needed corrective actions associated with the surveillance testing.

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

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

On February 23, 2011, reactor coolant routine chemistry surveillance

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

response test

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

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

On March 20-21, 2011, functional checks with reactor core isolation cooling

valves at the remote shutdown panel

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

- 21 - Enclosure

These activities constitute completion of seven surveillance (one reactor coolant system

leakage detection, one inservice test, and five routine tests) testing inspection samples

as defined in Inspection Procedure 71111.22-05.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06)

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on March 3,

2011, to identify any weaknesses and deficiencies in classification, notification, and

protective action recommendation development activities. The inspectors observed

emergency response operations in the simulator control room and emergency

operations facility to determine whether the event classification, notifications, and

protective action recommendations were performed in accordance with procedures. The

inspectors also attended the licensee drill critique to compare any inspector-observed

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

to verify whether the licensee staff was properly identifying weaknesses and entering

them into the corrective action program. As part of the inspection, the inspectors

reviewed the drill package and other documents listed in the attachment.

These activities constitute completion of one sample as defined in Inspection

Procedure 71114.06-05.

b. Findings

No findings were identified.

2. RADIATION SAFETY

Cornerstone: Occupational and Public Radiation Safety

2RS01 Radiological Hazard Assessment and Exposure Controls (71124.01)

a. Inspection Scope

This area was inspected to: (1) review and assess licensees performance in assessing

the radiological hazards in the workplace associated with licensed activities and the

implementation of appropriate radiation monitoring and exposure control measures for

both individual and collective exposures, (2) verify the licensee is properly identifying

and reporting Occupational Radiation Safety Cornerstone performance indicators, and

- 22 - Enclosure

(3) identify those performance deficiencies that were reportable as a performance

indicator and which may have represented a substantial potential for overexposure of

the worker.

The inspectors used the requirements in 10 CFR Part 20, the technical specifications,

and the licensees procedures required by technical specifications as criteria for

determining compliance. During the inspection, the inspectors interviewed the radiation

protection manager, radiation protection supervisors, and radiation workers. The

inspectors performed walkdowns of various portions of the plant, performed independent

radiation dose rate measurements and reviewed the following items:

Performance indicator events and associated documentation reported by the

licensee in the Occupational Radiation Safety Cornerstone

The hazard assessment program, including a review of the licenses evaluations

of changes in plant operations and radiological surveys to detect dose rates,

airborne radioactivity, and surface contamination levels

Instructions and notices to workers, including labeling or marking containers of

radioactive material, radiation work permits, actions for electronic dosimeter

alarms, and changes to radiological conditions

Programs and processes for control of sealed sources and release of potentially

contaminated material from the radiologically controlled area, including survey

performance, instrument sensitivity, release criteria, procedural guidance, and

sealed source accountability

Radiological hazards control and work coverage, including the adequacy of

surveys, radiation protection job coverage, and contamination controls; the use of

electronic dosimeters in high noise areas; dosimetry placement; airborne

radioactivity monitoring; controls for highly activated or contaminated materials

(non-fuel) stored within spent fuel and other storage pools; and posting and

physical controls for high radiation areas and very high radiation areas

Radiation worker and radiation protection technician performance with respect to

radiation protection work requirements

Audits, self-assessments, and corrective action documents related to radiological

hazard assessment and exposure controls since the last inspection

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

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

Inspection Procedure 71124.01-05.

b. Findings

- 23 - Enclosure

Introduction. The inspectors identified a Green, noncited violation of Technical Specification 5.7.2, resulting from the licensees failure to use a qualified radiation

protection technician to provide direct continuous coverage of work in a locked high

radiation area.

Description. The inspectors reviewed Condition Report CR-GGN-2011-00655, which

documented the identification by Cooper Nuclear Station that a contractor seeking

employment as a radiation protection technician did not meet ANSI 18.1 requirements.

The finding, documented February 2, 2011, was discussed with Entergy sites during a

teleconference. Then, Grand Gulf Nuclear Station determined the individual had been

employed as a radiation protection technician at Grand Gulf Nuclear Station during

Refueling Outage 17, conducted in April and May 2010. In response, Grand Gulf

Nuclear Station reviewed the radiation surveys performed by the individual (from April 15

through May 13, 2010), concluded the surveys contained data comparable with that

documented in other surveys in the same areas under similar conditions, and closed the

condition report on February 8, 2011. The inspectors reviewed the radiation survey

records included in the condition report and noted something the licensee had not

addressed. On April 27, 2010, the individual had provided job coverage for work in a

locked high radiation area (an area with dose rates greater than 1000 mrem/hour).

Survey GG-1004-0660 identified the work area as the 128-foot auxiliary pipe chase,

above the reactor water cleanup pump rooms. Since the individual used by the licensee

to provide job coverage and surveillance in a locked high radiation area was not a

qualified radiation protection technician, the inspectors identified this as a performance

deficiency.

Analysis. The failure to use a qualified radiation protection technician to provide direct

continuous coverage of work in a locked high radiation area is a performance deficiency.

The finding was more than minor because it was associated with the Occupational

Radiation Safety Cornerstone attribute (exposure control) of program and process and

affected the cornerstone objective, in that, the failure to use qualified radiation protection

technicians to provide job coverage in a high radiation area with dose rates in excess of

1000 mrem/hr had the potential to increase personnel dose. Using the Occupational

Radiation Safety Significance Determination Process, the inspectors determined the

finding to have very low safety significance because: (1) it was not associated with

ALARA planning or work controls, (2) there was no overexposure, (3) there was no

substantial potential for an overexposure, and (4) the ability to assess dose was not

compromised. The inspectors identified no cross-cutting aspect associated with this

finding.

Enforcement. Technical Specification 5.7.2, controls for high radiation areas with dose

rates greater than 1000 mrem/hour, consists of all the controls for high radiation areas

(Technical Specification 5.7.1) plus it requires doors to the area remain locked except

during periods of access by personnel under an approved radiation work permit that

shall specify the dose rate levels in the immediate work areas and the maximum

allowable stay times for individuals in those areas. In lieu of the stay time specification

for the radiation work permit, direct or remote continuous surveillance may be made by

personnel qualified in radiation protection procedures to provide positive exposure

- 24 - Enclosure

control over the activities being performed within the area. Contrary to the above, during

work in an area with dose rates greater than 1000 mrem/hour on April 27, 2010, in lieu of

the stay time specification for the radiation work permit, direct or remote surveillance

was not made by personnel qualified in radiation protection procedures to provide

positive exposure control over the activities being performed within the area. Instead, an

unqualified person was assigned to provide surveillance of a locked high radiation on

April 27, 2010. The licensee initiated Condition Report CR-GGN-2011-01045 to

document the fact that it failed to identify this performance deficiency as part of the

review associated with the closure of Condition Report CR-GGN-2011-00655.

Because the violation was of very low safety significance and it was entered into the

licensees corrective action program, the violation is being treated as a noncited

violation, consistent with the enforcement policy. NCV 05000416/2011002-04, Failure

to Use a Qualified Radiation Protection Technician to Provide Direct Continuous

Coverage of Work in a Locked High Radiation Area.

2RS02 Occupational ALARA Planning and Controls (71124.02)

a. Inspection Scope

This area was inspected to assess performance with respect to maintaining occupational

individual and collective radiation exposures as low as is reasonably achievable

(ALARA). The inspectors used the requirements in 10 CFR Part 20, the technical

specifications, and the licensees procedures required by technical specifications as

criteria for determining compliance. During the inspection, the inspectors interviewed

licensee personnel and reviewed the following items:

Site-specific ALARA procedures and collective exposure history, including the

current 3-year rolling average, site-specific trends in collective exposures, and

source-term measurements

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

exposure mitigation requirements

The methodology for estimating work activity exposures, the intended dose

outcome, the accuracy of dose rate and man-hour estimates, and intended

versus actual work activity doses and the reasons for any inconsistencies

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

terms and contingency plans for expected changes in the source term due to

changes in plant fuel performance issues or changes in plant primary chemistry

Radiation worker and radiation protection technician performance during work

activities in radiation areas, airborne radioactivity areas, or high radiation areas

Audits, self-assessments, and corrective action documents related to ALARA

planning and controls since the last inspection

- 25 - Enclosure

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

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

Inspection Procedure 71124.02-05.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES

4OA1 Performance Indicator Verification (71151)

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the performance indicator data submitted by the

licensee for the fourth Quarter 2010 performance indicators for any obvious

inconsistencies prior to its public release in accordance with Inspection Manual

Chapter 0608, Performance Indicator Program.

This review was performed as part of the inspectors normal plant status activities and,

as such, did not constitute a separate inspection sample.

b. Findings

No findings were identified.

.2 Unplanned Scrams per 7000 Critical Hours (IE01)

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned scrams per 7000 critical

hours performance indicator for the period from the first quarter 2010 through the fourth

quarter 2010. To determine the accuracy of the performance indicator data reported

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

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6.

The inspectors reviewed the licensees operator narrative logs, condition reports, event

reports, and NRC integrated inspection reports for the period of January 2010 through

December 2010 to validate the accuracy of the submittals. The inspectors also reviewed

the licensees condition report database to determine if any problems had been identified

with the performance indicator data collected or transmitted for this indicator and none

were identified. Specific documents reviewed are described in the attachment to this

report.

These activities constitute completion of one unplanned scrams per 7000 critical hours

sample as defined in Inspection Procedure 71151-05.

- 26 - Enclosure

b. Findings

No findings were identified.

.3 Unplanned Scrams with Complications (IE02)

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned scrams with

complications performance indicator for the period from first quarter 2010 through the

fourth quarter 2010. To determine the accuracy of the performance indicator data

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

NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,

Revision 6. The inspectors reviewed the licensees operator narrative logs, condition

reports, event reports, and NRC integrated inspection reports for the period of January

2010 through December 2010 to validate the accuracy of the submittals. The inspectors

also reviewed the licensees condition report database to determine if any problems had

been identified with the performance indicator data collected or transmitted for this

indicator and none were identified. Specific documents reviewed are described in the

attachment to this report.

These activities constitute completion of one unplanned scrams with complications

sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

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

a. Inspection Scope

The inspectors sampled licensee submittals for the unplanned power changes per 7000

critical hours performance indicator for the period from first quarter 2010 through the