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05000416/FIN-2018003-0230 September 2018 23:59:59Grand GulfNRC identifiedMinor ViolationMinor Violation: The licensee did not include any unplanned power changes as inputs for the Unplanned Power Changes per 7,000 Critical Hours performance indicator (PI) that was reported to the NRC for the second quarter 2016. Based on a plant event that took place on June 17, 2016, the inspectors noted that the PI data submitted by the licensee may not have been accurate. In response, the licensee submitted frequently asked question (FAQ) 17-01 to the reactor oversight process working group. This FAQ resulted in the determination that three unplanned power changes should have been reported associated with the event in question. Following resolution of the FAQ, the licensee reported the associated PI data. As required by 10 CFR 50.9, Completeness and accuracy of information, information provided to the NRC by a licensee shall be complete and accurate in all material respects. Contrary to the above, from July 2016 through May 2017, information provided to the NRC by the licensee was not complete and accurate in all material respects. Specifically, the data for the Unplanned Power Changes per 7,000 Critical Hours PI did not include any unplanned power changes for the second quarter 2016. Screening: The inspectors determined that this violation was of minor significance in accordance with the NRC Enforcement Policy, Section 6.9.d.11, since the PI data in question did not ultimately result in the PI changing from Green to White. Enforcement: The licensee entered this issue into their corrective action program as Condition Report CR-GGN-2016-06028. The licensee took action to restore compliance by submitting an appropriate correction to the PI data. This failure to comply with 10 CFR 50.9 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The disposition of this violation closes URI 05000416/2017001-02, Grand Gulf Unplanned Power Changes per 7000 Critical Hours Performance Indicator.
05000416/FIN-2018003-0130 September 2018 23:59:59Grand GulfSelf-revealingFailure to Develop Adequate Work InstructionsA self-revealed, Green finding was identified when feedwater heater drain tank oscillations caused a feedwater perturbation which required a manual reactor scram. Specifically, the licensee failed to develop appropriate work instructions for filling and venting the feedwater heater 6A level transmitters.
05000416/FIN-2018201-0130 September 2018 23:59:59Grand GulfNRC identifiedSecurity
05000416/FIN-2018002-0330 June 2018 23:59:59Grand GulfSelf-revealingFailure to Adequately Test NUS Temperature SwitchA self-revealed,Green non-cited violationof 10CFRPart50, AppendixB, CriterionIII, Design Control, was identified when the reactor core isolation cooling (RCIC) system automatically isolated due to an inadvertent high temperature input from the leakage detection system. Specifically, the licensee failed to fully test a modification that installed a new type of temperature switches, and the system inappropriately isolated the RCIC system when a loss and subsequent restoration of power occurred.
05000416/FIN-2018002-0430 June 2018 23:59:59Grand GulfSelf-revealingHigh Radiation Area Boundary ViolationA self-revealed, Green non-cited violation of Technical Specification 5.7.1 was identified when an individual received a dose rate alarm when the individual failed to comply with established radiological barriers and protective measures and entered a high radiation area. Specifically, an individual leaned over a high radiation area barricade rope, thereby entering the high radiation area. The individuals radiation work permit (RWP) did not permit entry into a high radiation area.
05000416/FIN-2018002-0630 June 2018 23:59:59Grand GulfSelf-revealingImproper Evaluation and Resolution of Intermediate Range MonitorNoise Leads to Manual Reactor ShutdownA self-revealed, Green non-cited violation of 10CFRPart50, Appendix B, Criterion XVI, Corrective Action, was identified for the failure of the licensee to identify and correct a condition adverse to quality. Specifically, the licensee failed to implement appropriate corrective actions related to intermediate range monitor (IRM) nuclear instrument (NI) electronic noise spiking. The failure to implement adequate corrective actions over the course of at least 5 years resulted in a plant shutdown due to declaration of multiple IRM channels inoperable while in Mode 2.
05000416/FIN-2018002-0530 June 2018 23:59:59Grand GulfSelf-revealingFailure to Follow Procedure Requirements Resulting in Unplanned DoseA self-revealed, Green non-cited violation of Technical Specification 5.4.1 was identified when an individual alarmed a personnel contamination monitor upon exit from the radiologically controlled area. Specifically, the licensee failed to follow procedures to establish a decontamination plan or procedure, conduct a specific pre-job brief addressing appropriate contamination risk, and receive approval by radiation protection supervision prior to conducting decontamination activities on thereactor pressure vessel(RPV) O-rings
05000416/FIN-2018002-0130 June 2018 23:59:59Grand GulfNRC identifiedFailure to Institute Effective Corrective Action to Preclude RepetitionAn NRC-identified,Green non-cited violation of 10CFRPart50, AppendixB, CriterionXVI, Corrective Action, was identified when the licensee failed to institute effective corrective actions to preclude repetition of a significant condition adverse to quality. Specifically, the licensee left a secondary containment personnel hatch in an open configuration for approximately 30 minutes while performing a roof inspection, which rendered secondary containment inoperable. This issue had also previously occurred in 2016, but corrective actions to prevent it from occurring again were ineffective.
05000416/FIN-2018002-0730 June 2018 23:59:59Grand GulfSelf-revealingLoss of Shutdown CoolingA self-revealed,Green non-cited violation of Technical Specification 5.4, Procedures,for the licensees failure to follow written procedures was identified when the residual heat removal (RHR) system automatically isolated due to an inadvertent emergency core cooling system (ECCS) actuation. While the plant was shut down with the RHR system in decay heat removal mode, maintenance personnel inadvertently opened an incorrect valve during a transmitter calibration activity, which caused a false low reactor pressure vessel (RPV) water level signal, an ECCS actuation, and a loss of decay heat removal for approximately 31 minutes
05000416/FIN-2018002-0230 June 2018 23:59:59Grand GulfNRC identifiedFailure to Follow ASME Requirements for Maintaining Inservice Inspection (ISI) Cycles and Perform ASME Required Inservice Inspections within the Scheduled ISI CycleThe inspector identified 15 examples of a Green non-cited violation (NCV)of 10 CFR 50.55(a)(g)(4)(ii), which requires that inservice examination of components classified as American Society of Mechanical Engineers (ASME), Section XI, Code Class 1, Class 2, and Class 3 be conducted during successive 120-month inspection intervals, and requires compliance with the requirements of the latest edition and addenda of the ASME Code (and all its paragraphs) applicable to the specific interval, including maintaining the 120-month inspection interval in accordance with the ASME Code, Section XI, Paragraph IWA-2430. Specifically, the licensee inappropriately adjusted its second inservice inspection 120-month cycle, and failed to perform VT-3 and MT examinations of 15 class 1, class 2, and class 3 components, including the high pressure core spray pump attachment weld and reinforcing band before the third inservice inspection cycle expired on November 30, 2017, as required by 10CFR50.55(a)(g)(4)(ii).
05000416/FIN-2018002-0830 June 2018 23:59:59Grand GulfNRC identifiedPerformance of Surveillance Testing Following Maintenance on Containment AirlockThe inspectors identified a Green non-cited violation of 10CFRPart50,AppendixB, Criterion XI, Test Control, for the licensees failure to perform surveillance testing of containment airlock seals under appropriate conditions. The licensee failed to appropriately control the sequence of maintenance and testing activities to ensure that surveillance testing was not performed subsequent to maintenance which could affect the validity of surveillance test results.
05000416/FIN-2018001-0131 March 2018 23:59:59Grand GulfSelf-revealingFailure to Promptly Correct Lube Oil Leak on Division 2 Diesel GeneratorThe inspectors reviewed a self-revealed non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, associated with the licensees failure to promptly correct an identified condition adverse to quality. Specifically, the licensee failed to correct an identified oil leak on the division 2 diesel generator before the leak worsened to a condition that rendered the diesel generator inoperable.
05000416/FIN-2017011-0431 March 2018 23:59:59Grand GulfSelf-revealingFailure to Install the Residual Heat Removal Pump A Mechanical Seal in Accordance with ProceduresThe inspectors reviewed a self-revealed, non-cited violation of Technical Specification 5.4, Procedures, for the licensees failure to perform maintenance on the residual heat removal pump A mechanical seal in accordance with written procedures. Specifically, on September 22, 2016, maintenance did not install seal assembly drive pins in accordance with Step 7.8.2 of Procedure 07-S-14-279, Revision 007. The licensee entered this issue into their corrective action program as Condition Reports CR-GGN-2017-08269 and CR-GGN-2017-11009. The licensee implemented immediate corrective actions by declaring the pump inoperable and replacing the mechanical seal. The failure to perform maintenance on the residual heat removal pump A mechanical seal in accordance with written procedures was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the human performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, on September 22, 2016, mechanical maintenance installed the residual heat removal pump A seal drive pins backwards. As a result, the drive pins damaged the seal and on August 23, 2017, caused an unisolable leak from the seal. This resulted in unplanned inoperability and unavailability of the residual heat removal pump A from August 23, 2017, through August 25, 2017, when the mechanical seal was replaced. Using Nuclear Regulatory Commission Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, and Nuclear Regulatory Commission Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that the finding was of very low safety significance (Green) because it was related to, but was not itself: (1) a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) a loss of system and/or function; (3) an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees Maintenance Rule program. This finding had a cross-cutting aspect in the area of human performance, avoid complacency, because the licensee failed to recognize and plan for the possibility of mistakes, and individuals failed to implement appropriate error reduction tools. Specifically, the licensee failed to use appropriate error reductions tools such as self-check or peer checking which resulted in incorrect performance of procedural steps (H.12)
05000416/FIN-2018001-0331 March 2018 23:59:59Grand GulfNRC identifiedInadequate Procedural Guidance Which Resulted in Control Room Air Conditioning InoperabilityThe inspectors reviewed a self-revealed non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to have adequate procedural guidance while performing a standby service water surveillance procedure. Specifically, the licensees procedural guidance was not adequate to prevent the control room air conditioning subsystem B compressor from starting while condenser cooling water was isolated, which caused damage and rendered the subsystem inoperable and unavailable.
05000416/FIN-2018001-0431 March 2018 23:59:59Grand GulfSelf-revealingInadequate Procedural Guidance which Resulted in Undemanded Control Valve Movements and Manual ScramThe inspectors reviewed a self-revealed non-cited violation of Technical Specification 5.4.1.a, Procedures, associated with the licensees failure to provide appropriate procedural guidance while performing calibration of a steam line compensator. Specifically, Work Order 4449267, Task 14 did not contain adequate instructions to calibrate a steam line compensator circuit card potentiometer, which led to undemanded control valve opening and closing and a subsequent manual reactor scram.
05000416/FIN-2017011-0631 March 2018 23:59:59Grand GulfNRC identifiedFailure to Perform Functionality Assessments as Required by ProceduresThe inspectors identified a finding for the licensees failure to follow Procedure EN-OP-104, Operability Determination Process, Revisions 10 through 12. Specifically, the licensee did not perform functionality assessments for adverse conditions on the offgas system as required by the procedure. The licensee entered this issue into their corrective action program as Condition Report CR-GGN-2017-11265. The licensee initiated corrective actions to perform functionality assessments for the conditions identified and to evaluate any potential programmatic issues. The failure to perform functionality assessments required by Procedure EN-OP-104 was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, the failure to perform functionality assessments could affect the availability and reliability of the offgas system to maintain the doses associated with releases to the environment as low as reasonably achievable. Using Nuclear Regulatory Commission Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, the inspectors determined that the finding was of very low safety significance (Green) because it involved the Effluent Release Program, it did not impair the ability to assess dose, and did not exceed the 10 CFR Part 50, Appendix I, or 10 CFR 20.1301(d) limits. This finding had a cross-cutting aspect in the area of human performance, consistent process, because the licensee did not use a consistent, systematic approach to make decisions. Specifically, the licensees failure to consistently disposition adverse conditions associated with the offgas system resulted in the station not performing required functionality assessments (H.13)
05000416/FIN-2018001-0531 March 2018 23:59:59Grand GulfLicensee-identifiedLicensee-Identified Violation10 CFR 50.72(b)(3)(v)(D) requires the licensee to report an event or condition that could have prevented fulfillment of a safety function (accident mitigation).Contrary to the above, from February 18, 2018, until February 23, 2018, Grand Gulf Nuclear Station failed to make a timely event report for an event or condition that could have prevented fulfillment of a safety function (accident mitigation). Specifically, Grand Gulf Nuclear Station experienced the concurrent inoperability of the division 2 diesel generator and the high pressure core spray diesel generator. Per Technical Specification Bases 3.8.1.E.1, there are insufficient standby ac sources available in this condition to power the minimum required engineered safety feature functions.Significance/Severity Level: In accordance with NRC Enforcement Policy, Section 6.9.d.9, the failure to make a report required by 10 CFR 50.72 is a Severity Level IV violation.Corrective Action Reference(s): The licensee entered the failure to make a timely report into the corrective action program as CR-GGN-2018-1595.
05000416/FIN-2017011-0131 March 2018 23:59:59Grand GulfNRC identifiedFailure to Categorize Condition Reports for Significant Conditions Adverse to Quality as Required by ProceduresThe inspectors identified five examples of a finding for the licensees failure to categorize and evaluate conditions in accordance with procedural requirements. Specifically, the licensee did not categorize adverse conditions that represented the loss of a safety function as significant conditions adverse to quality as required by Procedure EN-LI-102, Corrective Action Program, Revisions 24 through 28. The licensee entered the conditions into their corrective action program as Condition Report CR-GGN-2017-10896. The licensee initiated corrective actions to re-categorize the conditions and perform the required evaluations. The failure to categorize conditions that represent the loss of a safety function as significant conditions adverse to quality as required by Procedure EN-LI-102 was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, root cause evaluations, corrective actions to prevent recurrence, and effectiveness reviews are used per licensee Procedure EN-LI-102 to ensure availability and reliability of structures, systems, and components are maintained. Using Nuclear Regulatory Commission Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that the finding was of very low safety significance (Green) because it was related to, but was not itself: (1) a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) a loss of system and/or function; (3) an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees Maintenance Rule program. This finding had a cross-cutting aspect in the area of human performance, consistent process, because the licensee did not use a consistent, systematic approach to make decisions. Specifically, the licensees failure to consistently evaluate the conditions during initial screening led to the incorrect categorization of the condition reports (H.13)
05000416/FIN-2017011-0231 March 2018 23:59:59Grand GulfNRC identifiedFailure to Disposition Adverse Conditions as Required by ProceduresThe inspectors identified a finding for the licensees failure to disposition conditions as required by Procedure EN-LI-102, Corrective Action Program, Revisions 24 through 30. Specifically, the licensee did not identify 72 conditions as either Adverse Category B, C, or D as required by the procedure. As a result, the licensee failed to perform the required cause evaluations and develop corrective actions to address the conditions. The licensee entered the conditions into their corrective action program as Condition Report CR-GGN-2017-10896. The licensee initiated corrective actions to re-categorize the conditions and perform the required evaluations. The failure to disposition conditions as adverse (B, C, or D) as required by Procedure EN-LI-102 was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, condition reports associated with deficiencies or potential deficiencies involving safety-related equipment are required to be categorized as adverse and appropriate corrective actions are assigned including causal analyses appropriate to the circumstances per licensee Procedure EN-LI-102. The inspectors performed an initial screening of the finding in accordance with Nuclear Regulatory Commission Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Nuclear Regulatory Commission Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that the finding was of very low safety significance (Green) because it was related to, but was not itself: (1) a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) a loss of system and/or function; (3) an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees Maintenance Rule program. This finding had a cross-cutting aspect in the area of human performance, consistent process, because the licensee did not use a consistent, systematic approach to make decisions. Specifically, the licensees failure to consistently disposition identified conditions as adverse led to the failure to fully evaluate the conditions (H.13).
05000416/FIN-2017011-0531 March 2018 23:59:59Grand GulfSelf-revealingFailure to Correct Control Room Boundary Door Resulted in Loss of Safety FunctionThe inspectors reviewed a self-revealed, non-cited violation of 10 CFR Part 50, Criterion XVI, Corrective Action, for the licensees failure to appropriately correct a condition adverse to quality. Specifically, the control room envelope door had been documented in several condition reports for not consistently working properly. Subsequent to these condition reports, on July 9, 2017, the door was opened and did not close automatically, and therefore the door was left in an unsecured position. The licensee entered this issue into their corrective action program as Condition Report CR-GGN-2017-06705. The licensee restored compliance by securing the door and replacing the hinge bushings to ensure the door would close properly. The failure to correct a condition adverse to quality for a control room envelope boundary door was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the structures, systems, and components and barrier performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (functionality of the control room) protect the public from radionuclide releases caused by accidents or events. Specifically, on July 9, 2017, since the licensee had not corrected the adverse conditions identified on the control room envelope door, the door was left in an unsecured position and resulted in the station declaring both trains of standby fresh air inoperable. Using Nuclear Regulatory Commission Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, and Nuclear Regulatory Commission Inspection Manual Chapter 0609, Appendix A, Exhibit 3, Barrier Integrity Screening Questions, the inspectors determined that the finding was of very low safety significance (Green) because the finding did not represent a degradation of the radiological barrier function provided for the control room, auxiliary building, spent fuel pool, or standby gas treatment system, and did not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere. The period of the barrier in the open position was of short duration, approximately 1 minute, and therefore did not result in significant risk input. This finding had a cross-cutting aspect in the area of problem identification and resolution, resolution, because the licensee did not take corrective actions in a timely manner commensurate with their safety significance. Specifically, the licensee did not ensure proper priority of corrective actions on the degraded control room envelope boundary door (P.3).
05000416/FIN-2017011-0331 March 2018 23:59:59Grand GulfNRC identifiedFailure to Conduct Common Cause Failure Evaluation in Response to Inoperable Emergency Diesel GeneratorThe inspectors identified three instances of a non-cited violation of Technical Specification 3.8.1, AC Sources Operating, for the licensees failure to take required actions for an inoperable emergency diesel generator. Specifically, after classifying the Division I or Division II emergency diesel generator as inoperable on the basis of nonconforming conditions, and after failing to either verify that the opposite train emergency diesel generator was not inoperable due to common cause failure within 24 hours or conduct a surveillance run on the opposite train emergency diesel generator within 24 hours, the licensee failed to enter Mode 3 within 12 hours as required by Technical Specification 3.8.1, Actions B.3.1, B.3.2, and G.1, respectively. The licensee entered this issue into their corrective action program as Condition Report CR-GGN-2017-11393. The licensee initiated corrective actions to conduct an adverse condition analysis. The failure to take required actions for an inoperable emergency diesel generator was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment reliability attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Actions B.3.1 and B.3.2 of Technical Specification 3.8.1 exist to ensure the availability, reliability, and capability of at least one emergency diesel generator in scenarios where there is a potential for a common cause failure of both emergency diesel generators, and the licensee took neither action. Using Nuclear Regulatory Commission Inspection Manual Chapter 0609, Appendix A, Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that the finding was of very low safety significance (Green) because the finding did not represent an actual loss of function of either the Division I or Division II emergency diesel generator for greater than its technical specifications allowed outage time. The finding had a cross-cutting aspect in the area of human performance, consistent process, because the licensee failed to use a consistent, systematic approach to make decisions. Specifically, the licensee failed to review the required actions of the applicable technical specification to ensure that all of those actions would be properly carried out (H.13).
05000416/FIN-2018001-0231 March 2018 23:59:59Grand GulfSelf-revealingFailure to Follow Procedure when Returning Containment Airlock to Operable StatusThe inspectors reviewed a self-revealed non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to follow written procedures for returning a technical specification component to service. Specifically, the licensee failed to follow Procedure 01-S-06-12, Surveillance Program Procedure, Revision 112, when performing a completion review on the 208 foot elevation inner door personnel airlock seal test, which is a Technical Specification required surveillance.
05000416/FIN-2017007-0531 December 2017 23:59:59Grand GulfNRC identifiedFailure to Update a Calculation and Procedure to Address Standby Service Water Passive FailureThe team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, which states, in part, Measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Specifically, since September 25, 2013, the licensee failed to include a design basis standby service water system (SSWS) piping crack in the appropriate design calculation and procedure. In response to this issue the licensee performed an operability determination to ensure that the ultimate heat sink basins would still have sufficient capacity to meet the 30 -day mission time. This finding was entered into the licensees corrective action program as Condition Report CR-GGN-2017-10192. The team determined that the failure to update a design calculation and a procedure to address a postulated standby service water passive failure was a performance deficiency. The finding was more than minor because it was associated with the Mitigating Systems Cornerstone attribute of equipment performance and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of non-technical specification equipment; and did not screen as potentially risk-significant due to seismic, flooding, or severe weather. The team determined that this finding did not have a cross-cutting aspect because the most significant contributor did not reflect current licensee performance.
05000416/FIN-2017007-0431 December 2017 23:59:59Grand GulfNRC identifiedFailure to Update the Final Safety Analys is ReportThe team identified three examples of a Severity Level IV, non-cited violation of 10 CFR 50.71, Maintenance of Records, Making of Reports, Section (e), which states, in part, Each person licensed to operate a nuclear power reactor shall update periodically the final safety analysis report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. This submittal shall contain all the changes necessary to reflect information and analyses submitted to the Commission by the applicant or licensee, or prepared by the applicant or licensee pursuant to Commission requirement since the submittal of the original or the last update to the final safety analysis report. Specific ally, prior to September 29, 2017, the licensee failed to ensure the final safety analysis report reflected the current plant configuration. In response to this issue, the licensee created a corrective action to update the final safety analysis report. The finding was entered into the licensees corrective action program as Condition Reports CR -GGN -2017- 09154, CR- HQN- 2017- 01356, and CR -GGN -2017 -09747. 5 The team determined that the failure to update the final safety analysis report in accordance with 10 CFR 50.71(e) was a performance deficiency. Following the Reactor Oversight Process (ROPs) significance determination process, the team determined this violation was associated with a minor performance deficiency. The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to also address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non- compliance. Assessing the performance deficiency in accordance with the NRC Enforcement Policy, the team determined it to be a Severity Level IV violation because the lack of up- to-date information in the final safety analysis report has not resulted in any unacceptable change to the facility or procedures. This finding did not have an assigned cross-cutting aspect because cross-cutting aspects are not assigned to traditional enforcement violations
05000416/FIN-2017007-0631 December 2017 23:59:59Grand GulfNRC identifiedFailure to Ensure Adequate Design Control Measures Are in Place Associated with Leakage Control SystemsThe team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, which states, in part, Measures shall be established to assure that applicable regulatory requirements and the design basis...for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. Specifically, prior to October 17, 2017, the licensee failed to provide adequate procedures or training to licensed operators to ensure the main steam isolation valve-leakage control system and feedwater leakage control system are manually started consistent with the licensees design basis assumptions. In response to this issue the licensee has provided specific guidance and training to the operators. This finding was entered into the licensees corrective action program as Condition Report CR-GGN-2017-09112. The team determined that the failure to ensure adequate design control measures are translated into procedures and training is a performance deficiency. The performance deficiency is more than minor, and therefore a finding, because it was associated with the barrier performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the plant was operated at power for an extended period of time without adequate procedures and training for licensed operators to ensure that the system would be placed in service in a manner that ensured radiological leakage across main steam isolation valves and through feedwater pi ping is addressed during a postulated accident. In accordance with Manual Chapter 0609, Significance Determination Process, Attachment 4 (effective date October 7, 2016); and the corresponding Appendix A, The Significance Determination Process (SDP) f or Findings At-Power, Exhibit 3, Barrier Integrity Screening Questions (issue date June 19, 2012); the issue was evaluated using Appendix H, Containment Integrity Significance Determination Process (issue date May 6, 2004). Because the opportunities to ensure the design control measures were correctly captured in procedures and instructions for the main steam isolation valve-leakage control system and feedwater leakage control system were in 2001 and 1987, respectively; and the licensee instituted a time-critical operator action program within the last year to prevent such issues from occurring, the issue was determined to have very low safety significance (Green). The performance deficiency was not indicative of current performance. Therefore, no cross-cutting aspect is being assigned.
05000416/FIN-2017007-0331 December 2017 23:59:59Grand GulfNRC identifiedFailure to Establish a Preventive Maintenance Procedure for Safety -Related EquipmentThe team identified a Green, non -cited violation of Technical Specification (TS) 5.4.1, which states , in part , Written procedures shall be established, implemented, and maintained covering the following activities , referenced in Regulatory Guide (RG) 1.33, Revision 2, dated February 1978, Appendix A.9 , Procedures for Performing Maintenance, which requires that maintenance that can affect the performance of safety -related equipment should be properly pre- planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstance. Specifically, prior to September 29, 2017, the licensee did not have a procedure to implement maintenance as recommended by the vendor in Vendor Document VM460000161, ELMA Cast Coil Power Transformers Installation, Maintenance, Operating, and Storage Instructions. In response to this issue, the licensee performed testing to ensure that the transformer will perform its design function and is developing an improved maintenance procedure. The finding was entered into the corrective action program as Condition Report CR- GGN -2017- 09390. The team determined that the failure to implement vendor recommended preventive maintenance is a performance deficiency. The finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to have procedures that implement vendor recommended maintenance resulted in a question regarding the functionality of the transformer at elevated temperature. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At -Power, dated July 19, 2012, the finding screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of non- technical specification equipment; and did not screen as potentially risk -significant due to seismic, flooding, or severe weather. This finding had a cross -cutting aspect in the area of human performance associated with conservative bias because the licensee failed to ensure that maintenance implement a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority (H.5).
05000416/FIN-2017014-0131 December 2017 23:59:59Grand GulfNRC identifiedInappropriate Proctoring of Training Examinations10 CFR 50.120, requires, in part, that each holder of an operating license shall implement a training program derived from a systems approach to training (SAT) as defined in 10 CFR 55.4 that provides for the training and qualification of electrical maintenance, mechanical maintenance, and engineering support personnel.10 CFR 55.4 defines a SAT program as including, in part, an evaluation of trainee mastery of the objectives during training.Licensee Procedure EN-TQ-107, General Employee Training, Revision 9, a quality related procedure, provides instructions for implementing the General Employee Training Program for Entergy Operations, Inc., including plant access training and radiation worker training for electrical maintenance, mechanical maintenance, and engineering support personnel. Step 5.5(2) requires, in part, that all general employee training examinations provided to non-utility personnel be proctored.Licensee Procedure EN-TQ-201-04, SAT - Implementation Phase, Revision 5, a quality related procedure, provides instructions for administering examinations in the training program. Step 5.12(7)(h) requires that proctors answer trainees questions carefully to avoid compromise of the examination. Step 5.12(7)(i) requires that the proctor notmodify a trainees answer or direct a trainee to change an answer.Licensee Procedure EN-TQ-217, Examination Security, Revision 4, a quality related procedure, provides controls necessary for examination security. Step 3.0(3) defines Exam Compromise as any activity that could affect equitable and consistent administration of the examination in question regardless of whether the activity takes place, before, during, or after the examination administrated. Step 4.0(5) states, in part, that instructors are responsible for establishing and maintaining examination security and immediately reporting to training management any potential or actual examination compromise.Contrary to the above, from January through September 2015, the licensee failed to implement the SAT training program that provides for the training and qualification of electrical maintenance, mechanical maintenance, and engineering support personnel. Specifically, the licensee failed to ensure that general employee training examinations provided to non-utility (contractor) personnel were appropriately proctored. An examination proctor compromised examinations by providing inappropriate assistance (i.e., answers and/or information leading to answers) during trainee examinations.This apparent violation is designated as AV 05000416/2017014-01, Inappropriate Proctoring of Training Examinations.
05000416/FIN-2017007-0831 December 2017 23:59:59Grand GulfLicensee-identifiedLicensee-Identified Violation10 CFR 50 Appendix B, Criterion III, requires in part, That measures shall be established to assure that the design bases are correctly translated into specifications, drawings procedures, and instructions. Contrary to the above, from original plant construction until June 22, 2016, GGNS failed to ensure the design basis tornado and differential pressures associated with it, would not cause a spurious trip of the Division I and II standby diesel generators. Specifically, a design basis tornado, includes a differential pressure of 3.0 psig, whereas an active diesel generator trip on high crankcase pressure actuates at 1.5 psig. The licensee identified this issue using an effective operating experience program and entered it in the corrective action program as Condition Report CR -GGN -2016- 04919. The violation is of very low safety significance (Green), for the same reason as NCV -05000416/2017007 -05, discussed in Section 1R21.4.5 of this report.
05000416/FIN-2017014-0331 December 2017 23:59:59Grand GulfNRC identifiedFalsification of Operator Rounds Records10 CFR 50.9 requires, in part, that information required by the Commissions regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects.10 CFR Part 50, Appendix B, Criterion XVII, Quality Assurance Records requires, in part, that sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include at least the following: operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses.Procedure EN-OP-115-01, Operator Rounds, Revision 1, a quality related procedure, provides instructions for operators to conduct watchstanding rounds. It defines operator rounds as electronic media or data sheets used by the operator to record parameters or conditions existing in his area of responsibility. Subparagraph 5.1(7) requires, in part, that operators tour all required areas of their watch station, and Subparagraph 5.2(3) requires operators assigned to an area to complete rounds applicable to that area.Contrary to the above, between February and December 2016, the licensee failed to ensure that information required by the Commission's regulations, orders, or license conditions to be maintained by the licensee were complete and accurate in all material respects. Specifically, non-licensed operators did not tour all required areas of their watch station, and then deliberately completed falsified rounds for their assigned area. These operator rounds are material to the NRC because when performing inspections, the NRC uses the information contained in the rounds to ensure that the condition of safety-related equipment is being monitored as required by station procedures.This apparent violation is designated as AV 05000416/2017014-03, Falsification of Operator Rounds Records.
05000416/FIN-2017007-0731 December 2017 23:59:59Grand GulfLicensee-identifiedLicensee-Identified ViolationThe following violations of very low safety significance (Green) were identified by the licensee and are violations of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as non- cited violations. Technical Specification 5.4.1(a) requires written procedures to be established, implemented, and maintained as recommended by Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Section 4.e recommends, in part, instructions for startup of shutdown cooling and reactor vessel head spray system be prepared. Contrary to the above, from about 2004 until September 1, 2017, the 04-1-01-E12-2 instruction failed to provide instruction for placing the alternate decay heat removal system in service. Specifically, Step 4.9.2a.7(d) instructs an operator to, Manually control component cooling water temperature by throttling P44-F010A(B)(C), PSW inlet to CCW HXs. However, the purpose of that step is to throttle plant service water flow through the alternate decay heat removal system and component cooling water system to ensure both systems have plant service water flow, which is not accomplished by the instruction step. The licensee identified this procedural violation before the system was credited for availability during an inservice demonstration on September 1, 2017, and entered it in the corrective action program as Condition Report CR-GGN-2017-08643. The violation is of very low safety significance (Green) because, although the procedure did delay placing the system in service due to the procedure error, the system was capable of performing its design function, consistent with Inspection Manual Chapter 0609, Appendix G, Attachment 1, Exhibit 3 screening.
05000416/FIN-2017007-0231 December 2017 23:59:59Grand GulfSelf-revealingFailure to Correct Standby Diesel Generator TripThe team identified a Green, self -revealed, non -cited violation of 10 CFR 50 Appendix B, Criterion XVI, Corrective Actions, which states, in part, Conditions adverse to quality are promptly identified and corrected. On June 22, 2016, the station identified a condition adverse to quality affecting the standby diesel generators, but did not promptly correct the issue until September 22, 2017. Specifically, the actions described in Standing Order 17 -0011 were not appropriate for restoring full capability during a design basis tornado event, which could affect the capability of the Division I and II standby diesel generators. In response to this issue the licensee revised the standing order to have the operator press the diesel generator manual start button while the diesel is running to eliminate the associated non- safety trips. The finding was entered into the corrective action program as Condition Report CR -GGN -2017 -09751. The team determined that the failure to promptly correct a condition adverse to quality, regarding diesel generator capability during a design basis tornado is a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the design control attribute of the Mitigating Systems Cornerstone. Specifically, the failure to correct an identified condition adverse to quality resulted in a prolonged design challenge to the Division I and II standby diesel generator capability, which adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. In accordance with Inspection Manual Chapter 0609, Appendix A, Exhibit 2, dated June 19, 2012, the team determined that the finding required a detailed risk evaluation, per Exhibit 4 screening question number 1, for external event mitigation systems. According to the tornado analysis database prepared by the Office of Reactor Research, the frequency of an F -2 tornado or stronger at Grand Gulf Nuclear Station (GGNS) is 4.71E -4/year. The design basis tornado at GGNS has a maximum wind velocity of 360 mph which correlates to a strong F- 5 tornado. The design basis tornado generates a differential pressure of 3 psi. The pressure of concern is the 1.5 psi that could affect operation of the Division I and II diesel generators. Given that pressure is proportional to the square of the velocity, the wind speed affecting the diesel generators would be approximately 250 mph. 250 mph is in the range of an F- 4 tornado. Using generic distributions of the frequency of varying tornado strengths, the analyst estimated that the frequency of an F- 4 tornado or stronger at GGNS is 3.93E -6/year. Using the site- specific SPAR model, the analyst quantified the conditional core damage probability for a tornado- induced loss of offsite power with the failure of both Division I and II diesel generators. The conditional core damage probability was 6.35E -2. Therefore, the incremental conditional core damage probability of the performance deficiency, using the bounding assumption that all F -4 or stronger tornados striking the site would fail both diesel generators, was 2.50E -7. Qualitatively, given this bounding assumption, and the potential to recover the diesels after failure, the analyst determined that the CDF was less than 1E -7. This results in a finding of very low safety significance (Green). This finding had a cross -cutting aspect in the area of human performance associated with procedure adherence because the licensee failed to follow the operability evaluation process to properly determine operability (H.8).
05000416/FIN-2017014-0231 December 2017 23:59:59Grand GulfNRC identifiedFailure to Perform Operator Rounds10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be accomplished in accordance with documented instructions or procedures of a type appropriate to the circumstances. Procedure EN-OP-115-01, Operator Rounds, Revision 1, a quality related procedure, provides instructions for operators to conduct watchstanding rounds. Subparagraph5.1(7) requires, in part, that watchstanders tour all required areas of their watch station.Contrary to the above, between February and December, 2016, three watchstandersfailed to tour all required areas of their watchstation. Specifically, three non-licensed operators deliberately failed to tour the area of the standby service water pump houses, which is an area they were required to tour for that watch station.This apparent violation is designated as AV 05000416/2017014-02, Failure to Perform Operator Rounds.
05000416/FIN-2017012-0230 September 2017 23:59:59Grand GulfNRC identifiedFailure to Operate the Gaseous Radwaste System Within Design SpecificationsThe inspectors identified a finding associated with the licensees failure to operate the gaseous radwaste system within design specifications. These deficiencies in design specifications were associated with the off gas charcoal adsorber and vault refrigeration components of the gaseous radwaste system, which has impacted the systems reliability and efficiency since at least 2007. The design parameters for offgas flow rate into the charcoal adsorbers and vault refrigeration temperature were 30 scfm and 0 degrees Fahrenheit, respectively. In contrast, the gaseous radwaste system is being operated with an approximate flow rate is 80 scfm and vault refrigeration temperature is 15 degrees Fahrenheit. The licensee has developed a system improvement plan to address resolution of these issues during the next scheduled outages. This performance deficiency was entered into the licensees corrective action program as Condition Report CR-GGN-2017-06875. 5 The failure to operate the offgas gaseous radwaste system within design specifications, resulting in elevated radiological effluent releases, is a performance deficiency. The finding is more than minor because it is associated with the plant equipment attribute of the Public Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure of radioactive materials released into the public domain as a result of routine civilian nuclear plant operation. Using Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance (Green) because it involved the Effluent Release Program, it did not impair the ability to assess dose, and did not exceed the 10 CFR Part 50, Appendix I, or 10 CFR 20.1301(d) limits. The finding has a cross - cutting aspect in the area of problem identification and resolution, associated with the resolution component, because the licensee failed to take effective corrective actions in a timely manner to minimize the unreliability and inefficiency of the gaseous radwaste system (P.3).
05000416/FIN-2017003-0130 September 2017 23:59:59Grand GulfSelf-revealingIsolation of Reactor Core Isolation Cooling System during Surveillance TestingThe inspectors reviewed a self-revealed, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to accomplish quality related activities in accordance with Surveillance Procedure 06-IC-1E31-A-1004, RCIC Equipment Room High Temperature Calibration Channel A, Revision 106. Specifically, on August 21, 2017, the licensee did not follow Step 5.15.4, which states, Identify and disconnect field lead located at Terminal EE-50 in 1H13-P632. This step was not performed correctly; therefore, the reactor core isolation cooling (RCIC) system isolation feature was not bypassed. When performing the next step, an inadvertent isolation of the RCIC system occurred. On August 21, 2017, the licensee restored compliance by performing actions to restore the leads to the correct location and performing the surveillance test satisfactorily. This issue has been entered into the licensees corrective action program as Condition Report CR-GGN-2017-08246.The failure to follow Surveillance Procedure 06-IC-1E31-A-1004 was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because it was associated with the human performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensees failure to follow Surveillance Procedure 06-IC-1E31-A-1004 resulted in unplanned inoperability and unavailability of the reactor core isolation cooling system. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, and Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating System Screening Questions, the inspectors determined that the finding was of very low safety significance (Green) because the finding was not a deficiency affecting the design or qualification of a mitigating structure, system, or component; did not represent a loss of safety function; did not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time, and did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. The inspectors determined that the finding had a field presence cross-cutting aspect within the human performance area because licensee management failed to ensure supervisory and management oversight of work activities, including contractors and supplemental personnel. Specifically, the performer in the field was a supplemental worker that was observed by a licensee instrumentation and controls technician. The technician telephoned the supervisor to ensure that they were performing the steps correctly, and the supervisor did not go into the field to verify the step was performed correctly (H.2).
05000416/FIN-2017003-0230 September 2017 23:59:59Grand GulfLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR 55.49 requires, in part, that licensees shall not engage in any activity that compromises the integrity of any test or examination required by 10 CFR 55.49. The integrity of a test or examination is considered compromised if any activity, regardless of intent, affected, or, but for detection, would have affected the equitable and consistent administration of the test or examination. Contrary to the above, on August 8, 2017, Grand Gulf Nuclear Station engaged in an activity that compromised the integrity of an examination required by 10 CFR 55.49. Specifically, the licensee left written exam material from a previous weeks exam unattended. The previous weeks exam contained half of the current weeks written exam material. The exam material was marked appropriately and located within an instructors office. This finding was determined to be of very low safety significance (Green) because the finding did not have an actual effect on the equitable and consistent administration of the biennial requalification exam cycle. The licensee entered this issue into the corrective action program as Condition Report CR-GGN-2017-07723.
05000416/FIN-2017012-0130 September 2017 23:59:59Grand GulfNRC identifiedFailure to Correct Instrument Calibration Process in a Timely MannerThe inspectors identified a violation of 10 CFR 20.1501(c) for the failure to properly calibrate installed radiation monitors using industry accepted calibration methods and tolerances. Specifically, since January 2012, the licensee failed to properly calibrate the following radiation monitors: main steam line, containment high range, and the drywell high range. This violation was originally entered into the licensees corrective action program in March 2015 as Condition Report CR-GGNS-2015-01832. However, in 2017, inspectors determined that subsequent to 2015, the licensee failed to implement corrective actions to properly calibrate the instruments. The licensee entered this repetitive issue into their corrective action process as Condition Report CR-GGN-2017-06826. The failure to properly calibrate radiation monitors is a performance deficiency. The performance deficiency is more than minor because it is associated with the cornerstone attribute of plant instrumentation and adversely affects the cornerstone objective to ensure adequate protection of employee health and safety during routine civilian nuclear reactor operation and is therefore a finding. Specifically, the failure to properly calibrate radiation monitors impacts the licensees ability to assess dose rates. Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, the inspectors determined the finding to be of very low safety significance because it was not an as low as reasonably achievable (ALARA) issue, there was no overexposure or substantial potential for overexposure, and the licensees ability to assess dose was not compromised. This finding has a cross-cutting aspect in the resources component of the Problem Identification and Resolution area because the licensee did not ensure that effective corrective actions were implemented to address issues in a timely manner commensurate with the safety significance (P.3).
05000416/FIN-2017008-0230 June 2017 23:59:59Grand GulfNRC identifiedInadequate Alternative Shutdown Procedure TimingGreen. The team identified a Green non-cited violation of Technical Specification 5.4.1.a for the failure to implement and maintain adequate written procedures covering a fire in the control room. Specifically, the licensee failed to maintain an alternative shutdown procedure that ensured operators could safely shut down the plant under all postulated fire scenarios within the time limits established by the thermal hydraulic analysis. The licensee entered this finding into their corrective action program as Condition Report CR-GGN-2017-04011. As an immediat e compensatory measure, the license issued Standing Order 17-0010 to provide operators additional guidance. The failure to implement and maintain adequate written procedures covering timed operator actions during a fire in the cont rol room was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the alternative shutdown procedur e failed to ensure operators could safely shut down the plant under all postulated fire scenarios within the time limits established by the thermal hydraulic analysis. The team evaluated this finding using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, dated September 20, 2013, because it affected the ability to reach and maintain safe shutdown conditions in case of a fire. A senior reactor analyst performed a Phase 3 evaluation to determine the risk significance of this finding since it involved a postulated control room fire that led to control room evacuation. The senior reactor analyst determined this finding was of very low safety significance. The finding did not have a cross-cutting aspect since it was not indicative of present performance in that the performance deficiency occurred more than 3 years ago.
05000416/FIN-2017002-0530 June 2017 23:59:59Grand GulfLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR 50.72(b)(2)(iv)(B) requires, in part, the licensee shall notify the NRC as soon as practical , and in all cases within 4 hours of the occurrence, of any event or 24 condition that results in actuation of the reactor protection system (RPS) when the reactor is critical. Contrary to the above, on April 4, 2017, the licensee did not notify the NRC within 4 hours of the occurrence of any event or condition that resulted in actuation of the RPS when the reactor was critical. Specifically, the licensee failed to notify the NRC within 4 hours after they performed a manual scram of the reactor due to a failure in the condensate system. The NRCs significance determination process is not designed to assess the significance of violations that impact or impede the regulatory process. Therefore, the issue of an untimely notification was assessed using the traditional enforcement process in accordance with the Enforcement Policy. The inspectors determined the violation to be at Severity Level IV in accordance with Enforcement Policy Section 6.9.d.9. Since this issue was entered into the licensees corrective action program as Condition Report CR -GGN -1-2017 -03331, compliance was restored within a reasonable period of time, the violation was not repetitive, and the violation was not willful, this violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2.a of the Enforcement Policy. Traditional enforcement violations are not assigned a cross -cutting aspect.
05000416/FIN-2016008-0130 June 2017 23:59:59Grand GulfNRC identifiedFailure to Have Alternate Decay Heat Removal CapabilityThe team identified two examples of a non -cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to have adequate procedures for activities affecting quality. Specifically, Grand Gulf Nuclear Station failed to have adequate procedures for feedwater, condensate, and shutdown cooling activities. The licensee implemented corrective actions to revise the procedures. The licensee entered this issue into their corrective action program as Condition Reports CR- GGN -2016- 08334, 08273, and 08290. The failure to have adequate procedures for activities affecting quality was a performance deficiency. Example (1) of this performance deficiency was more than minor, and therefore a finding, because it was associated with the procedure quality attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, not having procedural guidance for the alternate decay heat removal system alignment resulted in misalignment of the system and its subsequent inability to perform its required function if needed. A detailed risk evaluation (Attachment 2) calculated an increase in core damage frequency of 3.2E -7/year and an increase in large early release frequency of 7.3E -8/year, which has a very low safety significance (Green) . Example (2) of this performance deficiency was more than minor, and therefore a finding, because it was associated with the procedure quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown operations. Specifically, not having procedural guidance for feedwater isolation valve operation resulted in inadvertent over fill of the reactor vessel. This violation is associated with a finding having very low safety significance (Green). The team did not assign a cross -cutting aspect because the performance deficiency was not reflective of current plant performance .
05000416/FIN-2017008-0330 June 2017 23:59:59Grand GulfNRC identifiedFailure to Isolate Control Circuits for Safe Shutdown Equipment From the Effects of a Control Room FireGreen. The team identified a Green non-cited violation of License Condition 2.C.(41) for the failure to implement and maintain in effect all provisions of the approved fire protection program. Specifically, the licensee failed to adequately isolate control circuits for safe shutdown equipment to ensure independence from the effects of a fire in the control room. The licensee entered this finding into their corrective action program as Condition Report CR-GGN-2017-04028. As an immediate compensatory measure, the licensee issued Standing Order 17-0010 to provide operators additional guidance. The failure to adequately isolate control circuits for safe shutdown equipment from the effects of a control room fire was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the spurious actuation of safety relief valves would adversely affect the safe shutdown 4 equipment relied upon to achieve and maintain safe shutdown conditions. The team evaluated this finding using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, dated September 20, 2013, because it affected the ability to reach and maintain safe shutdown conditions in case of a fire. A senior reactor analyst performed a Phase 3 evaluation to determine the risk significance of this finding since it involved a postulated control room fire that led to control room evacuation. The senior reactor analyst determined this finding was of very low safety significance. The finding did not have a cross-cutting aspect since it was not indicative of present performance in that the performance deficiency occurred more than 3 years ago
05000416/FIN-2017002-0130 June 2017 23:59:59Grand GulfSelf-revealingFailure to Establish an Appropriate Preventative Maintenance Procedure for the HPCS Jockey PumpGreen . The inspectors reviewed a self -revealed, non- cited violation of Technical Specification 5.4.1.a, for the licensees failure to establish appropriate procedural instructions for performing preventative maintenance on the high pressure core spray jockey pump. Specifically, on January 27, 2017, the high pressure core spray jockey pump failed because the licensee did not establish a preventative maintenance procedure that prescribes oil analysis and additional performance trending for the high pressure core spray jockey pump every 6 months consistent with the licensees preventative maintenance strategy template. On January 29, 2017, the licensee completed repairs and returned the high pressure core spray jockey pump and high pressure core spray system to operable status . The licensee has also incorporated oil analysis and performance trending into the preventative maintenance for jockey pumps. This issue has been entered into the licensees corrective action program as Condition Report CR -GGN -2017- 0917. The failure to establish appropriate preventative maintenance instructions for the high pressure core spray jockey pump was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, 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. Specifically, the failure to establish appropriate preventative and predictive maintenance work instructions resulted in the unplanned inoperability and unavailability of the high pressure core spray system. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At -Power, dated June 19, 2012, and Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that the finding resulted in a loss of system and/or function; therefore, a detailed risk evaluation was performed. A senior reactor analyst performed a detailed risk evaluation in accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power. The NRC determined that the increase in core damage frequency for internal initiators was 1.59 E-7/year, and a bounding analysis of external initiators indicated that these events would not result in a 3 change in the color of the finding. Therefore, this finding is of very low safety significance (Green). The analyst also determined that an estimation of large early release frequency (LERF) was required. The result was an increase in LERF of 3.19E -8/year, which is of very low safety significance for LERF (Green). This finding had a cross -cutting aspect in the area of human performance associated with consistent process because the licensee did not use a consistent, systematic approach to make decisions. Specifically, the licensee did not use a consistent approach in developing a preventative maintenance strategy for the high pressure core spray jockey pump by utilizing the approved preventative maintenance strategy template (H.13).
05000416/FIN-2016008-0230 June 2017 23:59:59Grand GulfNRC identifiedFailure to Have Adequate ProceduresThe team reviewed a self -revealed, non -cited violation of Technical Specification 3.4.10, Residual Heat Removal Shutdown Cooling System Cold Shutdown, for the licensees failure to verify an alternate method of decay heat removal was available when residual heat removal subsystem A was inoperable and unavailable due to a pump replacement. Specifically, the licensee inappropriately credited the alternate decay heat removal system as an available alternate method of decay heat removal. Credit for this system was inappropriate because, although the licensee believed the system had been aligned in standby, the alternate decay heat removal heat exchanger isolation valves had remained tagged closed, rendering the system unavailable to satisfy the technical specification requirement during the time period that residual heat removal subsystem A was unavailable. The licensee restored compliance by restoring residual heat removal subsystem A to available status . The licensee entered this issue into their corrective action program as Condition Report CR -GGN -2016 -07281. The failure to perform the required action to verify an alternate method of decay heat removal was available, when a residual heat removal shutdown cooling system was inoperable, was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the human performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. A detailed risk evaluation (Attachment 2) calculated an increase in core damage frequency of 3.2E -7/y ear and an increase in large early release frequency of 7.3E -8/year. Therefore, this violation is associated with a finding having very low safety significance (Green). The team determined the finding had a cross -cutting aspect within the human performance area, field presence, because leaders failed to reinforce standards and expectations in the work areas of the plant (H.2).
05000416/FIN-2017002-0230 June 2017 23:59:59Grand GulfLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR 72.44(d)(3) requires, in part, that an annual report be submitted to the Commission, specifying the quantity of each of the principal radionuclides released to the environment in liquid and in gaseous effluents during the previous 12 months of operation and such other information as may be required by the Commission to estimate maximum potential radiation dose commitment to the public resulting from effluent releases. The report must be submitted within 60 days after the end of the 12- month monitoring period. Contrary to the above, from March 2, 2017 , until April 27, 2017, the licensee did not submit the annual report within 60 days after the end of the 12- month monitoring period. The NRCs significance determination process is not designed to assess the significance of violations that impact or impede the regulatory process. Therefore, the issue of an untimely annual report submittal was assessed using the traditional enforcement process in accordance with the Enforcement Policy. The inspectors determined the violation to be at Severity Level IV because the licensee submitted the annual report approximately 2 months late, and it is similar to examples in the Enforcement Policy , Section 6.9.d. Since this issue was entered into the licensees corrective action program as Condition Report CR-GGN-1-2017-03092 , compliance was restored within a reasonable period of time, the violation was not repetitive, and the violation was not willful, this violation is being treated as a n on-cited violation (NCV), consistent with Section 2.3.2.a of the Enforcement Policy. Traditional enforcement violations are not assigned a cross -cutting aspect .
05000416/FIN-2017008-0430 June 2017 23:59:59Grand GulfNRC identifiedInadequate Alternative Shutdown Procedure StepGreen. The team identified a Green non-cited violation of Technical Specification 5.4.1.a for the failure to maintain adequate written procedures covering a fire in the control room. Specifically, the licensee failed to ensure that all steps in Procedure 05-1-02-II-1, Shutdown from the Remote Shutdown Panel, could be performed as written. Specifically, the licensees procedure did not provide specific guidance to the control room staff on how to actuate the low pressure core spray pump breaker lockout relay. The licensee initiated Condition Report CR-GGN-2017-03368 to address the deficiency and immediately implemented Standing Order 17-0009, which provides specific guidance to the control room staff on how to actuate the low pressure core spray pump breaker lockout relay. The failure to provide a procedure that operators understood to implement the requirements of the approved fire protection program for a fire in the control room was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the alternative shutdown procedure failed to ensure operators could safely shut down the plant during a control room fire causing circuit faults. The team evaluated this finding using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, dated September 20, 2013, because it affected the ability to reach and maintain safe shutdown conditions in case of a fire. A senior reactor analyst performed a Phase 3 evaluation to determine the risk significance of this finding since it involved a postulated control room fire that led to control room evacuation. The Senior Reactor Analyst determined this finding was of very low safety significance. The finding did not have a cross-cutting aspect since it was not indicative of present performance in that the performance deficiency occurred more than 3 years ago.
05000416/FIN-2017008-0130 June 2017 23:59:59Grand GulfNRC identifiedUntimely Corrective ActionGreen. The team identified a non-cited violation of License Condition 2.C.(41) for failure to correct a condition adverse to fire protection in a timely manner. Specifically, the licensee failed to complete evaluations of multiple spurious operations (MSO) concerns identified in 2011. The licensee entered this finding into their corrective action program as Condition Report CR-GGN-2017-03996. The failure to correct a condition adverse to fire protection in a timely manner was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, untimely resolution of these MSO actuations placed the facility at risk of being unable to safely shutdown the facility in response to a fire. The finding was screened in accordance with Inspection Manual Chapter (IMC) 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, dated June 19, 2012. Because the finding affected the ability to achieve and maintain post-fire safe shutdown, the team reviewed the finding using IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated September 20, 2013. The finding was screened as a Green finding of very low safety significance in accordance with Task 1.3, Ability to Achieve Safe Shutdown, Question A. Although the licensee failed to completely evaluate the impact of MSOs that could potentially result in the loss of suppression pool inventory, the team determined that for all fire areas one division of the residual heat removal system and the supporting standby service water system remained available along with suppression pool level indication. The team confirmed that suppression pool makeup for the standby service water system would remain available. For the postulated control room fire that led to control room evacuation, a senior reactor analyst performed a Phase 3 evaluation to determine the risk significance of this finding. The senior reactor analyst determined this finding was of very low safety significance. The finding had a cross-cutting aspect in 3 the Conservative Bias component of the Human Performance area because the licensee failed to use decision making-practices that emphasize prudent choices over those that are simply allowable. Specifically, the licensee reclassified a condition report to be non-adverse allowing resolution to be given a lower priority prior to completing the evaluations required to provide a technical basis for that decision (H.14)
05000416/FIN-2016008-0330 June 2017 23:59:59Grand GulfNRC identifiedFailure to Follow Operations ProceduresThe team identified a non -cited violation of Technical Specification 5.4.1.a , Procedures, for the licensees failure to implement procedures required by Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Specifically, contrary to procedures , on September 23, 2016, operations personnel failed to verify adequate plant service water flow to the alternate decay heat removal heat exchangers while placing the system in service . The licensee implemented corrective actions which included high intensity training to improve nuclear worker behaviors and clarifying the directions in the procedure. The licensee entered this issue into the corrective action program as Condition Report CR- GGN -2016- 08333. The failure to implement procedures , as required by Technical Specification 5.4.1. a, was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because , if left uncorrected, the failure to implement procedures as required by Technical Specification would have the potential to lead to a more significant safety concern. Using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process , and Inspection Manual Chapter 0609, Appendix G, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, the team determined that the finding was of very low safety significance (Green ) because it did not affect the design or qualification of a mitigating system structure, system , or component and did not directly prevent the alternate decay heat removal system from maintaining its functionality. The team identified a cross -cutting aspect the area of human performance, challenge the unknown, because individuals failed 4 to stop when faced with uncertain conditions and risks were not evaluated and managed before proceeding (H.11).
05000416/FIN-2017002-0330 June 2017 23:59:59Grand GulfLicensee-identifiedLicensee-Identified ViolationLicense Condition 2.C (46)(f) requires, during the first two scheduled refueling outages after reaching full EPU (extended power uprate) conditions, Entergy shall conduct a visual inspection of all accessible, susceptible locations of the steam dryer in accordance with BWRVIP -139 and GE inspection guidelines. Entergy shall report the results of the visual inspections of the steam dryer to the NRC staff within 60 days following startup. Contrary to the above, on August 16, 2012 , and May 15, 2014, the licensee did not report the results of the visual inspections of the steam dryer to the NRC staff within 60 days following startup. The NRCs significance determination process is not designed to assess the significance of violations that impact or impede the regulatory process. Therefore, the issue of an untimely inspection results submittal was assessed using the traditional enforcement process in accordance with the Enforcement Policy. The inspectors determined the violation to be at Severity Level IV because it is similar to examples in the Enforcement Policy Section 6.9.d. Since this issue was entered into the licensees corrective action program as Condition Report CR -GGN -1-2017 -03404, compliance was restored within a reasonable period of time, the violation was not repetitive, and the violation was not willful, this violation is being treated as a n on-cited violation (NCV), consistent with Section 2.3.2.a of the Enforcement Policy. Traditional enforcement violations are not assigned a cross -cutting aspect.
05000416/FIN-2017002-0430 June 2017 23:59:59Grand GulfLicensee-identifiedLicensee-Identified ViolationLicense Condition 2.C (46)( g) requires, at the end of the second refueling outage following the implementation of the EPU, the licensee shall submit a long- term steam dryer inspection plan based on industry operating experience along with the baseline inspection results f or NRC review and approval. Contrary to the above, since May 15, 2014, the licensee did not submit a long -term steam dryer inspection plan based on industry operating experience along with the baseline inspection results for NRC review and approval. The NRCs significance determination process is not designed to assess the significance of violations that impact or impede the regulatory process. Therefore, the issue of an untimely inspection plan submittal was assessed using the traditional enforcement process in accordance with the Enforcement Policy. The inspectors determined the violation to be at Severity Level IV because it is similar to examples in the Enforcement Policy Section 6.9.d. Since this issue was entered into the licensees corrective action program as Condition Report CR -GGN -1-2017 -03404, compliance was restored within a reasonable period of time, the violation was not repetitive, and the violation was not willful, this violation is being treated as a n on-cited violation (NCV), consistent with Section 2.3.2.a of the Enforcement Policy. Traditional enforcement violations are not assigned a cross -cutting aspect.
05000416/FIN-2017001-0331 March 2017 23:59:59Grand GulfLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR 50.54(q)(2) requires, in part, that a power reactor licensee follow an emergency plan which meets the requirements of Appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b). Planning Standard 10 CFR 50.47(b)(4) requires, in part, that a standard emergency classification and action level scheme is in use by the licensee. Contrary to the above, on June 7, 2015, Grand Gulf Nuclear Station failed to follow an emergency plan which met the requirements of Appendix E and the standards 20 of 10 CFR 50.47(b). Specifically, the licensee failed to accurately classify a Notification of Unusual Event in accordance with the licensees emergency action level scheme. The licensee declared the emergency based on a fire condition, which did not exist, as identified in the licensees after-action report dated July 13, 2015. The finding was evaluated using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015, and was determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements, was associated with a risk-significant planning standard, and was not a lost or degraded planning standard function. The licensee entered this issue into the corrective action program as Condition Reports CR-GGN-2015-03345 and CR-GGN-2017-00288.
05000416/FIN-2017001-0231 March 2017 23:59:59Grand GulfNRC identifiedGrand Gulf Unplanned Power Changes per 7000 Critical Hours Performance IndicatorThe inspectors identified an URI associated with the unplanned power changes per 7000 critical hours performance indicator related to events that occurred on June 17, 2016. Description. On June 17, 2016, during turbine stop valve testing, stop valve B was to be cycled closed. Upon performing that action, stop valve B closed as expected; however, stop valve D unexpectedly closed. In response to the unexpected valve closure, the electro-hydraulic control trip fluid pressure fluctuated at an increased rate which caused the turbine control valves to cycle. This valve cycling resulted in numerous unplanned reactor pressure and power changes for approximately 42 minutes. During this time, operations personnel repeatedly performed troubleshooting activities by attempting to reset the stop valves, which caused additional system instability and increased the magnitude of the power oscillations. Ultimately, operations personnel decided to insert control rods in an attempt to stabilize the power and pressure oscillations. The operator action to insert control rods failed to stabilize the power and pressure oscillations, and approximately 1 minute later, an automatic reactor scram occurred due to a valid oscillating power range monitor input to the reactor protection system. This event was documented in Licensee Event Report 05000416/2016004-00, and NRC Inspection Reports 05000416/2016002 and 05000416/2016003. The unplanned power changes per 7000 critical hours performance indicator measures the rate of unplanned power changes per year of operation at power and provides an indication of initiating event frequency. The licensee did not include any unplanned power changes as inputs into this performance indicator for the second quarter of 2016. The inspectors questioned whether any unplanned power changes should have been reported with this performance indicator, and the licensee submitted a frequently asked question (FAQ) to the NRC reactor oversight process working group (ADAMS Accession No. ML17100A235, 03/23/2017 Reactor Oversight Process Working Group Public Meeting). This FAQ (FAQ 17-01) is currently under review to determine whether the above events should be captured as inputs to the unplanned power changes performance indicator. The inspectors concluded that additional inspection would be required to assess whether the unplanned power changes should have been reported in the unplanned power changes per 7000 critical hours performance indicator. This issue was identified as URI 05000416/2017001-02, Grand Gulf Unplanned Power Changes per 7000 Critical Hours Performance Indicator.