IR 05000416/2019002: Difference between revisions

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=Text=
=Text=
{{#Wiki_filter:August 14, 2019 Mr. Eric Larson Site Vice President Entergy Operations, Inc.
{{#Wiki_filter:ust 14, 2019


Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150 SUBJECT: GRAND GULF NUCLEAR STATION  
==SUBJECT:==
- INTEGRATED INSPECTION REPORT 05000416/2019002
GRAND GULF NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000416/2019002


==Dear Mr. Larson:==
==Dear Mr. Larson:==
On June 30, 2019
On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Grand Gulf Nuclear Station. On July 11, 2019, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Grand Gulf Nuclear Station. On July 11, 2019
, the NRC inspectors discussed the results of this inspection with you and other members of your staff.


The results of this inspection are documented in the enclosed report. The NRC inspectors documented one finding of very low safety significance (Green) in this report. The finding did not involve a violation of NRC requirements.
The NRC inspectors documented one finding of very low safety significance (Green) in this report. The finding did not involve a violation of NRC requirements. Additionally, NRC inspectors documented one Severity Level IV violation with no associated finding. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.


Additionally, NRC inspectors documented one Severity Level IV violation with no associated finding. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
Inspection Procedure 92723, Follow up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period, was performed during this inspection period to assess your evaluation of 10 previously issued violations in the area of impeding the regulatory process, and to assess the adequacy of associated corrective actions. Based on the results of this inspection, which are documented in the enclosed report, the NRC was not able to conclude that the actions taken were adequate to meet the inspection objectives. Therefore, additional inspection will be performed to continue this review under Inspection Procedure 92723 upon notification of your readiness. The additional Severity Level IV violation documented in the enclosed report, which is also in the area of impeding the regulatory process, will be included in the scope of this traditional enforcement follow-up inspection.


Inspection Procedure 92723, "Follow up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period," was performed during this inspection period to assess your evaluation of 10 previously issued violations in the area of impeding the regulatory process, and to assess the adequacy of associated corrective actions. Based on the results of this inspection, which are documented in the enclosed report, the NRC was not able to conclude that the actions taken were adequate to meet the inspection objectives. Therefore, additional inspection will be performed to continue this review under Inspection Procedure 92723 upon notification of your readiness. The additional Severity Level IV violation documented in the enclosed report, which is also in the area of impeding the regulatory process, will be included in the scope of this traditional enforcement follow-up inspection.
If you contest the violation or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Grand Gulf. If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Grand Gulf.


If you contest the violation or severity of the violation documented in this inspection report, 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
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Grand Gulf
. If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S.
 
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Grand Gulf
. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding
."


Sincerely,
Sincerely,
/RA/ Cale H. Young, Acting Chief Reactor Project Branch C Division of Reactor Projects Docket No. 05000416 License No
/RA/
. NPF-29  
Cale H. Young, Acting Chief Reactor Project Branch C Division of Reactor Projects Docket No. 05000416 License No. NPF-29


===Enclosure:===
===Enclosure:===
Line 51: Line 43:


==Inspection Report==
==Inspection Report==
Docket Number
Docket Number: 05000416 License Number: NPF-29 Report Number: 05000416/2019002 Enterprise Identifier: I-2019-002-0008 Licensee: Entergy Operations, Inc.
: 05000416 License Number:
NPF-29 Report Number:
05000416/2019002 Enterprise Identifier:
I-2019-002-0008 Licensee: Entergy Operations, Inc.


Facility: Grand Gulf Nuclear Station Location: Port Gibson, MS Inspection Dates:
Facility: Grand Gulf Nuclear Station Location: Port Gibson, MS Inspection Dates: April 1, 2019 to June 30, 2019 Inspectors: L. Carson, Senior Health Physicist N. Day, Resident Inspector D. Dodson, Senior Resident Inspector P. Elkmann, Senior Emergency Preparedness Inspect S. Hedger, Emergency Preparedness Inspector W. Sifre, Senior Reactor Inspector T. Steadham, Senior Resident Inspector B. Tharakan, Senior Project Engineer D. Reinert, Ph.D., Reactor Inspector Approved By: Cale H. Young, Acting Chief Reactor Project Branch C Division of Reactor Projects
April 1, 2019 to June 30, 2019 Inspectors:
L. Carson, Senior Health Physicist N. Day, Resident Inspector D. Dodson, Senior Resident Inspector P. Elkmann, Senior Emergency Preparedness Inspect S. Hedger, Emergency Preparedness Inspector W. Sifre, Senior Reactor Inspector T. Steadham, Senior Resident Inspector B. Tharakan, Senior Project Engineer D. Reinert, Ph.D., Reactor Inspector Approved By:
Cale H. Young, Acting Chief Reactor Project Branch C Division of Reactor Projects
 
2


=SUMMARY=
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee's performance by conducting a n integrated inspection at the Grand Gulf Nuclear Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at the Grand Gulf Nuclear Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
. List of Findings and Violations Failure to Update the UFSAR Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000416/2019002
-01 Closed Not Applicable 71111.05Q The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.71(e) for the licensee's failure to update the Updated Final Safety Analysis Report, Section 9A.5. The inspectors identified over 20 discrepancies between the fire zone description s in the Updated Final Safety Analysis Report and the licensee's implementing documents, including Procedure 06
-OP-SP64-R-0047, "Fire Rated Assembly Visual Inspection," Revision 116. The licensee periodically updated fire protection implementing procedures but did not update the Updated Final Safety Analysis Report, when needed, to reflect those changes.
 
Failure to Follow Design Control Procedure Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000416/2019002
-02 Closed [H.6] - Design Margins 71152 A self-revealed, Green finding was identified when an actuation of the generator protection negative phase sequence trip caused a generator lockout and a reactor scram. The licensee failed to ensure that a recent change in the applicable trip setpoint was managed in accordance with Procedure EN-DC-115, "Engineering Change Process," Revision 21. The licensee failed to identify, evaluate, and manage a reduction in operating margin associated with the negative phase sequence trip setpoint. The setpoint was reduced from 9 percent to percent as part of a digital upgrade modification; however, the licensee failed to fully evaluate the change. As a result, routine grid operations above 5 percent negative phase sequence were unmanaged and ultimately led to an unplanned reactor scram.


Additional Tracking Items Type Issue Number Title Report Section Status LER 05000416/2019
List of Findings and Violations Failure to Update the UFSAR Cornerstone            Severity                                Cross-Cutting        Report Aspect              Section Not Applicable        Severity Level IV                        Not Applicable      71111.05Q NCV 05000416/2019002-01 Closed The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.71(e) for the licensee's failure to update the Updated Final Safety Analysis Report, Section 9A.5.
-001-00 Automatic Reactor Shutdown due to Activation of Generator Lockout 71153 Closed 3


=PLANT STATUS=
The inspectors identified over 20 discrepancies between the fire zone descriptions in the Updated Final Safety Analysis Report and the licensee's implementing documents, including Procedure 06-OP-SP64-R-0047, Fire Rated Assembly Visual Inspection, Revision 116. The licensee periodically updated fire protection implementing procedures but did not update the Updated Final Safety Analysis Report, when needed, to reflect those changes.


Unit 1 began the inspection period at full power.
Failure to Follow Design Control Procedure Cornerstone            Significance                            Cross-Cutting        Report Aspect              Section Initiating Events      Green                                    [H.6] - Design      71152 FIN 05000416/2019002-02                  Margins Closed A self-revealed, Green finding was identified when an actuation of the generator protection negative phase sequence trip caused a generator lockout and a reactor scram. The licensee failed to ensure that a recent change in the applicable trip setpoint was managed in accordance with Procedure EN-DC-115, Engineering Change Process, Revision 21. The licensee failed to identify, evaluate, and manage a reduction in operating margin associated with the negative phase sequence trip setpoint. The setpoint was reduced from 9 percent to percent as part of a digital upgrade modification; however, the licensee failed to fully evaluate the change. As a result, routine grid operations above 5 percent negative phase sequence were unmanaged and ultimately led to an unplanned reactor scram.


On April 6, 2019, operators reduced power to approximately 56 percent for control rod pattern adjustments.
Additional Tracking Items Type        Issue Number                Title                          Report Section    Status LER        05000416/2019-001-00        Automatic Reactor              71153            Closed Shutdown due to Activation of Generator Lockout


Full power operation resumed on April 8, 2019.
=PLANT STATUS=


On April 9, 2019, to allow for repair of a high pressure feedwater heater leak, power was reduced to approximately 66 percent. Power was increased to approximately 94 percent on April 12, 2019, with the high pressure feedwater heaters isolated.
===Unit 1 began the inspection period at full power. On April 6, 2019, operators reduced power to approximately 56 percent for control rod pattern adjustments. Full power operation resumed on April 8, 2019. On April 9, 2019, to allow for repair of a high pressure feedwater heater leak, power was reduced to approximately 66 percent. Power was increased to approximately 94 percent on April 12, 2019, with the high pressure feedwater heaters isolated. On April 16, 2019, power was reduced to approximately 65 percent to perform power suppression testing. Following repairs to the feedwater heater and power suppression testing, the unit reached full power on April 21, 2019. On May 12, 2019, due to a significant loss of plant service water, operators manually shut down the unit. Following repairs to the plant service water electrical distribution system, the unit was started up on May 19, 2019, and full power was achieved on May 30, 2019. On June 26, 2019, in order to support replacement of a recirculation flow control valve controller, operators reduced power to approximately 96 percent.


On April 16, 2019, power was reduced to approximately 65 percent to perform power suppression testing. Following repairs to the feedwater heater and power suppression testing, the unit reached full power on April 21, 2019. On May 12, 2019, due to a significant loss of plant service water, operators manually shut down the unit.
On June 27, 2019, the unit reached full power and remained at or near full power for the remainder of the inspection period.
 
Following repairs to the plant service water electrical distribution system, the unit was started up on May 19, 2019, and full power was achieved on May 30, 2019. On June 26, 2019, in order to support replacement of a recirculation flow control valve controller, operators reduced power to approximately 96 percent. On June 27, 2019, the unit reached full power and remained at or near full power for the remainder of the inspection period.


==INSPECTION SCOPES==
==INSPECTION SCOPES==
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC)2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC2 515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
-rm/doc-collections/insp
-manual/inspection
-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC)2515, "Light
-Water Reactor Inspection Program - Operations Phase."  The inspectors performed plant status activities described in IMC 2 515 , Appendix D, "Plant Status
," and conducted routine reviews using IP
 
===71152, "Problem Identification and Resolution."  The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.


==REACTOR SAFETY==
==REACTOR SAFETY==
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==71111.01 - Adverse Weather Protection==
==71111.01 - Adverse Weather Protection==


===Impending Severe Weather Sample (IP Section 03.03) (2 Sample s)
===Impending Severe Weather Sample (IP Section 03.03)===
{{IP sample|IP=IP 71111.01|count=2}}
: (1) The inspectors evaluated readiness for impending adverse weather conditions for storms on April 13, 2019, and April 18, 2019;
: (1) The inspectors evaluated readiness for impending adverse weather conditions for storms on April 13, 2019, and April 18, 2019;
: (2) The inspectors evaluated readiness for impending adverse weather conditions for storms on May 9, 2019.
: (2) The inspectors evaluated readiness for impending adverse weather conditions for storms on May 9, 2019.
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==71111.04 - Equipment Alignment==
==71111.04 - Equipment Alignment==


Partial Walkdown Sample (IP Section 03.01)
===Partial Walkdown Sample (IP Section 03.01)===
(3 Sample s) The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
{{IP sample|IP=IP 71111.04|count=3}}
 
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
: (1) Residual heat removal subsystem A after securing from shutdown cooling for startup on May 18, 2019;
: (1) Residual heat removal subsystem A after securing from shutdown cooling for startup on May 18, 2019;
: (2) Control room air conditioning B following adjustment on capacity control valve on June 4, 2019;
: (2) Control room air conditioning B following adjustment on capacity control valve on June 4, 2019;
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==71111.05A - Fire Protection (Annual)==
==71111.05A - Fire Protection (Annual)==


Annual Inspection (IP Section 03.02)===
===Annual Inspection (IP Section 03.02)===
{{IP sample|IP=IP 71111.01|count=1}}
{{IP sample|IP=IP 71111.05A|count=1}}
: (1) The inspectors evaluated fire brigade performance to a simulated fire in the Unit 2 switchgear room on May 2, 2019.
: (1) The inspectors evaluated fire brigade performance to a simulated fire in the Unit 2 switchgear room on May 2, 2019.


==71111.05Q - Fire Protection==
==71111.05Q - Fire Protection==


===Quarterly Inspection (IP Section 03.01)
===Quarterly Inspection (IP Section 03.01)===
(5 Sample s) The inspectors evaluated fire protection program implementation in the following selected areas:
{{IP sample|IP=IP 71111.05Q|count=5}}
 
The inspectors evaluated fire protection program implementation in the following selected areas:
: (1) Fuel pool heat exchanger area, 185 feet auxiliary building, on May 1, 2019;
: (1) Fuel pool heat exchanger area, 185 feet auxiliary building, on May 1, 2019;
: (2) Auxiliary building steam tunnel on May 15, 2019;
: (2) Auxiliary building steam tunnel on May 15, 2019;
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==71111.06 - Flood Protection Measures==
==71111.06 - Flood Protection Measures==


Inspection Activities  
===Inspection Activities - Internal Flooding (IP Section 02.02a.)===
- Internal Flooding (IP Section 02.02a.)===
{{IP sample|IP=IP 71111.06|count=1}}
{{IP sample|IP=IP 71111.05Q|count=1}}
 
The inspectors evaluated internal flooding mitigation protections in the:
The inspectors evaluated internal flooding mitigation protections in the:
: (1) Division 2 switchgear room on May 4, 2019.
: (1) Division 2 switchgear room on May 4, 2019.


71111.07T  
===71111.07T - Heat Sink Performance Triennial Review (IP Section 02.02) ===
- Heat Sink Performance Triennial Review (IP Section 02.02)
{{IP sample|IP=IP 71111.07|count=3}}
(3 Sample s) The inspectors evaluated heat exchanger/sink performance on the following:
The inspectors evaluated heat exchanger/sink performance on the following:
: (1) Division 2 emergency diesel generator jacket water cooler, Section 02.02b
: (1) Division 2 emergency diesel generator jacket water cooler, Section 02.02b;
;
: (2) Residual heat removal heat exchanger B, Section 02.02b;
: (2) Residual heat removal heat exchanger B, Section 02.02b
;
: (3) High pressure core spray room cooler, Section 02.02c.
: (3) High pressure core spray room cooler, Section 02.02c.


==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance==
==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance==


===Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
===Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)===
(2 Sample s)
{{IP sample|IP=IP 71111.11Q|count=2}}
: (1) The inspectors observed and evaluated licensed operator performance in the control room during a downpower due to a steamleak in the high pressure feedwater heater 6B room on April 3, 2019;
: (1) The inspectors observed and evaluated licensed operator performance in the control room during a downpower due to a steamleak in the high pressure feedwater heater 6B room on April 3, 2019;
: (2) The inspectors observed and evaluated licensed operator performance in the control room during control rod withdrawal to reactor criticality and point of adding heat on May 18, 2019. Licensed Operator Requalification Training/Examinations (IP Section 03.02)===
: (2) The inspectors observed and evaluated licensed operator performance in the control room during control rod withdrawal to reactor criticality and point of adding heat on May 18, 2019.
{{IP sample|IP=IP 71111.11Q|count=1}}
 
: (1) The inspectors observed and evaluated operator performance during a simulated suppression pool leak and loss of turbine building cooling water with an anticipated transient without scram on April 30, 2019.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)===
: (1) The inspectors observed and evaluated operator performance during a simulated
 
===suppression pool leak and loss of turbine building cooling water with an anticipated transient without scram on April 30, 2019.


==71111.12 - Maintenance Effectiveness==
==71111.12 - Maintenance Effectiveness==
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===Quality Control (IP Section 02.02)===
===Quality Control (IP Section 02.02)===
{{IP sample|IP=IP 71111.12|count=1}}
{{IP sample|IP=IP 71111.12|count=1}}
The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:
The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:
: (1) Standby service water system on April 12, 2019.
: (1) Standby service water system on April 12, 2019.
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==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
==71111.13 - Maintenance Risk Assessments and Emergent Work Control==


===Risk Assessment and Management Sample (IP Section 03.01)
===Risk Assessment and Management Sample (IP Section 03.01)===
(6 Sample s) The inspectors evaluated the risk assessments for the following planned and emergent work activities:
{{IP sample|IP=IP 71111.13|count=6}}
 
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
: (1) Loading of Trinuke filters into cask washdown pit on April 1, 2019;
: (1) Loading of Trinuke filters into cask washdown pit on April 1, 2019;
: (2) High pressure core spray availability during the pump high pressure bypass surveillance on May 6, 2019;
: (2) High pressure core spray availability during the pump high pressure bypass surveillance on May 6, 2019;
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: (4) Plant service water pump power line insulator installation on May 16, 2019;
: (4) Plant service water pump power line insulator installation on May 16, 2019;
: (5) Maintenance risk management during high grid demand conditions and Midcontinent Independent System Operator conservative operations declaration on June 4, 2019;
: (5) Maintenance risk management during high grid demand conditions and Midcontinent Independent System Operator conservative operations declaration on June 4, 2019;
: (6) Maintenance work control with plant service water pump D out of service on June 17, 2 019.
: (6) Maintenance work control with plant service water pump D out of service on June 17, 2019.


==71111.15 - Operability Determinations and Functionality Assessments==
==71111.15 - Operability Determinations and Functionality Assessments==


Operability Determination or Functionality Assessment (IP Section 02.02)
===Operability Determination or Functionality Assessment (IP Section 02.02)===
(4 Sample s) The inspectors evaluated the following operability determinations and functionality assessments:
{{IP sample|IP=IP 71111.15|count=4}}
 
The inspectors evaluated the following operability determinations and functionality assessments:
: (1) Operability of standby service water A with indications of pipe wall thinning, Condition Report CR-GGN-2019-02975 on April 11, 2019;
: (1) Operability of standby service water A with indications of pipe wall thinning, Condition Report CR-GGN-2019-02975 on April 11, 2019;
: (2) Operability of Division 1 emergency diesel generator due to loose lube oil heat exchanger bolts, Condition Reports CR
: (2) Operability of Division 1 emergency diesel generator due to loose lube oil heat exchanger bolts, Condition Reports CR-GGN-2019-03256 and CR-GGN-2019-03354 on April 26, 2019;
-GGN-2019-03256 and CR
-GGN-2019-03354 on April 26, 2019;
: (3) Operability of residual heat removal B due to minimum flow valve response time, Condition Report CR-GGN-2019-03679 on May 7, 2019;
: (3) Operability of residual heat removal B due to minimum flow valve response time, Condition Report CR-GGN-2019-03679 on May 7, 2019;
: (4) Equipment qualification of outbound main steam line B drain valve due to exposed cable, Condition Reports CR-GGN-2019-03972 on May 17, 2019.
: (4) Equipment qualification of outbound main steam line B drain valve due to exposed cable, Condition Reports CR-GGN-2019-03972 on May 17, 2019.
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==71111.18 - Plant Modifications==
==71111.18 - Plant Modifications==


Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)===
===Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)===
{{IP sample|IP=IP 71111.13|count=1}}
{{IP sample|IP=IP 71111.18|count=1}}
 
The inspectors evaluated the following temporary or permanent modifications:
The inspectors evaluated the following temporary or permanent modifications:
: (1) Fire rated assembly visual inspection Procedure 06
: (1) Fire rated assembly visual inspection Procedure 06-OP-SP64-R-0047 revisions on April 1, 2019.
-OP-SP64-R-0047 revisions on April 1, 2019.


==71111.19 - Post-Maintenance Testing==
==71111.19 - Post-Maintenance Testing==


===Post Maintenance Test Sample (IP Section 03.01)
===Post Maintenance Test Sample (IP Section 03.01)===
(8 Sample s) The inspectors evaluated the following post maintenance tests:
{{IP sample|IP=IP 71111.19|count=8}}
 
The inspectors evaluated the following post maintenance tests:
: (1) Work Order 514019 to replace water accumulator for HCU 48-25 on April 6, 2019;
: (1) Work Order 514019 to replace water accumulator for HCU 48-25 on April 6, 2019;
: (2) Work Order 523523 to replace standby service water sparger C piping support on April 24, 2019;
: (2) Work Order 523523 to replace standby service water sparger C piping support on April 24, 2019;
: (3) Troubleshooting replacement via CR
: (3) Troubleshooting replacement via CR-GGN-2019-03565, emergent replacement of Division 2 emergency diesel generator jacket water heater breaker on May 3, 2019;
-GGN-2019-03565, emergent replacement of Division 2 emergency diesel generator jacket water heater breaker on May 3, 2019;
: (4) Work Order 450109 to install insulators on the plant service water electrical distribution overhead power lines on May 17, 2019;
: (4) Work Order 450109 to install insulators on the plant service water electrical distribution overhead power lines on May 17, 2019;
: (5) Work Order 524662 to replace solenoid and shuttle valve on outboard main steam isolation valve A on May 16, 2019;
: (5) Work Order 524662 to replace solenoid and shuttle valve on outboard main steam isolation valve A on May 16, 2019;
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==71111.20 - Refueling and Other Outage Activities==
==71111.20 - Refueling and Other Outage Activities==


Refueling/Other Outage Sample (IP Section 03.01)===
===Refueling/Other Outage Sample (IP Section 03.01)===
{{IP sample|IP=IP 71111.19|count=1}}
{{IP sample|IP=IP 71111.20|count=1}}
: (1) The inspectors evaluated forced shutdown outage inspection activities on May 12, 2019.
: (1) The inspectors evaluated forced shutdown outage inspection activities on May 12, 2019.


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===The inspectors evaluated the following surveillance tests:
===The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
Surveillance Tests (other) (IP Section 03.01)===
(3 Sample s)
{{IP sample|IP=IP 71111.22|count=3}}
: (1) Work Order 52860862, high pressure core spray emergency diesel generator monthly functional test, on April 9, 2019;
: (1) Work Order 52860862, high pressure core spray emergency diesel generator monthly functional test, on April 9, 2019;
: (2) Work Order 52758695, Division 1 emergency diesel generator crankshaft deflection and thrust bearing test, on April 22, 2019;
: (2) Work Order 52758695, Division 1 emergency diesel generator crankshaft deflection and thrust bearing test, on April 22, 2019;
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==71114.01 - Exercise Evaluation==
==71114.01 - Exercise Evaluation==


Inspection Review (IP Section 02.01
===Inspection Review (IP Section 02.01-02.11)===
-02.11)===
{{IP sample|IP=IP 71114.01|count=1}}
{{IP sample|IP=IP 71111.22|count=1}}
 
The inspectors reviewed licensee drill and exercise performance between April 2017 and February 2019 and observed emergency response performance during the biennial emergency preparedness exercise conducted March 13, 2019. The inspectors also observed emergency response organization performance during a May 9, 2019, Operations Support Center drill, which was conducted because drill control issues prevented some key emergency response organization skills from being demonstrated during the March 2019 exercise. The inspectors participated in post
The inspectors reviewed licensee drill and exercise performance between April 2017 and February 2019 and observed emergency response performance during the biennial emergency preparedness exercise conducted March 13, 2019. The inspectors also observed emergency response organization performance during a May 9, 2019, Operations Support Center drill, which was conducted because drill control issues prevented some key emergency response organization skills from being demonstrated during the March 2019 exercise. The inspectors participated in post-exercise public meetings conducted by Federal Emergency Management Agency (FEMA) Region VI on March 14, 2019, in Tensas Parish, Louisiana, and by FEMA Region IV on March 15, 2019, in Claiborne County, Mississippi.
-exercise public meetings conducted by Federal Emergency Management Agency (FEMA) Region VI on March 14, 2019, in Tensas Parish, Louisiana, and by FEMA Region IV on March 15, 2019, in Claiborne County, Mississippi.
: (1) The March 13, 2019, exercise scenario simulated a tornado striking the plant switchyard, a failed emergency diesel generator, reactor coolant leakage into the drywell, and a unisolable steam leak on the reactor core isolation cooling system turbine.
: (1) The March 13, 2019, exercise scenario simulated a tornado striking the plant switchyard, a failed emergency diesel generator, reactor coolant leakage into the drywell, and a unisolable steam leak on the reactor core isolation cooling system turbine.


Line 239: Line 215:
===Radiological Work Planning (IP Section 02.01)===
===Radiological Work Planning (IP Section 02.01)===
{{IP sample|IP=IP 71124.02|count=1}}
{{IP sample|IP=IP 71124.02|count=1}}
The inspectors evaluated the licensee's radiological work planning.
 
: (1) The inspectors evaluated the licensee's radiological work planning by reviewing the following activities:
The inspectors evaluated the licensees radiological work planning.
RWP 2018-1400; RP/Decon Support for Refuel Floor
: (1) The inspectors evaluated the licensees radiological work planning by reviewing the following activities:
;  RWP 2018-1403: Rx Vessel Disassembly & Re
* RWP 2018-1400; RP/Decon Support for Refuel Floor;
-Assembly; RWP 2018-1511: General Maintenance in the Drywell RF21
* RWP 2018-1403: Rx Vessel Disassembly & Re-Assembly;
;  RWP 2018-1513: AOV/MOV Valve Work in the Drywell
* RWP 2018-1511: General Maintenance in the Drywell RF21;
;  RWP 2018-1902: Ops Rounds; Surveillances, Tagouts and Tours
* RWP 2018-1513: AOV/MOV Valve Work in the Drywell;
;  RWP 2018-1904: General Maintenance Activities & Support
* RWP 2018-1902: Ops Rounds; Surveillances, Tagouts and Tours;
;  RWP 2018-1908: AOV/MOV Program Valve Work, Votes, & Viper Test
* RWP 2018-1904: General Maintenance Activities & Support;
. Verification of Dose Estimates and Exposure Tracking Systems (IP Section 02.02)
* RWP 2018-1908: AOV/MOV Program Valve Work, Votes, & Viper Test.
(1 Sample) The inspectors evaluated dose estimates and exposure tracking.
 
: (1) The inspectors evaluated dose estimates and exposure tracking. The inspectors reviewed the following as low as reasonably achievable planning documents:
Verification of Dose Estimates and Exposure Tracking Systems (IP Section 02.02) (1 Sample)===
RWP 201 8-1400; RP/Decon Support for Refuel Floor
The inspectors evaluated dose estimates and exposure tracking.
;  RWP 2018-1403: Rx Vessel Disassembly & Re
 
-Assembly; RWP 2018-1511: General Maintenance in the Drywell RF21
===(1)     The inspectors evaluated dose estimates and exposure tracking. The inspectors reviewed the following as low as reasonably achievable planning documents:
;  RWP 2018-1513: AOV/MOV Valve Work in the Drywell
* RWP 2018-1400; RP/Decon Support for Refuel Floor;
;  RWP 2018-1902: Ops Rounds; Surveillances, Tagouts and Tours; RWP 2018-1904: General Maintenance Activities & Support
* RWP 2018-1403: Rx Vessel Disassembly & Re-Assembly;
;  RWP 2018-1908: AOV/MOV Program Valve Work, Votes, & Viper Test
* RWP 2018-1511: General Maintenance in the Drywell RF21;
. Additionally, the inspectors reviewed the following radiological outcome evaluations:
* RWP 2018-1513: AOV/MOV Valve Work in the Drywell;
RWP 2018-1400; RP/Decon Support for Refuel Floor
* RWP 2018-1902: Ops Rounds; Surveillances, Tagouts and Tours;
;  RWP 2018-1403: Rx Vessel Disassembly & Re
* RWP 2018-1904: General Maintenance Activities & Support;
-Assembly; RWP 2018-1511: General Maintenance in the Drywell RF21
* RWP 2018-1908: AOV/MOV Program Valve Work, Votes, & Viper Test.
;  RWP 2018-1513: AOV/MOV Valve Work in the Drywell
 
;  RWP 2018-1902: Ops Rounds; Surveillances, Tagouts and Tours
Additionally, the inspectors reviewed the following radiological outcome evaluations:
;  RWP 2018-1904: General Maintenance Activities & Support
* RWP 2018-1400; RP/Decon Support for Refuel Floor;
;  RWP 2018-1908: AOV/MOV Program Valve Work, Votes, & Viper Test
* RWP 2018-1403: Rx Vessel Disassembly & Re-Assembly;
.
* RWP 2018-1511: General Maintenance in the Drywell RF21;
* RWP 2018-1513: AOV/MOV Valve Work in the Drywell;
* RWP 2018-1902: Ops Rounds; Surveillances, Tagouts and Tours;
* RWP 2018-1904: General Maintenance Activities & Support;
* RWP 2018-1908: AOV/MOV Program Valve Work, Votes, & Viper Test.


==71124.04 - Occupational Dose Assessment==
==71124.04 - Occupational Dose Assessment==
Line 273: Line 253:
: (1) The inspectors evaluated the external dosimetry program implementation.
: (1) The inspectors evaluated the external dosimetry program implementation.


Internal Dosimetry (IP Section 02.03)
Internal Dosimetry (IP Section 02.03) (1 Sample)===
(1 Sample) The inspectors evaluated the internal dosimetry program implementation.
The inspectors evaluated the internal dosimetry program implementation.
: (1) The inspectors evaluated the internal dosimetry program implementation.


The inspectors reviewed the following:
===(1)  The inspectors evaluated the internal dosimetry program implementation. The inspectors reviewed the following:
Whole Body Counts (WBCs)
Whole Body Counts (WBCs)
WBC No. 33580         04/23/18 WBC No. 33201         04/06/19 WBC No. 33043         04/12/18 WBC No. 32447         05/04/18 In-Vitro Internal Monitoring In general, there were no in
* WBC No. 33580         04/23/18
-vitro internal monitoring at Grand Gulf Nuclear Station from 2018 to 2019. However, in May 2018, one personnel contamination event resulted in WBCs with an assigned internal dose, and a diver provided a urine sample for tritium analysis.
* WBC No. 33201         04/06/19
* WBC No. 33043         04/12/18
* WBC No. 32447         05/04/18 In-Vitro Internal Monitoring
* In general, there were no in-vitro internal monitoring at Grand Gulf Nuclear Station from 2018 to 2019. However, in May 2018, one personnel contamination event resulted in WBCs with an assigned internal dose, and a diver provided a urine sample for tritium analysis.


Dose Assessments Performed Using Air Sampling and Derived Air Concentration
Dose Assessments Performed Using Air Sampling and Derived Air Concentration-(DAC) Hour Monitoring
-(DAC) Hour Monitoring During 2018 and as of June 5, 2019, Grand Gulf Nuclear Station has not needed to perform dose assessments using air sampling and DAC
* During 2018 and as of June 5, 2019, Grand Gulf Nuclear Station has not needed to perform dose assessments using air sampling and DAC-hour monitoring.
-hour monitoring.


Source Term Categorization (IP Section 02.01)
Source Term Categorization (IP Section 02.01) (1 Sample)===
(1 Sample)
: (1) The inspectors evaluated the licensees characterization of the source term and use
: (1) The inspectors evaluated the licensee's characterization of the source term and use of scaling factors for the use of hard
-to-detect radionuclide activity.


Special Dosimetric Situations (IP Section 02.04)
===of scaling factors for the use of hard-to-detect radionuclide activity.
(1 Sample) The inspectors evaluated the following special dosimetric situation:
: (1) The inspectors evaluated special dosimetric situations.


The inspectors reviewed the following:
Special Dosimetric Situations (IP Section 02.04) (1 Sample)===
Declared Pregnant Workers There were two declared pregnant workers at Grand Gulf Nuclear Station in 2018 and four declared pregnant workers as of June 5, 2019. Effective Dose Equivalent Exposures (EDEX)
The inspectors evaluated the following special dosimetric situation:
EDEX multi
-package No. MP374  EDEX multi
-package No. MP367  EDEX multi
-package No. MP366 EDEX multi
-package No. MP457  EDEX multi
-package No. MP437  Shallow Dose Equivalent During 2018 and as of June 5, 2019, Grand Gulf Nuclear Station has not needed to have any shallow-dose equivalent assessments performed.


Neutron Dose Assessment At Grand Gulf Nuclear Station
===(1)  The inspectors evaluated special dosimetric situations. The inspectors reviewed the following:
, Landauer CR
Declared Pregnant Workers
-39 dosimetry is used that are sensitive to fast neutrons and thermal neutrons. However, from 2018 to June 5, 2019, there have been no documented neutron exposures on Grand Gulf Nuclear Station's doses of legal record (DLRs); the lower limit of detection (LLD) is 40 mR.
* There were two declared pregnant workers at Grand Gulf Nuclear Station in 2018 and four declared pregnant workers as of June 5, 2019.


==OTHER ACTIVITIES
Effective Dose Equivalent Exposures (EDEX)
- BASELINE==
* EDEX multi-package No. MP374
71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
* EDEX multi-package No. MP367
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)
* EDEX multi-package No. MP366
(1 Sample)
* EDEX multi-package No. MP457
: (1) January 1, 2018
* EDEX multi-package No. MP437 Shallow Dose Equivalent
- March 31, 2019 IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03)
* During 2018 and as of June 5, 2019, Grand Gulf Nuclear Station has not needed to have any shallow-dose equivalent assessments performed.
(1 Sample)
: (1) January 1, 2018  
- March 31, 2019 MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)
(1 Sample)
: (1) April 1, 2018
- March 31, 2019


==71152 - Problem Identification and Resolution==
Neutron Dose Assessment
* At Grand Gulf Nuclear Station, Landauer CR-39 dosimetry is used that are sensitive to fast neutrons and thermal neutrons. However, from 2018 to June 5, 2019, there have been no documented neutron exposures on Grand Gulf Nuclear Stations doses of legal record (DLRs); the lower limit of detection (LLD) is 40 mR.


===Annual Follow
==OTHER ACTIVITIES - BASELINE==
-up of Selected Issues (IP Section 02.03)
(2 Sample s) The inspectors reviewed the licensee's implementation of its corrective action program related to the following issues:
: (1) Condition Report CR-GGN-2004-00786, corrosion on emergency diesel generator jacket cooling service water piping, on April 1, 2019;
: (2) Condition Report CR
-GGN-2019-01504, automatic reactor scram due to generator lockout, on May 30, 2019;  Semiannual Trend Review (IP Section 02.02)===
{{IP sample|IP=IP 71152|count=1}}
: (1) The inspectors reviewed the licensee's corrective action program and maintenance program to identify trends that could be indicative of a more significant safety concern. The inspectors noted that for some work tasks, the work instructions contained in the work authorizing document (such as a work order) contained minimal instructions on how to accomplish the intended task. As a result, craft personnel had to either identify the relevant procedures to use or rely heavily on ski ll-of-the-craft. While no findings were identified, the inspectors were concerned that the lack of thorough work instructions could contribute to human performance errors. Examples of work orders that the inspectors had concerns with include Work Order 5 2754394 and 00522779 as well as Condition Reports CR
-GGN-2019-00202, 02092, 02399, 02639, and 04601. 71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow
-up (IP Section 03.01)
(1 Sample)
: (1) The inspectors evaluated the licensee's SCRAM response to a partial loss of plant service water on May 12, 2019.


Event Report (IP Section 03.02)
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
(1 Sample) The inspectors evaluated the following licensee event reports (LERs):
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) ===
: (1) LER 05000416/2019 00, Automatic Reactor Shutdown due to Activation of Generator Lockout, (ADAMS Accession No.
{{IP sample|IP=IP 71151|count=1}}
: (1) January 1, 2018 - March 31, 2019 IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)===
: (1) January 1, 2018 - March 31, 2019


ML19112A058).
===MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)===
: (1) April 1, 2018 - March 31, 2019


As documented in the inspection results section below, the inspectors identified a Green finding associated with this event for the licensee's failure to follow the station procedures for design control. No additional findings were identified as a result of reviewing this LER. The inspectors also concluded that no violation of NRC requirements occurred.
=====71152 - Problem Identification and Resolution==


==OTHER ACTIVITIES==
===Annual Follow-up of Selected Issues (IP Section 02.03)===
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 92723 - Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12
{{IP sample|IP=IP 71152|count=2}}
-Month Period
===
{{IP sample|IP=IP 71152|count=1}}
From December 9, 2016, through February 7, 2019, the NRC issued 10 Severity Level IV traditional enforcement violations associated with impeding the regulatory process.


These violations, which are listed below, were issued in the following NRC Inspection Reports:
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
05000416/2016007 (ADAMS Accession No.
: (1) Condition Report CR-GGN-2004-00786, corrosion on emergency diesel generator jacket cooling service water piping, on April 1, 2019;
: (2) Condition Report CR-GGN-2019-01504, automatic reactor scram due to generator lockout, on May 30, 2019; Semiannual Trend Review (IP Section 02.02) (1 Sample)===
: (1) The inspectors reviewed the licensees corrective action program and maintenance


ML16348A222), dated December 9, 2016  05000416/2017002 (ADAMS Accession No.
===program to identify trends that could be indicative of a more significant safety concern. The inspectors noted that for some work tasks, the work instructions contained in the work authorizing document (such as a work order) contained minimal instructions on how to accomplish the intended task. As a result, craft personnel had to either identify the relevant procedures to use or rely heavily on skill-of-the-craft.


ML17220A152), dated Augu st 3, 2017  05000416/2017007 (ADAMS Accession No.
While no findings were identified, the inspectors were concerned that the lack of thorough work instructions could contribute to human performance errors. Examples of work orders that the inspectors had concerns with include Work Order 52754394 and 00522779 as well as Condition Reports CR-GGN-2019-00202, 02092, 02399,


ML17339A154), dated December 1, 2017  05000416/2018004 (ADAMS Accession No.
===02639, and 04601.


ML19038A437), dated February 7,2019  Specifically, the violations included:
71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01) ===
: (1) Failure to Obtain NRC Approval for Changes to the Reactor Protection System, NRC-identified NCV 05000416/2016007
{{IP sample|IP=IP 02639|count=1}}
-02;
: (1) The inspectors evaluated the licensee's SCRAM response to a partial loss of plant service water on May 12, 2019.
: (2) Failure to Obtain NRC Approval for Changes to Diesel Generator Trips and Flood Mitigation Strategy
, NRC-identified NCV 05000416/2016007
-03;
: (3) Failure to Evaluate Delaying Inspection of Diesel Fuel Oil Storage Tank, NRC-identified NCV 05000416/2016007
-04;
: (4) Failure to submit an annual effluent report in accordance with 10 CFR 72.44(d)(3); licensee-identified NCV documented in Inspection Report 05000416/2017002
;
: (5) Failure to report the results of the visual inspections of all accessible, susceptible locations of the steam dryer to the NRC staff within 60 days following startup in accordance with License Condition 2.C(46)(f), licensee
-identified NCV documented in Inspection Report 05000416/2017002;
: (6) Failure to submit a long
-term steam dryer inspection plan based on industry operating experience along with the baseline inspection results for NRC review and approval in accordance with License Condition 2.C(46)(g), licensee
-identified NCV documented in Inspection Report 05000416/2017002;
: (7) Failure to notify the NRC within 4 hours of the occurrence of any event or condition that resulted in actuation of the reactor protection system when the reactor was critical in accordance with 10 CFR 50.72(b)(2)(iv)(B), licensee
-identified NCV documented in Inspection Report 05000416/2017002;
: (8) Failure to Update the Final Safety Analysis Report, NRC-identified NCV 05000416/2017007
-04;
: (9) Failure to make a timely event report for an event or condition that could have prevented fulfillment of a safety function (accident mitigation), licensee
-identified NCV documented in Inspection Report 05000416/2018001;
: (10) Failure to Update the Updated Final Safety Analysis Report, NRC
-identified NCV 05000416/2018004
-01. In April 2019 the inspectors performed Inspection Procedure 92723, "Follow
-up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period."


The inspectors reviewed the licensee's cause evaluations and corrective actions associated with these issues in order to determine whether the licensee's actions met the Inspection Procedure 92723 inspection objectives, which include:
Event Report (IP Section 03.02) (1 Sample)===
: (1) providing assurance that the cause(s) of multiple Severity Level IV traditional enforcement violations are understood by the licensee; (2)providing assurance that the extent of condition and extent of cause of multiple Severity Level IV traditional enforcement violations are identified; and (3)providing assurance that licensee corrective actions to traditional enforcement violations are sufficient to address the cause(s).
The inspectors evaluated the following licensee event reports (LERs):
: (1) LER 05000416/2019-001-00, Automatic Reactor Shutdown due to Activation of Generator Lockout, (ADAMS Accession No. ML19112A058). As documented in the inspection results section below, the inspectors identified a Green finding associated with this event for the licensees failure to follow the station procedures for design control. No additional findings were identified as a result of reviewing this LER. The inspectors also concluded that no violation of NRC requirements occurred.


==INSPECTION RESULTS==
==OTHER ACTIVITIES==
Observation
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
:  Follow-up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12
-Month Period 92723 Background The inspectors noted that from January 1 to December 31, 2013, the NRC issued three Severity Level IV traditional enforcement violations associated with impeding the regulatory process, as documented in Annual Assessment Letter 05000416/2013001 (ADAMS Accession No.


ML14063A338), dated March 4, 2014. Inspection Procedure 92723 was performed in response to four Severity Level IV traditional enforcement violations, as documented in Inspection Report 05000416/2014005 (ADAMS Accession No. ML15033A479), dated February 2, 2015. These violations involved accuracy and completeness of the Updated Final Safety Analysis Report, accuracy and completeness of information in the license renewal process, failure to report changes to the emergency plan, and failure to obtain a license amendment as required.
===92723 - Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period ===
{{IP sample|IP=IP 92723|count=1}}
From December 9, 2016, through February 7, 2019, the NRC issued 10 Severity Level IV traditional enforcement violations associated with impeding the regulatory process. These violations, which are listed below, were issued in the following NRC Inspection Reports:
* 05000416/2016007 (ADAMS Accession No. ML16348A222), dated December 9, 2016
* 05000416/2017002 (ADAMS Accession No. ML17220A152), dated August 3, 2017
* 05000416/2017007 (ADAMS Accession No. ML17339A154), dated December 1, 2017
* 05000416/2018004 (ADAMS Accession No. ML19038A437), dated February 7,2019 Specifically, the violations included:
: (1) Failure to Obtain NRC Approval for Changes to the Reactor Protection System, NRC-identified NCV 05000416/2016007-02;
: (2) Failure to Obtain NRC Approval for Changes to Diesel Generator Trips and Flood Mitigation Strategy, NRC-identified NCV 05000416/2016007-03;
: (3) Failure to Evaluate Delaying Inspection of Diesel Fuel Oil Storage Tank, NRC-identified NCV 05000416/2016007-04;
: (4) Failure to submit an annual effluent report in accordance with 10 CFR 72.44(d)(3);
licensee-identified NCV documented in Inspection Report 05000416/2017002;
: (5) Failure to report the results of the visual inspections of all accessible, susceptible locations of the steam dryer to the NRC staff within 60 days following startup in accordance with License Condition 2.C(46)(f), licensee-identified NCV documented in Inspection Report 05000416/2017002;
: (6) Failure to submit a long-term steam dryer inspection plan based on industry operating experience along with the baseline inspection results for NRC review and approval in accordance with License Condition 2.C(46)(g), licensee-identified NCV documented in Inspection Report 05000416/2017002;
: (7) Failure to notify the NRC within 4 hours of the occurrence of any event or condition that resulted in actuation of the reactor protection system when the reactor was critical in accordance with 10 CFR 50.72(b)(2)(iv)(B), licensee-identified NCV documented in Inspection Report 05000416/2017002;
: (8) Failure to Update the Final Safety Analysis Report, NRC-identified NCV 05000416/2017007-04;
: (9) Failure to make a timely event report for an event or condition that could have prevented fulfillment of a safety function (accident mitigation), licensee-identified NCV documented in Inspection Report 05000416/2018001;
: (10) Failure to Update the Updated Final Safety Analysis Report, NRC-identified NCV 05000416/2018004-01.


The inspectors also noted that from January 1 to December 31, 2015, the NRC issued seven Severity Level IV traditional enforcement violations associated with impeding the regulatory process, as documented in Annual Assessment Letter 05000416/2015006 (ADAMS Accession No.
In April 2019 the inspectors performed Inspection Procedure 92723, Follow-up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period. The inspectors reviewed the licensees cause evaluations and corrective actions associated with these issues in order to determine whether the licensees actions met the Inspection Procedure 92723 inspection objectives, which include:
: (1) providing assurance that the cause(s) of multiple Severity Level IV traditional enforcement violations are understood by the licensee;
: (2) providing assurance that the extent of condition and extent of cause of multiple Severity Level IV traditional enforcement violations are identified; and
: (3) providing assurance that licensee corrective actions to traditional enforcement violations are sufficient to address the cause(s).


ML16061A361), dated March 2, 2016. Inspection Procedure 92723 was again performed in response to these Severity level IV traditional enforcement violations, as documented in NRC Inspection Report 05000416/2016003 (ADAMS Accession No. ML16315A372), dated November 10, 2016. These violations involved two failures to update the Final Safety Analysis Report; a failure to maintain a safety
==INSPECTION RESULTS==
-related cable tray overfill analysis record; an incomplete and inaccurate response to NRC Bulletin 88-04; a failure to obtain a license amendment; and two failures to make required event notifications or reports. Considering these facts, the inspectors sought to understand why failures to update the Final Safety Analysis Report, failures to make required reports, and failures to obtain license amendments were issues that have continued to be identified and documented as recently as 2019. Licensee Evaluation The inspectors reviewed the licensee's collective evaluations (completed at the "Condition Analysis" level) associated with the 10 CFR 50.59 issues and reporting issues, which included 10 CFR 50.71(e) and reporting issues. The inspectors also reviewed individual/combined evaluations associated with each of the 10 non
Observation: Follow-up Inspection for Three or More Severity Level IV                    92723 Traditional Enforcement Violations in the Same Area in a 12-Month Period Background The inspectors noted that from January 1 to December 31, 2013, the NRC issued three Severity Level IV traditional enforcement violations associated with impeding the regulatory process, as documented in Annual Assessment Letter 05000416/2013001 (ADAMS Accession No. ML14063A338), dated March 4, 2014. Inspection Procedure 92723 was performed in response to four Severity Level IV traditional enforcement violations, as documented in Inspection Report 05000416/2014005 (ADAMS Accession No. ML15033A479), dated February 2, 2015. These violations involved accuracy and completeness of the Updated Final Safety Analysis Report, accuracy and completeness of information in the license renewal process, failure to report changes to the emergency plan, and failure to obtain a license amendment as required.
-cited violations. The inspectors were not able to review in detail the latest revisions of the collective evaluation associated with Condition Report CR
-GGN-2019-01002 (associated with 50.59 issues) and the adverse condition analysis associated with Condition Report CR-GGN-2018-01595 (associated with a late 8-hour notification) because preliminary versions of the evaluations were provided during the inspection. Evaluations reviewed included:
CR-GGN-2019-01002, "50.59 Evaluations not Conducted as Required," which evaluated the causes of 10 CFR 50.59 related violations (three issues with four total examples).


CR-GGN-2017-01483 had previously been completed to address this group of issues. The individual issues included within this collective evaluation were evaluated by the following cause evaluations:
The inspectors also noted that from January 1 to December 31, 2015, the NRC issued seven Severity Level IV traditional enforcement violations associated with impeding the regulatory process, as documented in Annual Assessment Letter 05000416/2015006 (ADAMS Accession No. ML16061A361), dated March 2, 2016. Inspection Procedure 92723 was again performed in response to these Severity level IV traditional enforcement violations, as documented in NRC Inspection Report 05000416/2016003 (ADAMS Accession No. ML16315A372), dated November 10, 2016. These violations involved two failures to update the Final Safety Analysis Report; a failure to maintain a safety-related cable tray overfill analysis record; an incomplete and inaccurate response to NRC Bulletin 88-04; a failure to obtain a license amendment; and two failures to make required event notifications or reports.
1. CR-GGN-2019-01007, dated March 14, 2019, which revised the licensee's evaluations associated with CR
-GGN-2016-09757 (two revisions); these cause evaluations were associated with violation (3), as listed above
. 2. CR-GGN-2019-01185, dated March 20, 2019, which revised the licensee's evaluations associated with CR
-GGN-2016-08298 (two revisions); these cause evaluations were associated with violations
: (1) and (2), as listed above
.


CR-GGN-2019-01003, "Failure to Submit Reports to the NRC," which evaluated the causes of failures to make reports to the NRC (five issues/examples) and failures to update the Final Safety Analysis Report (two issues with four total examples).
Considering these facts, the inspectors sought to understand why failures to update the Final Safety Analysis Report, failures to make required reports, and failures to obtain license amendments were issues that have continued to be identified and documented as recently as 2019.


CR-GGN-2017-07970 had previously been completed to address this group of issues. The individual issues included within this collective evaluation were evaluated by the following cause evaluations:
Licensee Evaluation The inspectors reviewed the licensees collective evaluations (completed at the Condition Analysis level) associated with the 10 CFR 50.59 issues and reporting issues, which included 10 CFR 50.71(e) and reporting issues. The inspectors also reviewed individual/combined evaluations associated with each of the 10 non-cited violations. The inspectors were not able to review in detail the latest revisions of the collective evaluation associated with Condition Report CR-GGN-2019-01002 (associated with 50.59 issues) and the adverse condition analysis associated with Condition Report CR-GGN-2018-01595 (associated with a late 8-hour notification) because preliminary versions of the evaluations were provided during the inspection. Evaluations reviewed included:
1. CR-GGN-2017-03404, dated May 22, 2017, and later revised on March 1, 2019; this cause evaluation was associated with violations
* CR-GGN-2019-01002, 50.59 Evaluations not Conducted as Required, which evaluated the causes of 10 CFR 50.59 related violations (three issues with four total examples). CR-GGN-2017-01483 had previously been completed to address this group of issues. The individual issues included within this collective evaluation were evaluated by the following cause evaluations:
: (5) and (6), as listed above 2. CR-GGN-2017-12284, dated February 20, 2018, and later revised on March 1, 2019; this cause evaluation was associated with violation (8), as listed above 3. CR-GGN-2018-01595, dated March 27, 2018, and later revised March 1, 2019; this cause evaluation was associated with violation (9), as listed above 4. CR-GGN-2019-01047, dated March 22, 2019; this cause evaluation was associated with violation (10), as listed above 5. CR-GGN-2019-01390, dated March 1, 2019, which elevated the level of evaluation of CR
1. CR-GGN-2019-01007, dated March 14, 2019, which revised the licensees evaluations associated with CR-GGN-2016-09757 (two revisions); these cause evaluations were associated with violation (3), as listed above.
-GGN-2017-0 3092, which was documented on March 27, 2017, at the "C" significance level; these were associated with violation (4), as listed above 6. CR-GGN-2019-01391, dated March 14, 2019, which elevated the level of evaluation of CR
-GGN-2017-0 3331, which was documented on April 4, 2017, at the "C" significance level; these were associated with violation (7), as listed above  Assessment Considering all the cause evaluations and relevant condition reports the inspectors identified 16 examples where the responsible manager failed to ensure all available and relevant information was acquired by reviews of pertinent industry events in accordance with step 4[2]e of Procedure EN
-LI-118, "Cause Evaluation Process," Revision 23. The licensee documented Condition Reports CR
-GGN-2019-02684, CR-GGN-201 9-02716, CR-GGN-2019-02733 to address these concerns. These examples included:
Failure to review all relevant condition reports (such as CR-GGN-2015-05057) in the relevant internal operating experience section of the adverse condition analyses associated with CR-GGN-2019-01002 and CR
-GGN-2019-0 1003  Failure to review 17 relevant condition reports in the relevant internal operating experience section of the adverse condition analysis associated with CR-GGN-2017-12284  Failure to include relevant internal operating experience detailed review attachments with the adverse condition analyses associated with CR
-GGN-2017-12284, CR-GGN-2017-03404, CR-GGN-20 19-01391, and CR
-GGN-2018-01595 Failure to perform internal operating experience repeat event reviews with the adverse condition analyses associated with CR
-GGN-2018-01390, CR-GGN-2019-01047, and CR-GGN-2019-01391  Failure to perform an adequate review of external operating experience with the adverse condition analyses associated with CR
-GGN-2017-03404 and CR-GGN-2018-0 1390  Failure to include relevant external operating experience detailed review attachments with the adverse condition analyses associated with CR
-GGN-2017-12284, CR-GGN-2017-03404, CR-GGN-2019-01391, and CR
-GGN-2018-01595  The inspectors also identified other issues during the review:
The inspectors identified that Attachment 9.2, "UFSAR Change Process Flow Chart,"
of Procedure EN-LI-113-01, "Updated Final Safety Analysis Report Change Process," Revision 3, included numerous incorrect procedure step references. The licensee documented CR
-GGN-2019-02674 to address the concern.


The inspectors identified that a corrective action was not implemented to address a missed barrier identified as a factor in adverse condition analysis CR-GGN-2018-01595. This was associated with providing a procedure barrier to operators and licensing personnel when completing reportability evaluations. The licensee initiated CR
2. CR-GGN-2019-01185, dated March 20, 2019, which revised the licensees evaluations associated with CR-GGN-2016-08298 (two revisions); these cause evaluations were associated with violations
-GGN-2019-02690 to address this observation.
: (1) and (2), as listed above.
* CR-GGN-2019-01003, Failure to Submit Reports to the NRC, which evaluated the causes of failures to make reports to the NRC (five issues/examples) and failures to update the Final Safety Analysis Report (two issues with four total examples).


The licensee initiated CR
CR-GGN-2017-07970 had previously been completed to address this group of issues.
-GGN-2019-02732 in response to the inspectors' questions on licensing basis document change request (LBDCR)/Updated Final Safety Analysis Report tracking not being defined.


Conclusions The inspectors could not conclude that the inspection objectives were met because substantially relevant operating experience was not adequately considered and evaluated by the licensee when determining causes, extent of conditions, extent of causes, or corrective actions. Specifically, the inspectors identified that the conditions, scope, and causes associated with the two main collective evaluations and the previously performed root cause CR-GGN-2015-05057, which was associated with previous examples of incorrect maintenance of design and license basis documents, revealed substantive commonalities involving implementation and control of design change and license basis document changes; however, the CR
The individual issues included within this collective evaluation were evaluated by the following cause evaluations:
-GGN-2015-05057 root cause analysis was not appropriately evaluated as relevant operating experience in the current evaluations. Corrective actions to prevent recurrence of root causes would be expected to prevent recurrence of the same performance deficiency.
1. CR-GGN-2017-03404, dated May 22, 2017, and later revised on March 1, 2019; this cause evaluation was associated with violations (5)and (6), as listed above 2. CR-GGN-2017-12284, dated February 20, 2018, and later revised on March 1, 2019; this cause evaluation was associated with violation (8), as listed above 3. CR-GGN-2018-01595, dated March 27, 2018, and later revised March 1, 2019; this cause evaluation was associated with violation (9), as listed above 4. CR-GGN-2019-01047, dated March 22, 2019; this cause evaluation was associated with violation (10), as listed above 5. CR-GGN-2019-01390, dated March 1, 2019, which elevated the level of evaluation of CR-GGN-2017-03092, which was documented on March 27, 2017, at the C significance level; these were associated with violation (4), as listed above 6. CR-GGN-2019-01391, dated March 14, 2019, which elevated the level of evaluation of CR-GGN-2017-03331, which was documented on April 4, 2017, at the C significance level; these were associated with violation (7), as listed above Assessment Considering all the cause evaluations and relevant condition reports the inspectors identified 16 examples where the responsible manager failed to ensure all available and relevant information was acquired by reviews of pertinent industry events in accordance with step 4[2]e of Procedure EN-LI-118, Cause Evaluation Process, Revision 23. The licensee documented Condition Reports CR-GGN-2019-02684, CR-GGN-2019-02716, CR-GGN-2019-02733 to address these concerns. These examples included:
* Failure to review all relevant condition reports (such as CR-GGN-2015-05057) in the relevant internal operating experience section of the adverse condition analyses associated with CR-GGN-2019-01002 and CR-GGN-2019-01003
* Failure to review 17 relevant condition reports in the relevant internal operating experience section of the adverse condition analysis associated with CR-GGN-2017-12284
* Failure to include relevant internal operating experience detailed review attachments with the adverse condition analyses associated with CR-GGN-2017-12284, CR-GGN-2017-03404, CR-GGN-2019-01391, and CR-GGN-2018-01595
* Failure to perform internal operating experience repeat event reviews with the adverse condition analyses associated with CR-GGN-2018-01390, CR-GGN-2019-01047, and CR-GGN-2019-01391
* Failure to perform an adequate review of external operating experience with the adverse condition analyses associated with CR-GGN-2017-03404 and CR-GGN-2018-01390
* Failure to include relevant external operating experience detailed review attachments with the adverse condition analyses associated with CR-GGN-2017-12284, CR-GGN-2017-03404, CR-GGN-2019-01391, and CR-GGN-2018-01595 The inspectors also identified other issues during the review:
* The inspectors identified that Attachment 9.2, UFSAR Change Process Flow Chart, of Procedure EN-LI-113-01, Updated Final Safety Analysis Report Change Process, Revision 3, included numerous incorrect procedure step references. The licensee documented CR-GGN-2019-02674 to address the concern.
* The inspectors identified that a corrective action was not implemented to address a missed barrier identified as a factor in adverse condition analysis CR-GGN-2018-01595. This was associated with providing a procedure barrier to operators and licensing personnel when completing reportability evaluations. The licensee initiated CR-GGN-2019-02690 to address this observation.
* The licensee initiated CR-GGN-2019-02732 in response to the inspectors' questions on licensing basis document change request (LBDCR)/Updated Final Safety Analysis Report tracking not being defined.
 
Conclusions The inspectors could not conclude that the inspection objectives were met because substantially relevant operating experience was not adequately considered and evaluated by the licensee when determining causes, extent of conditions, extent of causes, or corrective actions. Specifically, the inspectors identified that the conditions, scope, and causes associated with the two main collective evaluations and the previously performed root cause CR-GGN-2015-05057, which was associated with previous examples of incorrect maintenance of design and license basis documents, revealed substantive commonalities involving implementation and control of design change and license basis document changes; however, the CR-GGN-2015-05057 root cause analysis was not appropriately evaluated as relevant operating experience in the current evaluations. Corrective actions to prevent recurrence of root causes would be expected to prevent recurrence of the same performance deficiency.


Additionally, the licensee continues to identify LBDCR performance issues. Specifically, engineering changes with LBDCRs are still being evaluated to ensure all LBDCRs from 2000-2013 are appropriately tracked and coordinated. Also, a trend of incorrectly implemented LBDCRs during a software conversion is still being evaluated to determine causes and to ensure that conversion issues have been identified.
Additionally, the licensee continues to identify LBDCR performance issues. Specifically, engineering changes with LBDCRs are still being evaluated to ensure all LBDCRs from 2000-2013 are appropriately tracked and coordinated. Also, a trend of incorrectly implemented LBDCRs during a software conversion is still being evaluated to determine causes and to ensure that conversion issues have been identified.


Finally, the inspectors could not conclude that the inspection objectives were met because the collective evaluations and additional causal analyses were being revised as of th e completion of the inspection. As a result of this inspection, the licensee voluntarily determined that the conclusions of its collective evaluations needed to be reconsidered. The licensee planned to re
Finally, the inspectors could not conclude that the inspection objectives were met because the collective evaluations and additional causal analyses were being revised as of the completion of the inspection. As a result of this inspection, the licensee voluntarily determined that the conclusions of its collective evaluations needed to be reconsidered. The licensee planned to re-evaluate and revise its collective evaluations (CR-GGN-2019-01002 and CR-GGN-2019-01003) associated with the 10 violations and review the previous CR-GGN-2015-05057 root cause analysis to ensure that the causes, extent of conditions, extent of causes, and corrective actions were adequate. The licensee initiated CR-GGN-2019-02717 to document that adverse condition analyses associated with CR-GGN-2019-01002 and CR-GGN-2019-01003 did not adequately evaluate issues with configuration control of design and licensing basis documentation. The licensee informed the inspectors that a cause evaluation will be completed to address this concern.
-evaluate and revise its collective evaluations (CR-GGN-2019-01002 and CR-GGN-2019-01003) associated with the 10 violations and review the previous CR-GGN-2015-05057 root cause analysis to ensure that the causes, extent of conditions, extent of causes, and corrective actions were adequate. The licensee initiated CR-GGN-2019-02717 to document that adverse cond ition analyses associated with CR-GGN-2019-01002 and CR
-GGN-2019-01003 did not adequately evaluate issues with configuration control of design and licensing basis documentation. The licensee informed the inspectors that a cause evaluation will be completed to address this concern.


Failure to Update the UFSAR Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000416/2019002
Failure to Update the UFSAR Cornerstone       Severity                                         Cross-Cutting   Report Aspect           Section Not               Severity Level IV                                 Not              71111.05Q Applicable        NCV 05000416/2019002-01                           Applicable Closed The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.71(e) for the licensee's failure to update the Updated Final Safety Analysis Report, Section 9A.5.
-01 Closed Not Applicable 71111.05Q The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.71(e) for the licensee's failure to update the Updated Final Safety Analysis Report, Section 9A.5. The inspectors identified over 20 discrepancies between the fire zone description in the Updated Final Safety Analysis Report and the licensee's implementing documents, including Procedure 06
 
-OP-SP64-R-0047, "Fire Rated Assembly Visual Inspection," Revision 116. The licensee periodically updated fire protection implementing procedures but did not update the Updated Final Safety Analysis Report, when needed, to reflect those changes.
The inspectors identified over 20 discrepancies between the fire zone description in the Updated Final Safety Analysis Report and the licensee's implementing documents, including Procedure 06-OP-SP64-R-0047, Fire Rated Assembly Visual Inspection, Revision 116. The licensee periodically updated fire protection implementing procedures but did not update the Updated Final Safety Analysis Report, when needed, to reflect those changes.


=====Description:=====
=====Description:=====
While reviewing the fire rated assembly visual inspection criteria contained in Procedure 06
While reviewing the fire rated assembly visual inspection criteria contained in Procedure 06-OP-SP64-R-0047, the inspectors identified discrepancies between the procedure and the Updated Final Safety Analysis Report (UFSAR), Section 9A.5.
-OP-SP64-R-0047, the inspectors identified discrepancies between the procedure and the Updated Final Safety Analysis Report (UFSAR), Section 9A.5. Specifically, the inspectors compared the fire barrier descriptions of 125 out of 266 fire zones described in UFSAR, Section 9A.5, with the surveillance requirements contained in Procedure 06
 
-OP-SP64-R-0047. From this review, the inspectors identified discrepancies with 24 fire zones. The inspectors found that in some instances, the procedure classified various barriers as 3
Specifically, the inspectors compared the fire barrier descriptions of 125 out of 266 fire zones described in UFSAR, Section 9A.5, with the surveillance requirements contained in Procedure 06-OP-SP64-R-0047. From this review, the inspectors identified discrepancies with 24 fire zones. The inspectors found that in some instances, the procedure classified various barriers as 3-hour fire barriers required by the technical requirements manual, while the UFSAR described them as non-rated barriers.
-hour fire barriers required by the technical requirements manual, while the UFSAR described them as non
-rated barriers.


For example, Procedure 06
For example, Procedure 06-OP-SP64-R-0047 described the ceiling as a fire-rated barrier for Fire Zones 1A115 and 1A116 that was required to remain functional per the technical requirements manual. Fire Zones 1A115 and 1A116 both included the ceiling as a required barrier in the procedure because the ceiling interfaces with a fire zone in a different fire area; however, the UFSAR descriptions for Fire Zones 1A115 and 1A116 both stated that the ceiling is a non-rated barrier in those fire zones. Likewise, the west walls for Fire Zones 1A130 and 1A131 separated these zones from a different fire area and were described as required fire barriers in Procedure 06-OP-SP64-R-0047; however, the UFSAR stated that these walls were not rated barriers.
-OP-SP64-R-0047 described the ceiling as a fire
-rated barrier for Fire Zones 1A115 and 1A116 that was required to remain functional per the technical requirements manual. Fire Zone s 1A115 and 1A116 both included the ceiling as a required barrier in the procedure because the ceiling interfaces with a fire zone in a different fire area; however, the UFSAR descriptions for Fire Zones 1A115 and 1A116 both stated that the ceiling is a no n-rated barrier in those fire zones.


Likewise, the west walls for Fire Zones 1A130 and 1A131 separated these zones from a different fire area and were described as required fire barriers in Procedure 06
While reviewing the revision history of this procedure, the inspectors learned that the licensee had previously identified numerous discrepancies with this procedure and documented the issues in Condition Report CR-GGN-2000-00585 on April 28, 2000. Corrective actions included revising the procedure to reflect the fire barriers required to remain operable per Technical Requirements Manual 6.2.8, but the licensee did not ensure that the UFSAR was revised to remain consistent with the procedure.
-OP-SP64-R-0047; however, the UFSAR stated that these walls were not rated barriers.


While reviewing the revision history of this procedure, the inspectors learned that the licensee had previously identified numerous discrepancies with this procedure and documented the issues in Condition Report CR-GG N-2000-00585 on April 28, 2000. Corrective actions included revising the procedure to reflect the fire barriers required to remain operable per Technical Requirements Manual 6.2.8, but the licensee did not ensure that the UFSAR was revised to remain consistent with the procedure.
Corrective Actions: The licensee performed an apparent cause analysis and initiated a review to identify all discrepancies between the UFSAR and Procedure 06-OP-SP64-R-0047.


Corrective Actions:  The licensee performed an apparent cause analysis and initiated a review to identify all discrepancies between the UFSAR and Procedure 06
Corrective actions planned included evaluating all the identified discrepancies and revising the procedure and/or the UFSAR as warranted by the nature of each discrepancy.
-OP-SP64-R-0047. Corrective actions planned included evaluating all the identified discrepancies and revising the procedure and/or the UFSAR as warranted by the nature of each discrepancy.


Corrective Action References: The licensee entered the issue into their corrective action program as Condition Report CR
Corrective Action References: The licensee entered the issue into their corrective action program as Condition Report CR-GGN-2019-02719, 2019-02427, and 2019-02471
-GGN-2019-02719, 2019-02427, and 2019
-02471


=====Performance Assessment:=====
=====Performance Assessment:=====
The inspectors determined this violation was associated with a minor performance deficiency.
The inspectors determined this violation was associated with a minor performance deficiency.


Enforcement
=====Enforcement:=====
:  The ROP's significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance.
The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter noncompliance.
 
Severity: This violation was determined to be Severity Level IV in accordance with the NRC Enforcement Policy, Example 6.1.d.3. The inspectors determined that there was a material impact on safety or licensed activities because if utilized, lack of up-to-date information in the UFSAR could have a nonconservative impact on design analyses.


Therefore, it is necessary to address this violation which impedes the NRC's ability to regulate using traditional enforcement to adequately deter noncompliance.
Violation: As required by 10 CFR 50.71, Maintenance of Records, Making of Reports, Section (e), 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. Contrary to the above, since April 28, 2000, the licensee did not update the Final Safety Analysis Report to assure that the information included in the report contains the latest information developed.


Severity:  This violation was determined to be Severity Level IV in accordance with the NRC Enforcement Policy, Example 6.1.d.3. The inspectors determined that there was a material impact on safety or licensed activities because if utilized, lack of up
Specifically, the licensee failed to update the Final Safety Analysis Report with the most up-to-date fire barrier descriptions both during and after the resolution of Condition Report CR-GGN-2000-00585.
-to-date information in the UFSAR could have a nonconservative impact on design analyses.


Violation:  As required by 10 CFR 50.71, "Maintenance of Records, Making of Reports," Section (e), "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."  Contrary to the above, since April 28, 2000, the licensee did not update the Final Safety Analysis Report to assure that the information included in the report contains the latest information developed. Specifically, the licensee failed to update the Final Safety Analysis Report with the most up
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
-to-date fire barrier descriptions both during and after the resolution of Condition Repor t CR-GGN-2000-00585. Enforcement Action
: This violation is being treated as a non
-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.


Failure to Follow Design Control Procedure Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000416/2019002
Failure to Follow Design Control Procedure Cornerstone           Significance                             Cross-Cutting       Report Aspect             Section Initiating Events     Green                                     [H.6] - Design     71152 FIN 05000416/2019002-02                  Margins Closed A self-revealed, Green finding was identified when an actuation of the generator protection negative phase sequence trip caused a generator lockout and a reactor scram. The licensee failed to ensure that a recent change in the applicable trip setpoint was managed in accordance with Procedure EN-DC-115, Engineering Change Process, Revision 21. The licensee failed to identify, evaluate, and manage a reduction in operating margin associated with the negative phase sequence trip setpoint. The setpoint was reduced from 9 percent to 5 percent as part of a digital upgrade modification; however, the licensee failed to fully evaluate the change. As a result, routine grid operations above 5 percent negative phase sequence were unmanaged and ultimately led to an unplanned reactor scram.
-02  Closed [H.6] - Design Margins 71152 A self-revealed, Green finding was identified when an actuation of the generator protection negative phase sequence trip caused a generator lockout and a reactor scram. The licensee failed to ensure that a recent change in the applicable trip setpoint was managed in accordance with Procedure EN-DC-115, "Engineering Change Process," Revision 21. The licensee failed to identify, evaluate, and manage a reduction in operating margin associated with the negative phase sequence trip setpoint. The setpoint was reduced from 9 percent to 5 percent as part of a digital upgrade modification; however, the licensee failed to fully evaluate the change. As a result, routine grid operations above 5 percent negative phase sequence were unmanaged and ultimately led to an unplanned reactor scram.


=====Description:=====
=====Description:=====
On February 23, 2019, an automatic reactor scram occurred as a result of a turbine trip. The licensee determined that a generator lockout caused the turbine trip and that the generator lockout was caused when the generator negative phase sequence protection portion of the generator protective relays 1N41M711A/B and 1N41M712A/B actuated. The relays actuated when the generator phase unbalance exceeded the trip setpoint of 5 percent. The licensee entered the issue in their corrective action program as Condition Report CR-GGN-2019-01504. In February 1981, the generator negative phase sequence setpoint was determined to be 9 percent as documented in Calculation PR0204, Revision 0. Although the calculation determined that a setpoint of 5 percent was acceptable, physical device limitations precluded the setpoint to be set any lower than 9 percent. This setpoint was revisited on May 5, 2012, when Revision 2 to Calculation PR0204 was issued as part of Engineering Change (EC) 20838. As part of this calculation, the trip threshold was retained at 9 percent based on industry guidance and previous settings. In May 2016, the licensee initiated a project to upgrade the analog generator protective relaying scheme to digital. The licensee hired a contractor to perform the engineering change as documented in EC 67304 using the licensee's change control program and procedures.
On February 23, 2019, an automatic reactor scram occurred as a result of a turbine trip. The licensee determined that a generator lockout caused the turbine trip and that the generator lockout was caused when the generator negative phase sequence protection portion of the generator protective relays 1N41M711A/B and 1N41M712A/B actuated. The relays actuated when the generator phase unbalance exceeded the trip setpoint of 5 percent.


As a part of this modification, Calculation EC
The licensee entered the issue in their corrective action program as Condition Report CR-GGN-2019-01504.
-N1N41-17001 determined that the negative phase sequence trip setpoint should be changed to 5 percent; however, there was no discussion or evaluation on the effects that reducing the setpoint from 9 percent to 5 percent would have on operating margin. Had the licensee thoroughly reviewed the setpoint change, operating experience available at the time would have identified that the local electrical grid is routinely operated at greater than 5 percent unbalance. Such a review would have prompted a more thorough evaluation of the impacts of lowering the setpoint to a value that could routinely be exceeded during normal power operations.


At the time EC 67304 was issued, licensee Procedure EN-DC-115, "Engineering Change Process," Revision 21, required that the responsible engineer describe the impact on plant operating margins. One of the impact screening criteria in Attachment 9.4 of Procedure EN-DC-115 included, "Change protective relay settings, generator exciter or Automatic Voltage Regulator (AVR) settings
In February 1981, the generator negative phase sequence setpoint was determined to be 9 percent as documented in Calculation PR0204, Revision 0. Although the calculation determined that a setpoint of 5 percent was acceptable, physical device limitations precluded the setpoint to be set any lower than 9 percent. This setpoint was revisited on May 5, 2012, when Revision 2 to Calculation PR0204 was issued as part of Engineering Change (EC) 20838. As part of this calculation, the trip threshold was retained at 9 percent based on industry guidance and previous settings.
."  Although this box was checked in conjunction with the licensee's implementation of EC 67304, the inspectors could find neither an evaluation for the effects of changing this setpoint nor an evaluation for the effects o f a reduced operating margin as a result of the setpoint reduction.


The licensee performed a root cause evaluation and concluded that the root cause was that engineering leadership did not ensure standards and expectations for adherence to a systematic and rigorous configuration change process were met to maintain operating margins and achieve an acceptable result to prevent an unplanned scram.
In May 2016, the licensee initiated a project to upgrade the analog generator protective relaying scheme to digital. The licensee hired a contractor to perform the engineering change as documented in EC 67304 using the licensees change control program and procedures.


Contributing causes were determined to be the failure of electrical design engineers to follow the configuration control process as described in Procedure EN
As a part of this modification, Calculation EC-N1N41-17001 determined that the negative phase sequence trip setpoint should be changed to 5 percent; however, there was no discussion or evaluation on the effects that reducing the setpoint from 9 percent to 5 percent would have on operating margin. Had the licensee thoroughly reviewed the setpoint change, operating experience available at the time would have identified that the local electrical grid is routinely operated at greater than 5 percent unbalance. Such a review would have prompted a more thorough evaluation of the impacts of lowering the setpoint to a value that could routinely be exceeded during normal power operations.
-DC-115. The licensee determined, based on previous operating experience and equipment limitations, that a setpoint of 9 percent was acceptable to provide an adequate level of protection to the generator equipment while still maintaining an acceptable operational margin to prevent spurious trips on generator negative phase sequence from normal grid operating conditions. As a result, the licensee issued EC 81801 to change the trip setpoint back to 9 percent, which was completed under Work Order 00519151 on February 27, 2019. Corrective Action s:  Licensee corrective actions included performing a root cause evaluation, which resulted in procedure changes and training of applicable engineering staff. The negative phase setpoint was changed back to 9 percent. Corrective Action Reference s:  The licensee entered the issue into their corrective action program as Condition Report CR
-GGN-2019-01504. Performance Assessment
:  Performance Deficiency:  The licensee's failure to follow the configuration control process as described in licensee Procedure EN
-DC-115 is a performance deficiency. Because the licensee did not effectively evaluate the impact of reducing generator protective relay setpoints, operating margins were not managed as required by Procedure EN
-DC-115. Screening:  The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Initiating Events cornerstone. Specifically, the performance deficiency contributed to an unplanned automatic reactor scram.


Significance:  The inspectors assessed the significance of the finding using Appendix A, "The Significance Determination Process (SDP) for Findings At
At the time EC 67304 was issued, licensee Procedure EN-DC-115, "Engineering Change Process," Revision 21, required that the responsible engineer describe the impact on plant operating margins. One of the impact screening criteria in Attachment 9.4 of Procedure EN-DC-115 included, Change protective relay settings, generator exciter or Automatic Voltage Regulator (AVR) settings. Although this box was checked in conjunction with the licensee's implementation of EC 67304, the inspectors could find neither an evaluation for the effects of changing this setpoint nor an evaluation for the effects of a reduced operating margin as a result of the setpoint reduction.
-Power."  Specifically, because the finding only caused a reactor trip but not the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition, the finding was determined to be of very low safety significance (Green). Cross-Cutting Aspect:  H.6 - Design Margins: The organization operates and maintains equipment within design margins.


Margins are carefully guarded and changed only through a systematic and rigorous process.
The licensee performed a root cause evaluation and concluded that the root cause was that engineering leadership did not ensure standards and expectations for adherence to a systematic and rigorous configuration change process were met to maintain operating margins and achieve an acceptable result to prevent an unplanned scram. Contributing causes were determined to be the failure of electrical design engineers to follow the configuration control process as described in Procedure EN-DC-115.


Special attention is placed on maintaining fission product barriers, defense
The licensee determined, based on previous operating experience and equipment limitations, that a setpoint of 9 percent was acceptable to provide an adequate level of protection to the generator equipment while still maintaining an acceptable operational margin to prevent spurious trips on generator negative phase sequence from normal grid operating conditions.
-in-depth, and safety related equipment.


Specifically, the licensee failed to carefully guard margins and did not employ a systematic and rigorous process to control operational margins when developing, reviewing, approving, and implementing EC 67304. Enforcement
As a result, the licensee issued EC 81801 to change the trip setpoint back to 9 percent, which was completed under Work Order 00519151 on February 27, 2019.
:  Inspectors did not identify a violation of regulatory requirements associated with this finding.


==EXIT MEETINGS AND DEBRIEFS==
Corrective Actions: Licensee corrective actions included performing a root cause evaluation, which resulted in procedure changes and training of applicable engineering staff. The negative phase setpoint was changed back to 9 percent.
The inspectors verified no proprietary information was retained or documented in this report.


On July 11, 2019, the inspector s presented the integrated inspection results to Mr. E. Larson, Site Vice President, and other members of the licensee staff.
Corrective Action References: The licensee entered the issue into their corrective action program as Condition Report CR-GGN-2019-01504.


On March 15, 2019
=====Performance Assessment:=====
, the inspector s presented the onsite inspection week debrief to Mr. T. Burnett, Director, Corporate Emergency Preparedness, Entergy
Performance Deficiency: The licensees failure to follow the configuration control process as described in licensee Procedure EN-DC-115 is a performance deficiency. Because the licensee did not effectively evaluate the impact of reducing generator protective relay setpoints, operating margins were not managed as required by Procedure EN-DC-115.
, and other members of the licensee staff.


On April 25, 2019
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Initiating Events cornerstone. Specifically, the performance deficiency contributed to an unplanned automatic reactor scram.
, the inspector s presented the Inspection Procedure 92723 results to Mr. E. Larson, Site Vice President
, and other members of the licensee staff.


On May 30, 2019
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, because the finding only caused a reactor trip but not the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition, the finding was determined to be of very low safety significance (Green).
, the inspector s presented the emergency preparedness exercise inspection results to Mr. E. Larson, Site Vice President
, and other members of the licensee staff.


On June 7, 2019
Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense-in-depth, and safety related equipment. Specifically, the licensee failed to carefully guard margins and did not employ a systematic and rigorous process to control operational margins when developing, reviewing, approving, and implementing EC 67304.
, the inspector s presented the radiation protection inspection results to Mr. E. Larson, Site Vice President
, and other members of the licensee staff.


On July 1, 2019
=====Enforcement:=====
, the inspector s presented the heat sink performance inspection results to Mr. M. Lingenfelter, Director Engineering
Inspectors did not identify a violation of regulatory requirements associated with this finding.
, and other members of the licensee staff.
 
==EXIT MEETINGS AND DEBRIEFS==
The inspectors verified no proprietary information was retained or documented in this report.
* On July 11, 2019, the inspectors presented the integrated inspection results to Mr. E. Larson, Site Vice President, and other members of the licensee staff.
* On March 15, 2019, the inspectors presented the onsite inspection week debrief to Mr. T. Burnett, Director, Corporate Emergency Preparedness, Entergy, and other members of the licensee staff.
* On April 25, 2019, the inspectors presented the Inspection Procedure 92723 results to Mr. E. Larson, Site Vice President, and other members of the licensee staff.
* On May 30, 2019, the inspectors presented the emergency preparedness exercise inspection results to Mr. E. Larson, Site Vice President, and other members of the licensee staff.
* On June 7, 2019, the inspectors presented the radiation protection inspection results to Mr. E. Larson, Site Vice President, and other members of the licensee staff.
* On July 1, 2019, the inspectors presented the heat sink performance inspection results to Mr. M. Lingenfelter, Director Engineering, and other members of the licensee staff.


THIRD PARTY REVIEWS Inspectors reviewed Institute on Nuclear Power Operations reports that were issued during the inspection period.
THIRD PARTY REVIEWS Inspectors reviewed Institute on Nuclear Power Operations reports that were issued during the inspection period.


=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=
Inspection Procedure Type Designation
Description or Title
Revision or Date 71111.07T Calculations
707752 Air Handling Unit, Pump Room Cooler
- Vane Axial Fan
A MC-Q1E12-10001 Water Hammer Analysis of the RHR System
MC-Q1P41-11001 GGNS Standby Service Water Ultimate Heat Sink Thirty Day Performance at EPU
MC-Q1P41-12001 SSW Dynamic Venting (CR
-GGN-2011-8690 and LO
-GLO-2011-0055) 0 MC-Q1P41-87215 Evaluation of Low SSW (P41) Flow to the Standby Diesel Jacket Water Cooler
MC-Q1P41-97020 Determination of Minimum Allowable SSW Flows (LOCA Lineup) to Safety Related Heat Exchangers
MC-Q1P41-99031 Standby Service Water Flow Evaluation
Drawings C-6024 Location of Settlement Markers and Permanent Bench Marks, Unit 1
E12-B001 Envelope heat Exchanger
- Residual Heat Removal System
Engineering Changes 0000040821
Justification of Plugging 10% Tubes on the Diesel Generator Jacket Water Cooler (1P75B004A/B) for CR
-GGN-2012-12060 11/02/2012
0000063673
Evaluate for Minimum RHR Tube Wall Thickness and Maximum Number of Allowed Plugged Tubes
03/21/2016
0000081755
Acceptance of Entergy Grand Gulf Failure Analysis Water Pipe System Final Report from SI
2/21/2019
Miscellaneous
04-1-02-1H13-P864 Alarm Response Instruction Panel NO: 1H13
-P864 033 08-S-03-10 Chemistry Sampling Program
056 460000403 Ceramic Cooling Tower Company
- Standby Service Water Cooling Towers
300 460000450 Transamerica Delaval Instruction Manual Volume 1, model DSRV-16-4 Diesel Engine/Generator
07/17/1980
460000503 Joy Nuclear Non
-Containment Axivane Fan Operators Handbook 11/22/2002


Inspection Procedure Type Designation
Inspection Type         Designation   Description or Title                                       Revision or
Description or Title
Procedure                                                                                          Date
Revision or Date CCE 202006
71111.07T Calculations  707752        Air Handling Unit, Pump Room Cooler - Vane Axial Fan        A
-0002 Commitment Change Evaluation
MC-Q1E12-     Water Hammer Analysis of the RHR System                    0
- AECM-90/007 05/25/2004
10001
CCE 202006
MC-Q1P41-     GGNS Standby Service Water Ultimate Heat Sink Thirty Day    0
-0002 Commitment Change Evaluation
11001        Performance at EPU
- AECM-90/007 05/02/2006
MC-Q1P41-     SSW Dynamic Venting (CR-GGN-2011-8690 and LO-GLO-          0
CCE 202006
2001        2011-0055)
-0004 Commitment Change Evaluation
MC-Q1P41-    Evaluation of Low SSW (P41) Flow to the Standby Diesel      1
- AECM-90/007 10/19/2006
215        Jacket Water Cooler
GEK-83280 Operation and Maintenance Instructions
MC-Q1P41-     Determination of Minimum Allowable SSW Flows (LOCA          14
- Residual Heat Removal System Heat Exchangers
97020        Lineup) to Safety Related Heat Exchangers
10/26/2005
MC-Q1P41-    Standby Service Water Flow Evaluation                      0
GNRO-2008/00044
99031
Report of 10CFR50.59 Evaluations and Commitment Changes April 1, 2007 through March 31, 2008 05/19/2008
Drawings      C-6024        Location of Settlement Markers and Permanent Bench          1
NDE Reports
Marks, Unit 1
2749571.01
E12-B001      Envelope heat Exchanger - Residual Heat Removal System      1
Eddy Current Inspection of DGJW P75B004B
Engineering  0000040821    Justification of Plugging 10% Tubes on the Diesel Generator 11/02/2012
2/25/2019
Changes                    Jacket Water Cooler (1P75B004A/B) for CR-GGN-2012-
2749571.01
2060
Eddy Current Inspection of DGJW P75B004B
0000063673    Evaluate for Minimum RHR Tube Wall Thickness and            03/21/2016
2/05/2019
Maximum Number of Allowed Plugged Tubes
BOP-UT-15-001 UT Thickness Examination, 3/4"-HBC-358, MIC-101B-116-059 04/27/2015
0000081755    Acceptance of Entergy Grand Gulf Failure Analysis Water    02/21/2019
BOP-UT-15-004 UT Thickness Examination, HBC
Pipe System Final Report from SI
-155 Pipping, MIC
Miscellaneous 04-1-02-1H13- Alarm Response Instruction Panel NO: 1H13-P864              033
-1061B-098-101 10/25/2015
P864
BOP-UT-15-005 UT Thickness Examination, 3/4" HBC
08-S-03-10    Chemistry Sampling Program                                  056
-154 Pipping, MIC
460000403    Ceramic Cooling Tower Company - Standby Service Water      300
-1061B-092-022 07/01/2015 BOP-UT-15-006 UT Thickness Examination, 3/4" HBD
Cooling Towers
-252 Drain Pipping, MIC
460000450    Transamerica Delaval Instruction Manual Volume 1, model    07/17/1980
-1061B-093-103 07/01/2015
DSRV-16-4 Diesel Engine/Generator
BOP-UT-15-010 UT Thickness Examination, Line 2" HBC
460000503    Joy Nuclear Non-Containment Axivane Fan Operators          11/22/2002
-94, MIC-1061C-075-024 11/25/2015
Handbook
BOP-UT-15-011 UT Thickness Examination, Line 1" HBC
Inspection Type        Designation  Description or Title                                    Revision or
-96, MIC-1061C-161-005 10/25/2015
Procedure                                                                                    Date
BOP-UT-15-014 UT Thickness Examination, 3/4" HBC
CCE 202006-   Commitment Change Evaluation - AECM-90/007              05/25/2004
-087, MIC-1061B-314-095 10/25/2015
0002
BOP-UT-15-018 UT Thickness Examination, 4" HBC
CCE 202006-   Commitment Change Evaluation - AECM-90/007              05/02/2006
-173, MIC-M1358K-057 10/25/2015
0002
BOP-UT-19-001 UT Thickness Examination, 10" HBC
CCE 202006-   Commitment Change Evaluation - AECM-90/007              10/19/2006
-87 Down Stream of 1P41F023A, 1P41 Standby Service Water
0004
01/07/2019
GEK-83280    Operation and Maintenance Instructions - Residual Heat  10/26/2005
BOP-UT-19-008 UT Thickness Examination, 10"-HBC-86-Elbow Downstream of 1P41F018A, 1P41 Standby Service Water
Removal System Heat Exchangers
04/25/2019
GNRO-         Report of 10CFR50.59 Evaluations and Commitment          05/19/2008
BOP-VE-16-032 Eddy Current Examination, RHR Heatexchanger
2008/00044    Changes April 1, 2007 through March 31, 2008
03/02/2016
NDE Reports 52749571.01  Eddy Current Inspection of DGJW P75B004B                02/25/2019
BOP-VE-16-033 Eddy Current Examination, RHR Heatexchanger
2749571.01  Eddy Current Inspection of DGJW P75B004B                02/05/2019
03/02/2016
BOP-UT-15-001 UT Thickness Examination, 3/4-HBC-358, MIC-101B-116-     04/27/2015
Inspection Procedure Type Designation
059
Description or Title
BOP-UT-15-004 UT Thickness Examination, HBC-155 Pipping, MIC-1061B-   10/25/2015
Revision or Date Operability Evaluations
098-101
06-OP-1P41-Q-0004 Standby Service Water Loop A Valve and Pump Operability Test 128 Procedures
BOP-UT-15-005 UT Thickness Examination, 3/4 HBC-154 Pipping, MIC-       07/01/2015
04-1-01-P41-1 Standby Service Water System
1061B-092-022
146 04-1-02-1H13-P601 Alarm Response Instruction Panel No.: 1H13
BOP-UT-15-006 UT Thickness Examination, 3/4 HBD-252 Drain Pipping, MIC- 07/01/2015
-P601 166 04-1-02-1H13-P870 Alarm Response Instruction, Panel No. 1H13
1061B-093-103
-P870 156 04-1-02-1H13-P870 Alarm Response Instruction Panel NO: 1H13
BOP-UT-15-010 UT Thickness Examination, Line 2 HBC-94, MIC-1061C-     11/25/2015
-P870 156 05-1-02-III-1 Inadequate Decay Heat Removal
075-024
046 06-OP-1P41-O-0001 Standby Service Water Loop Siphon Line Operability Test
BOP-UT-15-011 UT Thickness Examination, Line 1 HBC-96, MIC-1061C-    10/25/2015
2 06-OP-1P41-Q-0005 Standby Service Water Loop B Valve and Pump Operability Test 125 07-S-07-211 Service Level 1 Coating Assessment
161-005
2 08-S-03-14 Chemical Additions to Plant Systems
BOP-UT-15-014 UT Thickness Examination, 3/4 HBC-087, MIC-1061B-314-    10/25/2015
26 08-S-03-28 SSW Emergency Water Treatment Guide
095
001 08-S-04-120 Chemistry Evolution at Standby Service Water
BOP-UT-15-018 UT Thickness Examination, 4 HBC-173, MIC-M1358K-057    10/25/2015
017 17-S-03-29 Generic Letter 89
BOP-UT-19-001 UT Thickness Examination, 10 HBC-87 Down Stream of      01/07/2019
-13 Thermal Performance Data Collection and Analysis
1P41F023A, 1P41 Standby Service Water
007 CEP-WP-RBMD-1 Repair of Base Material Defects
BOP-UT-19-008 UT Thickness Examination, 10-HBC-86-Elbow Downstream    04/25/2019
2 EN-DC-150 Condition Monitoring of Maintenance Rule Structures
of 1P41F018A, 1P41 Standby Service Water
014 EN-DC-184 NRC Generic Letter 89
BOP-VE-16-032 Eddy Current Examination, RHR Heatexchanger              03/02/2016
-13 Service Water Program
BOP-VE-16-033 Eddy Current Examination, RHR Heatexchanger              03/02/2016
006 EN-DC-316 Heat Exchanger Performance and Condition Monitoring
Inspection Type              Designation  Description or Title                                    Revision or
011 EN-EP-S-039-G Testing Standard for Safety
Procedure                                                                                          Date
-Related Heat Exchangers Cooled by Standby Service Water
Operability      06-OP-1P41-Q- Standby Service Water Loop A Valve and Pump Operability 128
005 EN-LI-100 Process Applicability Determination
Evaluations      0004          Test
011 EN-LI-100 Process Applicability Determination
Procedures        04-1-01-P41-1 Standby Service Water System                            146
26 EN-LI-101 10 CFR 50.59 Evaluations
04-1-02-1H13- Alarm Response Instruction Panel No.: 1H13-P601          166
009 EN-LI-101 10 CFR 50.59 Evaluations
P601
017 EN-OP-104 Operability Determination Process
04-1-02-1H13- Alarm Response Instruction, Panel No. 1H13-P870          156
016 71114.01 Corrective Action
P870
CR-GGN- 2017-001874, 2017
04-1-02-1H13- Alarm Response Instruction Panel NO: 1H13-P870          156
-001917, 2017
P870
-003233, 2017
05-1-02-III-1 Inadequate Decay Heat Removal                            046
-003312,
06-OP-1P41-O- Standby Service Water Loop Siphon Line Operability Test  102
Inspection Procedure Type Designation
0001
Description or Title
06-OP-1P41-Q- Standby Service Water Loop B Valve and Pump Operability  125
Revision or Date Documents 2017-003314, 2017
0005          Test
-003687, 2017
07-S-07-211  Service Level 1 Coating Assessment                      002
-003688, 2017
08-S-03-14    Chemical Additions to Plant Systems                      026
-003906, 2017-004066, 2017
08-S-03-28    SSW Emergency Water Treatment Guide                      001
-004067, 2017
08-S-04-120  Chemistry Evolution at Standby Service Water             017
-004068, 2017
17-S-03-29    Generic Letter 89-13 Thermal Performance Data Collection 007
-004133, 2017-006065, 2017
and Analysis
-006802, 2017
CEP-WP-RBMD- Repair of Base Material Defects                          002
-006839, 2017
EN-DC-150    Condition Monitoring of Maintenance Rule Structures      014
-008121, 2017-008218, 2017
EN-DC-184    NRC Generic Letter 89-13 Service Water Program          006
-009814, 2017
EN-DC-316    Heat Exchanger Performance and Condition Monitoring      011
-010467, 2017
EN-EP-S-039-G Testing Standard for Safety-Related Heat Exchangers      005
-010730, 2017-010737, 2017
Cooled by Standby Service Water
-011841, 2017
EN-LI-100    Process Applicability Determination                      011
-011845, 2017
EN-LI-100    Process Applicability Determination                      026
-012598, 2017-012695, 2018
EN-LI-101    10 CFR 50.59 Evaluations                                009
-000429, 2018
EN-LI-101    10 CFR 50.59 Evaluations                                017
-001636, 2018
EN-OP-104    Operability Determination Process                        016
-002759, 2018-002805, 2018
71114.01  Corrective Action CR-GGN-       2017-001874, 2017-001917, 2017-003233, 2017-003312,
-011059, 2018
Inspection Type          Designation  Description or Title                                    Revision or
-011061, 2018
Procedure                                                                                      Date
-011077, 2018-012401, 2019
Documents                  2017-003314, 2017-003687, 2017-003688, 2017-003906,
-000501, 2019
2017-004066, 2017-004067, 2017-004068, 2017-004133,
-000988, 2019
2017-006065, 2017-006802, 2017-006839, 2017-008121,
-001023, 2019-001201, 2019
2017-008218, 2017-009814, 2017-010467, 2017-010730,
-002014, 2019
2017-010737, 2017-011841, 2017-011845, 2017-012598,
-002075, 2019
2017-012695, 2018-000429, 2018-001636, 2018-002759,
-002190, 2019-002364, 2019
2018-002805, 2018-011059, 2018-011061, 2018-011077,
-002369, 2019
2018-012401, 2019-000501, 2019-000988, 2019-001023,
-002371, 2019
2019-001201, 2019-002014, 2019-002075, 2019-002190,
-002375, 2019-002494 Drawings E-0300 34.5KV Substations (Units 1&2) Location Plan
2019-002364, 2019-002369, 2019-002371, 2019-002375,
Miscellaneous
2019-002494
Grand Gulf Nuclear Station Emergency Plan
Drawings      E-0300        34.5KV Substations (Units 1&2) Location Plan           2
76, 77, 78
Miscellaneous               Grand Gulf Nuclear Station Emergency Plan               76, 77, 78
GGNS Repair Team Demonstration Controller
GGNS Repair Team Demonstration Controller-Evaluator     5/9/2019
-Evaluator Manual 5/9/2019 2018-00221 GGN 2018 November 14 Blue Team ERO Training Drill Report 12/12/2018
Manual
EN-TQ-125 Fire Drill Scenario of 12
2018-00221   GGN 2018 November 14 Blue Team ERO Training Drill       12/12/2018
-2-2018 2/3/2018 GGNS-EP-2018HPDRILL
Report
-A Onsite Health Physics Drill Report
EN-TQ-125     Fire Drill Scenario of 12-2-2018                       2/3/2018
7/20/2018 Procedures
GGNS-EP-     Onsite Health Physics Drill Report                     7/20/2018
01-S-10-3 Emergency Planning Department Responsibilities
2018HPDRILL-A
10-S-01-1 Activation of the Emergency Plan, Revision 129
Procedures   01-S-10-3     Emergency Planning Department Responsibilities         24
3/5/2019 10-S-01-11 Evacuation of Onsite Personnel, Revision 26
10-S-01-1     Activation of the Emergency Plan, Revision 129         3/5/2019
10/24/2017
10-S-01-11   Evacuation of Onsite Personnel, Revision 26             10/24/2017
10-S-01-12 Radiological Assessment and Protective Action Recommendations, Revision 47
10-S-01-12   Radiological Assessment and Protective Action           11/7/ 2017
11/7/ 2017
Recommendations, Revision 47
10-S-01-17 Emergency Personnel Exposure Control, Revision 19
10-S-01-17   Emergency Personnel Exposure Control, Revision 19       6/17/2011
6/17/2011 10-S-01-20 Administration of Thyroid Blocking Agents, Revision 16
10-S-01-20   Administration of Thyroid Blocking Agents, Revision 16 1/7/2015
1/7/2015 10-S-01-26 Offsite Emergency Response, Revision 14
10-S-01-26   Offsite Emergency Response, Revision 14                 10/15/2013
10/15/2013
10-S-01-35   Core Damage Assessment, Revision 6                     8/9/2012
10-S-01-35 Core Damage Assessment, Revision 6
10-S-01-38   Equipment Important to Emergency Response, Revision 5   5/2/2017
8/9/2012 10-S-01-38 Equipment Important to Emergency Response, Revision 5
10-S-01-5     Control of Emergency Response Equipment and Facilities, 3/13/2018
5/2/2017 10-S-01-5 Control of Emergency Response Equipment and Facilities, Revision 17
Revision 17
3/13/2018 10-S-01-6 Notification of Offsite Agencies and Plant On
10-S-01-6     Notification of Offsite Agencies and Plant On-Call     1/10/2018
-Call Emergency Personnel, Revision 56
Emergency Personnel, Revision 56
1/10/2018
Inspection Type             Designation   Description or Title                                   Revision or
Inspection Procedure Type Designation
Procedure                                                                                          Date
Description or Title
EN-EP-306     Drills and Exercises, Revision 9                       12/14/2017
Revision or Date EN-EP-306 Drills and Exercises, Revision 9
EN-EP-308     Emergency Planning Critiques, Revision 5               5/11/2017
2/14/2017
EN-EP-310     Emergency Response Organization Notification System,   1/17/2019
EN-EP-308 Emergency Planning Critiques, Revision 5
Revision 7
5/11/2017 EN-EP-310 Emergency Response Organization Notification System, Revision 7
EN-EP-313     Offsite Dose Assessment Manual using the Unified RASCAL 3/31/2016
1/17/2019 EN-EP-313 Offsite Dose Assessment Manual using the Unified RASCAL Interface, Revision 2
Interface, Revision 2
3/31/2016 EN-EP-609 Emergency Operations Facility Operations, Revision 6
EN-EP-609     Emergency Operations Facility Operations, Revision 6   11/15/2018
11/15/2018
EN-EP-610     Technical Support Center Operations, Revision 4         9/27/2017
EN-EP-610 Technical Support Center Operations, Revision 4
EN-EP-611     Operations Support Center Operations, Revision 5       9/27/2017
9/27/2017 EN-EP-611 Operations Support Center Operations, Revision 5
EN-EP-801     Emergency Response Organization, Revision 16           11/30/2018
9/27/2017 EN-EP-801 Emergency Response Organization, Revision 16
EN-FAP-EP-013 Emergency Preparedness Program Maintenance, Revision 2 3/29/2018
11/30/2018
71124.02   Corrective Action CR-GGN-       2018-00330, 2018-00524, 2018-03376, 2018-03442, 2018-
EN-FAP-EP-013 Emergency Preparedness Program Maintenance, Revision 2
Documents                      03535, 2018-03571, 2018-04065, 2018-04681, 2018-06442,
3/29/2018 71124.02 Corrective Action Documents CR-GGN- 2018-00330, 2018
2018-07122, 2018-08989
-00524, 2018
Miscellaneous                   2017 Annual Radiation Protection Report
-03376, 2018
RF-21         GGNS Refueling Outage 21: 4/7/18 - 7/19/18, 103 Days   8/2018
-03442, 2018
Procedures       EN-RP-105     Radiation Work Permits                                 15
-03535, 2018
EN-RP-110     ALARA Program                                           14
-03571, 2018
EN-RP-110-01 ALARA Deferral Initiatives                             1
-04065, 2018
EN-RP-110-02 Elemental Cobalt Sampling                               0
-04681, 2018
EN-RP-110-03 Collective Radiation Exposure Reduction Guidelines     4
-06442, 2018-07122, 2018
EN-RP-110-04 Radiation Protection Risk Assessment Process           7
-08989 Miscellaneous
EN-RP-110-06 Outage Dose Estimating and Tracking                     1
2017 Annual Radiation Protection Report
Self-Assessments LO-GLO-2018- Pre-NRC Inspection IP71124.02 ALARA Planning & Controls 09/23/18
RF-21 GGNS Refueling Outage 21: 4/7/18  
27
- 7/19/18, 103 Days
71124.04   Corrective Action CR-GGN-       2018-03246, 2018-04298, 2018-04644, 2018-06062, 2018-
8/2018 Procedures
Documents                      06432, 2018-06460, 2018-06616, 2019-03504,
EN-RP-105 Radiation Work Permits
Miscellaneous     2018         RBS Dose by Department                                 12/31/18
EN-RP-110 ALARA Program
2019         RBS Dose by Department                                 05/30/19
EN-RP-110-01 ALARA Deferral Initiatives
Procedures       EN-RP-131     Air Sampling                                           16
EN-RP-110-02 Elemental Cobalt Sampling
EN-RP-201     Dosimetry Administration                               5
EN-RP-110-03 Collective Radiation Exposure Reduction Guidelines
EN-RP-202     Personnel Monitoring                                   5
EN-RP-110-04 Radiation Protection Risk Assessment Process
EN-RP-203     Dose Assessment                                         10
EN-RP-110-06 Outage Dose Estimating and Tracking
Inspection Type             Designation     Description or Title                                   Revision or
Self-Assessments
Procedure                                                                                            Date
LO-GLO-2018-0127 Pre-NRC Inspection IP71124.02 ALARA Planning & Controls
EN-RP-204-01   Effective Dose Equivalent (EDEX) Monitoring             3
09/23/18 71124.04 Corrective Action Documents CR-GGN- 2018-03246, 2018
EN-RP-205       Prenatal Monitoring                                     3
-04298, 2018
EN-RP-206       Dosimeter of Legal Record Quality Assurance             6
-04644, 2018
EN-RP-208       Whole Body Counting/In-Vitro Bioassay                   7
-06062, 2018
Self-Assessments 2017           2017 Evaluation of Internal Dose Monitoring
-06432, 2018
2017           On-Site Assessment of Landauer                         08/25/17
-06460, 2018
LO-LGO-0178     Pre-NRC Inspection IP71124.04 Dose Assessment
-06616, 2019
71152     Calculations     EC-N1N41-17001 Generator Protection                                   0
-03504,   Miscellaneous
PR0204         Generator Negative Sequence Protection                 2
2018 RBS Dose by Department
Corrective Action CR-GGN-         2019-01504
2/31/18 2019 RBS Dose by Department
Documents
05/30/19 Procedures
Engineering       EC-20838       GGN EPU Main Generator Replacement
EN-RP-131 Air Sampling 16 EN-RP-201 Dosimetry Administration
Changes          EC-67304       Main Generator and Transformer Relay Protection
EN-RP-202 Personnel Monitoring
EC-81801       Main Generator and Transformer Relay Protection
EN-RP-203 Dose Assessment
Procedures       EN-DC-115       Engineering Change Process                             21
Inspection Procedure Type Designation
EN-DC-156       Technical and Quality Requirements for Engineering     13
Description or Title
Contracted Services
Revision or Date EN-RP-204-01 Effective Dose Equivalent (EDEX) Monitoring
Work Orders       WO             519151
EN-RP-205 Prenatal Monitoring
71153     Corrective Action CR-GGN-         2017-12299, 2017-12314,
EN-RP-206 Dosimeter of Legal Record Quality Assurance
Documents
EN-RP-208 Whole Body Counting/In
Miscellaneous     LER 2017-007-00 Engineered Safety Feature System Actuations due to the 2/5/18
-Vitro Bioassay
Self-Assessments
2017 2017 Evaluation of Internal Dose Monitoring
2017 On-Site Assessment of Landauer
08/25/17 LO-LGO-0178 Pre-NRC Inspection IP71124.04 Dose Assessment
71152 Calculations
EC-N1N41-17001 Generator Protection
PR0204 Generator Negative Sequence Protection
Corrective Action Documents CR-GGN- 2019-01504 Engineering Changes EC-20838 GGN EPU Main Generator Replacement
EC-67304 Main Generator and Transformer
Relay Protection
EC-81801 Main Generator and Transformer Relay Protection
Procedures
EN-DC-115 Engineering Change Process
EN-DC-156 Technical and Quality Requirements for Engineering Contracted Services 13 Work Orders
WO 519151 71153 Corrective Action Documents CR-GGN- 2017-12299, 2017
-12314,   Miscellaneous
LER 2017-007-00 Engineered Safety Feature System Actuations due to the
Loss of Engineered Safety Features Transformer 11
Loss of Engineered Safety Features Transformer 11
2/5/18 LER 2017-007-01 Engineered Safety Features System Actuations due to the
LER 2017-007-01 Engineered Safety Features System Actuations due to the 12/12/18
Loss of Engineered Safety Features Transformer 11
Loss of Engineered Safety Features Transformer 11
2/12/18 92723 Corrective Action Documents  CR-HQN-2017-1356   CR-WF3-2019-3425 CR-GGN- 2014-03335, 2014
2723      Corrective Action                 CR-HQN-2017-1356
-05539, 2015
Documents                        CR-WF3-2019-3425
-05057, 2016
CR-GGN-         2014-03335, 2014-05539, 2015-05057, 2016-08295, 2016-
-08295, 2016
298, 2016-08327, 2016-08328, 2016-08329, 2016-09755,
-08298, 2016
2016-09756, 2016-09757, 2017-01483, 2017-03092, 2017-
-08327, 2016
03101, 2017-03331, 2017-03404, 2017-07970, 2017-09154,
-08328, 2016
2017-09747, 2017-12284, 2018-01595, 2018-04199, 2019-
-08329, 2016
232, 2019-00625, 2019-01002, 2019-01003, 2019-01007,
-09755, 2016-09756, 2016
2019-01047, 2019-01179, 2019-01185, 2019-01306, 2019-
-09757, 2017
01390, 2019-01391, 2019-01916, 2019-01917, 2019-01919,
-01483, 2017
Inspection Type       Designation Description or Title                                   Revision or
-03092, 2017
Procedure                                                                                Date
-03101, 2017
2019-01977, 2019-02077, 2019-02103, 2019-02417, 2019-
-03331, 2017
2441, 2019-02442, 2019-02458, 2019-02491, 2019-02493,
-03404, 2 017-07970, 2017
2019-02674, 2019-02684
-09154, 2017-09747, 2017
Procedures 08-S-08-5   Plant Operations Manual Volume 8 - Environmental       111
-12284, 2018
Procedure Environmental Reporting
-01595, 2018
EN-CY-100   Conduct of Chemistry                                   0
-04199, 2019
EN-CY-100   Conduct of Chemistry                                   1
-00232, 2019
EN-DC-114   Project Management                                     16
-00625, 2019
EN-DC-115   Engineering Change Process                             26
-01002, 2019
EN-DC-126   Engineering Calculation Process                       8
-01003, 2019
EN-DC-132   Control of Engineering Documents                       8
-01007, 2019-01047, 2019
EN-DC-147   Engineering Reports                                   7
-01179, 2019
EN-DC-149   Acceptance of Vendor Documents                         14
-01185, 2019
EN-HU-101   Human Performance Program                             20
-01306, 2019
EN-LI-100   Process Applicability Determination                   25
-01390, 2019
EN-LI-101   10 CFR 50.59 Evaluations                               17
-01391, 2019
EN-LI-102   Corrective Action Program                             27
-01916, 2019
EN-LI-102   Corrective Action Program                             28
-01917, 2019
EN-LI-102   Corrective Action Program                             36
-01919,
EN-LI-103   Operating License Amendments                           11
Inspection Procedure Type Designation
EN-LI-106   NRC Correspondence                                     19
Description or Title
EN-LI-112   10 CFR 72.48 Evaluations                               13
Revision or Date 2019-01977, 2019
EN-LI-113   Licensing Basis Document Change Process               17
-02077, 2019
EN-LI-113-01 Updated Final Safety Analysis Report Change Process   3
-02103, 2019
EN-LI-123   NRC Inspection Support                                 9
-02417, 2019
FWKB-CM-     Effluent Specialist Workbook                           1
-02441, 2019
EFFLUENT
-02442, 2019
The following items are requested for the:
-02458, 2019
Occupational Radiation Safety Inspection
-02491, 2019
Integrated Report 2019-002
-02493, 2019-02674, 2019
at
-02684 Procedures
Grand Gulf Nuclear Station
08-S-08-5 Plant Operations Manual Volume 8  
                                                            (June 3 -6, 2019)
- Environmental Procedure Environmental Reporting
Inspection areas are listed in the attachments below.
111 EN-CY-100 Conduct of Chemistry
EN-CY-100 Conduct of Chemistry
EN-DC-114 Project Management
EN-DC-115 Engineering Change Process
EN-DC-126 Engineering Calculation Process
EN-DC-132 Control of Engineering Documents
EN-DC-147 Engineering Reports
EN-DC-149 Acceptance of Vendor Documents
EN-HU-101 Human Performance Program
EN-LI-100 Process Applicability Determination
EN-LI-101 10 CFR 50.59 Evaluations
EN-LI-102 Corrective Action Program
EN-LI-102 Corrective Action Program
EN-LI-102 Corrective Action Program
EN-LI-103 Operating License Amendments
EN-LI-106 NRC Correspondence
EN-LI-112 10 CFR 72.48 Evaluations
EN-LI-113 Licensing Basis Document Change Process
EN-LI-113-01 Updated Final Safety Analysis Report Change Process
EN-LI-123 NRC Inspection Support
FWKB-CM-EFFLUENT Effluent Specialist Workbook
The following items are requested for the
:  Occupational Radiation Safety Inspection
Integrated Report 2019
-002 at Grand Gulf Nuclear Station
(June 3 -6, 2019)   Inspection areas are listed in the attachments below.
Please provide the requested information on or before May 23, 2019
Please provide the requested information on or before May 23, 2019
Please submit this information using the same lettering system as below. For example, all contacts and phone numbers for Inspection Procedure 71124.0
Please submit this information using the same lettering system as below. For example, all contacts and phone numbers for
should be in a file/folder titled "
Inspection Procedure 71124.01 should be in a file/folder titled 1- A, applicable organization charts in file/folder 1- B, etc.
1- A," applicable organization charts in file/folder "
If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at least 30 days later than the onsite
1- B," etc. If information is placed on ims.certrec.com, please ensure the inspection exit date
inspection dates, so the inspectors will have access to the information while writing the report.
entered is at least 30 days later than the onsite inspection dates, so the inspectors will have access to the information while writing the report.
In addition to the corrective action document lists provided for each inspection procedure listed below, please provide updated lists of
In addition to the corrective action document lists provided for each inspection procedure listed below, please provide updated lists of corrective action documents at the entrance meeting. The dates for these lists should range from the end dates of the original lists to the day of the entrance meeting.
corrective action documents at the entrance meeting. The dates for these lists should range from the end dates of the original lists to
If more than one inspection procedure is to be conducted and the information requests appear to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which file the information can be found.
the day of the entrance meeting.
If you have any questions or comments, please contact Louis Carson at (817)200
If more than one inspection procedure is to be conducted and the information requests appear to be redundant, there is no need to
-1221, Louis.Carson@nrc.gov
provide duplicate copies. Enter a note explaining in which file the information can be found.
. PAPERWORK REDUCTION ACT STATEMENT
If you have any questions or comments, please contact Louis Carson at (817)200-1221, Louis.Carson@nrc.gov.
This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 199
PAPERWORK REDUCTION ACT STATEMENT
(44 U.
This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995
: [[contact::S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget]], C ontrol Number 3150
    (44 U.
-0011.
: [[contact::S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget]],
Control Number 3150-0011.
2. Occupational ALARA Planning and Controls (71124.02)
2. Occupational ALARA Planning and Controls (71124.02)
Date of Last Inspection:
Date of Last Inspection:         April 23, 2018
April 23, 2018
A. List of contacts and telephone numbers for ALARA program personnel
A. List of contacts and telephone numbers for ALARA program personnel
B. Applicable organization charts
B. Applicable organization charts
: [[contact::C. Copies of audits]], self
: [[contact::C. Copies of audits]], self-assessments, and LERs, written since date of last inspection, focusing on ALARA
-assessments, and LERs, written since date of last inspection
, focusing on ALARA
D. Procedure index for ALARA Program
D. Procedure index for ALARA Program
E. Please provide specific procedures related to the following areas noted below. Additional Specific Procedures may be requested by number
E. Please provide specific procedures related to the following areas noted below. Additional Specific Procedures may be
after the inspector reviews the procedure indexes.
requested by number after the inspector reviews the procedure indexes.
1. ALARA Program
1. ALARA Program
2. ALARA Committee
2. ALARA Committee
3. Radiation Work Permit Preparation
3. Radiation Work Permit Preparation
F. A summary list of corrective action documents (including corporate and sub
F. A summary list of corrective action documents (including corporate and sub-tiered systems) written since date of last
-tiered systems) written since date of last inspection
inspection, related to the ALARA program. In addition to ALARA, the summary should also address Radiation Work Permit
, related to the ALARA program. In addition to ALARA, the summary should also address Radiation Work Permit violations, Electronic Dosimeter Alarms, and RWP Dose Estimates
violations, Electronic Dosimeter Alarms, and RWP Dose Estimates
NOTE: The lists should indicate the significance level
NOTE: The lists should indicate the significance level of each issue and the search criteria used. Please provide in document
of each issue and the search criteria
formats which are searchable so that the inspector can perform word searches.
used. Please provide in document formats which are "searchable" so that the inspector can perform word searches.
: [[contact::G. List of work activities greater than 1 rem]], since date of last inspection
: [[contact::G. List of work activities greater than 1 rem]], since date of last inspection
Include original dose estimate and actual dose.
Include original dose estimate and actual dose.
H. Site dose totals and 3
H. Site dose totals and 3-year rolling averages for the past 3 years (based on dose of record)
-year rolling averages for the past 3 years (based on dose of record)
I. Outline of source term reduction strategy
I. Outline of source term reduction strategy
: [[contact::J. If available]], provide
: [[contact::J. If available]], provide a copy of the ALARA outage report for the most recently completed outages for each unit
a copy of the ALARA outage report for the most recently
completed outages for each unit
K. Please provide your most recent Annual ALARA Report.
K. Please provide your most recent Annual ALARA Report.
4. Occupational Dose Assessment (Inspection Procedure 71124.04)
4. Occupational Dose Assessment (Inspection Procedure 71124.04)
Date of Last Inspection: November 21, 2016
Date of Last Inspection: November 21, 2016
A. List of contacts and telephone numbers for the following areas:
A. List of contacts and telephone numbers for the following areas:
1. Dose Assessment personnel
1. Dose Assessment personnel
B. Applicable organization charts
B. Applicable organization charts
: [[contact::C. Audits]], self
: [[contact::C. Audits]], self-assessments, vendor or NUPIC audits of contractor support, and LERs written since date of last inspection,
-assessments, vendor or NUPIC audits of contractor support, and LERs written since date of last inspection, related to:
related to:
1. Occupational Dose Assessment
1. Occupational Dose Assessment
D. Procedure indexes for the following areas:
D. Procedure indexes for the following areas:
1. Occupational Dose Assessment
1. Occupational Dose Assessment
E. Please provide specific procedures related to the following areas noted below. Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes.
E. Please provide specific procedures related to the following areas noted below. Additional Specific Procedures will be
requested by number after the inspector reviews the procedure indexes.
1. Radiation Protection Program
1. Radiation Protection Program
2. Radiation Protection Conduct of Operations
2. Radiation Protection Conduct of Operations
Line 940: Line 774:
7. Declared Pregnant Worker
7. Declared Pregnant Worker
8. Bioassay Program
8. Bioassay Program
F. List of corrective action documents (including corporate and sub
: [[contact::F. List of corrective action documents (including corporate and sub-tiered systems) written since date of last inspection]],
-tiered systems) written since date of last inspection, associated with:
associated with:
1. National Voluntary Laboratory Accreditation Program (NVLAP)
1. National Voluntary Laboratory Accreditation Program (NVLAP)
2. Dosimetry (TLD/OSL, etc.) problems
2. Dosimetry (TLD/OSL, etc.) problems
3. Electronic alarming dosimeters
3. Electronic alarming dosimeters
4. Bioassays or internally deposited radionuclides or internal dose
4. Bioassays or internally deposited radionuclides or internal dose
5. Neutron dose
5. Neutron dose
NOTE: The lists should indicate the significance level
NOTE: The lists should indicate the significance level of each issue and the search criteria used. Please provide in document
of each issue and the search criteria used. Please provide in document formats which are "searchable" so that the inspector can perform word searches.
formats which are searchable so that the inspector can perform word searches.
: [[contact::G. List of positive whole body counts since date of last inspection]], names redacted if desired
: [[contact::G.     List of positive whole body counts since date of last inspection]], names redacted if desired
H. Part 61 analyses/scaling factors
H.     Part 61 analyses/scaling factors
: [[contact::I. The most recent National Voluntary Laboratory Accreditation Program (NVLAP) accreditation report or]], if dosimetry is provided by a vendor, the vendor's most recent results
: [[contact::I.     The most recent National Voluntary Laboratory Accreditation Program (NVLAP) accreditation report or]], if dosimetry is
provided by a vendor, the vendors most recent results
PAPERWORK REDUCTION ACT STATEMENT
PAPERWORK REDUCTION ACT STATEMENT
This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).
This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995
Existing information collection requirements were approved by the Office of Management and Budget, Control Number 31 50-0011.
  (44 U.
: [[contact::S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget]],
Control Number 3150-0011.
 
ML19226A236
ML19226A236
SUNSI Review
SUNSI Review         ADAMS:           Non-Publicly Available       Non-Sensitive Keyword:
ADAMS:   Non-Publicly Available
By: CYoung           Yes No       Publicly Available           Sensitive     NRC-002
Non-Sensitive Keyword: By: CYoung  Yes    No Publicly Available
OFFICE       SRI:DRP/C   RI:DRP/C     ABC:DRS/EB1 C:DRS/EB2           C:DRS:EB2   TL:DRS/IPAT
Sensitive
NAME         TSteadham   NDay         GGeorge           NTaylor       GWermer     HFreeman
NRC-002 OFFICE SRI:DRP/C RI:DRP/C ABC:DRS/EB1
SIGNATURE     /RA/         /RA/         /RA/             /RA/         /RA/         /RA/
C:DRS/EB2 C:DRS:EB2 TL:DRS/IPAT
DATE         08/12/2019   08/12/2019   08/12/2019       08/13/2019   08/12/2019   08/12/2019
NAME TSteadham NDay GGeorge NTaylor GWermer HFreeman SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ DATE 08/12/2019
OFFICE       C:DRS/RCB   C:DNMS/RIB   PE/DRP/C         SRI/DRP/B     SPE/DRP     ABD:DRP/C
08/12/2019
NAME         MHaire       GWarnick     DProulx           DDodson       BTharakan   CYoung
08/12/2019
SIGNATURE     /RA/         /RA/         /RA/             /RA/         /RA/         /RA/
08/13/2019
DATE         08/12/2019   08/12/2019   08/12/2019       08/12/2019   08/09/2019   08/14/2019
08/12/2019
08/12/2019
OFFICE C:DRS/RCB C:DNMS/RIB
PE/DRP/C SRI/DRP/B SPE/DRP ABD:DRP/C NAME MHaire GWarnick DProulx DDodson BTharakan CYoung SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ DATE 08/12/2019
08/12/2019
08/12/2019
08/12/2019
08/09/2019
08/14/2019
}}
}}

Revision as of 23:20, 7 October 2019

Integrated Inspection Report 05000416/2019002
ML19226A236
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 08/14/2019
From: Cale Young
NRC/RGN-IV/DRP/RPB-C
To: Emily Larson
Entergy Operations
References
EPID: I-2019-002-0008 IR 2019002
Download: ML19226A236 (34)
v • d • e


Text

ust 14, 2019

SUBJECT:

GRAND GULF NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000416/2019002

Dear Mr. Larson:

On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Grand Gulf Nuclear Station. On July 11, 2019, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspectors documented one finding of very low safety significance (Green) in this report. The finding did not involve a violation of NRC requirements. Additionally, NRC inspectors documented one Severity Level IV violation with no associated finding. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

Inspection Procedure 92723, Follow up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period, was performed during this inspection period to assess your evaluation of 10 previously issued violations in the area of impeding the regulatory process, and to assess the adequacy of associated corrective actions. Based on the results of this inspection, which are documented in the enclosed report, the NRC was not able to conclude that the actions taken were adequate to meet the inspection objectives. Therefore, additional inspection will be performed to continue this review under Inspection Procedure 92723 upon notification of your readiness. The additional Severity Level IV violation documented in the enclosed report, which is also in the area of impeding the regulatory process, will be included in the scope of this traditional enforcement follow-up inspection.

If you contest the violation or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Grand Gulf. If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Grand Gulf.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Cale H. Young, Acting Chief Reactor Project Branch C Division of Reactor Projects Docket No. 05000416 License No. NPF-29

Enclosure:

Inspection Report 05000416/2019002 w/attachment: Request for Information

Inspection Report

Docket Number: 05000416 License Number: NPF-29 Report Number: 05000416/2019002 Enterprise Identifier: I-2019-002-0008 Licensee: Entergy Operations, Inc.

Facility: Grand Gulf Nuclear Station Location: Port Gibson, MS Inspection Dates: April 1, 2019 to June 30, 2019 Inspectors: L. Carson, Senior Health Physicist N. Day, Resident Inspector D. Dodson, Senior Resident Inspector P. Elkmann, Senior Emergency Preparedness Inspect S. Hedger, Emergency Preparedness Inspector W. Sifre, Senior Reactor Inspector T. Steadham, Senior Resident Inspector B. Tharakan, Senior Project Engineer D. Reinert, Ph.D., Reactor Inspector Approved By: Cale H. Young, Acting Chief Reactor Project Branch C Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at the Grand Gulf Nuclear Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations Failure to Update the UFSAR Cornerstone Severity Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71111.05Q NCV 05000416/2019002-01 Closed The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.71(e) for the licensee's failure to update the Updated Final Safety Analysis Report, Section 9A.5.

The inspectors identified over 20 discrepancies between the fire zone descriptions in the Updated Final Safety Analysis Report and the licensee's implementing documents, including Procedure 06-OP-SP64-R-0047, Fire Rated Assembly Visual Inspection, Revision 116. The licensee periodically updated fire protection implementing procedures but did not update the Updated Final Safety Analysis Report, when needed, to reflect those changes.

Failure to Follow Design Control Procedure Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.6] - Design 71152 FIN 05000416/2019002-02 Margins Closed A self-revealed, Green finding was identified when an actuation of the generator protection negative phase sequence trip caused a generator lockout and a reactor scram. The licensee failed to ensure that a recent change in the applicable trip setpoint was managed in accordance with Procedure EN-DC-115, Engineering Change Process, Revision 21. The licensee failed to identify, evaluate, and manage a reduction in operating margin associated with the negative phase sequence trip setpoint. The setpoint was reduced from 9 percent to percent as part of a digital upgrade modification; however, the licensee failed to fully evaluate the change. As a result, routine grid operations above 5 percent negative phase sequence were unmanaged and ultimately led to an unplanned reactor scram.

Additional Tracking Items Type Issue Number Title Report Section Status LER 05000416/2019-001-00 Automatic Reactor 71153 Closed Shutdown due to Activation of Generator Lockout

PLANT STATUS

===Unit 1 began the inspection period at full power. On April 6, 2019, operators reduced power to approximately 56 percent for control rod pattern adjustments. Full power operation resumed on April 8, 2019. On April 9, 2019, to allow for repair of a high pressure feedwater heater leak, power was reduced to approximately 66 percent. Power was increased to approximately 94 percent on April 12, 2019, with the high pressure feedwater heaters isolated. On April 16, 2019, power was reduced to approximately 65 percent to perform power suppression testing. Following repairs to the feedwater heater and power suppression testing, the unit reached full power on April 21, 2019. On May 12, 2019, due to a significant loss of plant service water, operators manually shut down the unit. Following repairs to the plant service water electrical distribution system, the unit was started up on May 19, 2019, and full power was achieved on May 30, 2019. On June 26, 2019, in order to support replacement of a recirculation flow control valve controller, operators reduced power to approximately 96 percent.

On June 27, 2019, the unit reached full power and remained at or near full power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC)2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC2 515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.03)

Main article: IP 71111.01
(1) The inspectors evaluated readiness for impending adverse weather conditions for storms on April 13, 2019, and April 18, 2019;
(2) The inspectors evaluated readiness for impending adverse weather conditions for storms on May 9, 2019.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01)

Main article: IP 71111.04

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

(1) Residual heat removal subsystem A after securing from shutdown cooling for startup on May 18, 2019;
(2) Control room air conditioning B following adjustment on capacity control valve on June 4, 2019;
(3) Recirculation system configuration due to inability to open recirculation flow control valve A on June 19, 2019.

71111.05A - Fire Protection (Annual)

Annual Inspection (IP Section 03.02)

Main article: IP 71111.05A
(1) The inspectors evaluated fire brigade performance to a simulated fire in the Unit 2 switchgear room on May 2, 2019.

71111.05Q - Fire Protection

Quarterly Inspection (IP Section 03.01)

Main article: IP 71111.05Q

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

(1) Fuel pool heat exchanger area, 185 feet auxiliary building, on May 1, 2019;
(2) Auxiliary building steam tunnel on May 15, 2019;
(3) Main control room on June 3, 2019;
(4) Division 1 switchgear room on June 4, 2019;
(5) Division 2 switchgear room on June 4, 2019.

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 02.02a.)

Main article: IP 71111.06

The inspectors evaluated internal flooding mitigation protections in the:

(1) Division 2 switchgear room on May 4, 2019.

71111.07T - Heat Sink Performance Triennial Review (IP Section 02.02)

Main article: IP 71111.07

The inspectors evaluated heat exchanger/sink performance on the following:

(1) Division 2 emergency diesel generator jacket water cooler, Section 02.02b;
(2) Residual heat removal heat exchanger B, Section 02.02b;
(3) High pressure core spray room cooler, Section 02.02c.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

Main article: IP 71111.11Q
(1) The inspectors observed and evaluated licensed operator performance in the control room during a downpower due to a steamleak in the high pressure feedwater heater 6B room on April 3, 2019;
(2) The inspectors observed and evaluated licensed operator performance in the control room during control rod withdrawal to reactor criticality and point of adding heat on May 18, 2019.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)===

(1) The inspectors observed and evaluated operator performance during a simulated

===suppression pool leak and loss of turbine building cooling water with an anticipated transient without scram on April 30, 2019.

71111.12 - Maintenance Effectiveness

Quality Control (IP Section 02.02)

Main article: IP 71111.12

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

(1) Standby service water system on April 12, 2019.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01)

Main article: IP 71111.13

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

(1) Loading of Trinuke filters into cask washdown pit on April 1, 2019;
(2) High pressure core spray availability during the pump high pressure bypass surveillance on May 6, 2019;
(3) Protected system lineup with residual heat removal A in shutdown cooling on May 12, 2019;
(4) Plant service water pump power line insulator installation on May 16, 2019;
(5) Maintenance risk management during high grid demand conditions and Midcontinent Independent System Operator conservative operations declaration on June 4, 2019;
(6) Maintenance work control with plant service water pump D out of service on June 17, 2019.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 02.02)

Main article: IP 71111.15

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Operability of standby service water A with indications of pipe wall thinning, Condition Report CR-GGN-2019-02975 on April 11, 2019;
(2) Operability of Division 1 emergency diesel generator due to loose lube oil heat exchanger bolts, Condition Reports CR-GGN-2019-03256 and CR-GGN-2019-03354 on April 26, 2019;
(3) Operability of residual heat removal B due to minimum flow valve response time, Condition Report CR-GGN-2019-03679 on May 7, 2019;
(4) Equipment qualification of outbound main steam line B drain valve due to exposed cable, Condition Reports CR-GGN-2019-03972 on May 17, 2019.

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

Main article: IP 71111.18

The inspectors evaluated the following temporary or permanent modifications:

(1) Fire rated assembly visual inspection Procedure 06-OP-SP64-R-0047 revisions on April 1, 2019.

71111.19 - Post-Maintenance Testing

Post Maintenance Test Sample (IP Section 03.01)

Main article: IP 71111.19

The inspectors evaluated the following post maintenance tests:

(1) Work Order 514019 to replace water accumulator for HCU 48-25 on April 6, 2019;
(2) Work Order 523523 to replace standby service water sparger C piping support on April 24, 2019;
(3) Troubleshooting replacement via CR-GGN-2019-03565, emergent replacement of Division 2 emergency diesel generator jacket water heater breaker on May 3, 2019;
(4) Work Order 450109 to install insulators on the plant service water electrical distribution overhead power lines on May 17, 2019;
(5) Work Order 524662 to replace solenoid and shuttle valve on outboard main steam isolation valve A on May 16, 2019;
(6) Work Order 522779 to adjust capacity control valve on June 17, 2019;
(7) Work Order 52871685 to inspect/clean inline suction filter media on June 17, 2019;
(8) Work Order 526901 to replace controller for recirculation system flow control valve A on June 24, 2019.

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01)

Main article: IP 71111.20
(1) The inspectors evaluated forced shutdown outage inspection activities on May 12, 2019.

71111.22 - Surveillance Testing

===The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)===

Main article: IP 71111.22
(1) Work Order 52860862, high pressure core spray emergency diesel generator monthly functional test, on April 9, 2019;
(2) Work Order 52758695, Division 1 emergency diesel generator crankshaft deflection and thrust bearing test, on April 22, 2019;
(3) Turbine mechanical overspeed operability test per Procedure 06-OP-1N32-V-0002 on May 1, 2019.

71114.01 - Exercise Evaluation

Inspection Review (IP Section 02.01-02.11)

Main article: IP 71114.01

The inspectors reviewed licensee drill and exercise performance between April 2017 and February 2019 and observed emergency response performance during the biennial emergency preparedness exercise conducted March 13, 2019. The inspectors also observed emergency response organization performance during a May 9, 2019, Operations Support Center drill, which was conducted because drill control issues prevented some key emergency response organization skills from being demonstrated during the March 2019 exercise. The inspectors participated in post-exercise public meetings conducted by Federal Emergency Management Agency (FEMA) Region VI on March 14, 2019, in Tensas Parish, Louisiana, and by FEMA Region IV on March 15, 2019, in Claiborne County, Mississippi.

(1) The March 13, 2019, exercise scenario simulated a tornado striking the plant switchyard, a failed emergency diesel generator, reactor coolant leakage into the drywell, and a unisolable steam leak on the reactor core isolation cooling system turbine.

RADIATION SAFETY

71124.02 - Occupational ALARA Planning and Controls

Radiological Work Planning (IP Section 02.01)

Main article: IP 71124.02

The inspectors evaluated the licensees radiological work planning.

(1) The inspectors evaluated the licensees radiological work planning by reviewing the following activities:
  • RWP 2018-1400; RP/Decon Support for Refuel Floor;
  • RWP 2018-1403: Rx Vessel Disassembly & Re-Assembly;
  • RWP 2018-1511: General Maintenance in the Drywell RF21;
  • RWP 2018-1513: AOV/MOV Valve Work in the Drywell;
  • RWP 2018-1902: Ops Rounds; Surveillances, Tagouts and Tours;
  • RWP 2018-1904: General Maintenance Activities & Support;
  • RWP 2018-1908: AOV/MOV Program Valve Work, Votes, & Viper Test.

Verification of Dose Estimates and Exposure Tracking Systems (IP Section 02.02) (1 Sample)===

The inspectors evaluated dose estimates and exposure tracking.

===(1) The inspectors evaluated dose estimates and exposure tracking. The inspectors reviewed the following as low as reasonably achievable planning documents:

  • RWP 2018-1400; RP/Decon Support for Refuel Floor;
  • RWP 2018-1403: Rx Vessel Disassembly & Re-Assembly;
  • RWP 2018-1511: General Maintenance in the Drywell RF21;
  • RWP 2018-1513: AOV/MOV Valve Work in the Drywell;
  • RWP 2018-1902: Ops Rounds; Surveillances, Tagouts and Tours;
  • RWP 2018-1904: General Maintenance Activities & Support;
  • RWP 2018-1908: AOV/MOV Program Valve Work, Votes, & Viper Test.

Additionally, the inspectors reviewed the following radiological outcome evaluations:

  • RWP 2018-1400; RP/Decon Support for Refuel Floor;
  • RWP 2018-1403: Rx Vessel Disassembly & Re-Assembly;
  • RWP 2018-1511: General Maintenance in the Drywell RF21;
  • RWP 2018-1513: AOV/MOV Valve Work in the Drywell;
  • RWP 2018-1902: Ops Rounds; Surveillances, Tagouts and Tours;
  • RWP 2018-1904: General Maintenance Activities & Support;
  • RWP 2018-1908: AOV/MOV Program Valve Work, Votes, & Viper Test.

71124.04 - Occupational Dose Assessment

External Dosimetry (IP Section 02.02)

Main article: IP 71124.04
(1) The inspectors evaluated the external dosimetry program implementation.

Internal Dosimetry (IP Section 02.03) (1 Sample)===

The inspectors evaluated the internal dosimetry program implementation.

===(1) The inspectors evaluated the internal dosimetry program implementation. The inspectors reviewed the following:

Whole Body Counts (WBCs)

  • WBC No. 33580 04/23/18
  • WBC No. 33201 04/06/19
  • WBC No. 33043 04/12/18
  • WBC No. 32447 05/04/18 In-Vitro Internal Monitoring
  • In general, there were no in-vitro internal monitoring at Grand Gulf Nuclear Station from 2018 to 2019. However, in May 2018, one personnel contamination event resulted in WBCs with an assigned internal dose, and a diver provided a urine sample for tritium analysis.

Dose Assessments Performed Using Air Sampling and Derived Air Concentration-(DAC) Hour Monitoring

  • During 2018 and as of June 5, 2019, Grand Gulf Nuclear Station has not needed to perform dose assessments using air sampling and DAC-hour monitoring.

Source Term Categorization (IP Section 02.01) (1 Sample)===

(1) The inspectors evaluated the licensees characterization of the source term and use

===of scaling factors for the use of hard-to-detect radionuclide activity.

Special Dosimetric Situations (IP Section 02.04) (1 Sample)===

The inspectors evaluated the following special dosimetric situation:

===(1) The inspectors evaluated special dosimetric situations. The inspectors reviewed the following:

Declared Pregnant Workers

  • There were two declared pregnant workers at Grand Gulf Nuclear Station in 2018 and four declared pregnant workers as of June 5, 2019.

Effective Dose Equivalent Exposures (EDEX)

  • EDEX multi-package No. MP374
  • EDEX multi-package No. MP367
  • EDEX multi-package No. MP366
  • EDEX multi-package No. MP457
  • EDEX multi-package No. MP437 Shallow Dose Equivalent
  • During 2018 and as of June 5, 2019, Grand Gulf Nuclear Station has not needed to have any shallow-dose equivalent assessments performed.

Neutron Dose Assessment

  • At Grand Gulf Nuclear Station, Landauer CR-39 dosimetry is used that are sensitive to fast neutrons and thermal neutrons. However, from 2018 to June 5, 2019, there have been no documented neutron exposures on Grand Gulf Nuclear Stations doses of legal record (DLRs); the lower limit of detection (LLD) is 40 mR.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) ===

Main article: IP 71151
(1) January 1, 2018 - March 31, 2019 IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)===
(1) January 1, 2018 - March 31, 2019

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)

(1) April 1, 2018 - March 31, 2019

===71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03)

Main article: IP 71152

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

(1) Condition Report CR-GGN-2004-00786, corrosion on emergency diesel generator jacket cooling service water piping, on April 1, 2019;
(2) Condition Report CR-GGN-2019-01504, automatic reactor scram due to generator lockout, on May 30, 2019; Semiannual Trend Review (IP Section 02.02) (1 Sample)===
(1) The inspectors reviewed the licensees corrective action program and maintenance

===program to identify trends that could be indicative of a more significant safety concern. The inspectors noted that for some work tasks, the work instructions contained in the work authorizing document (such as a work order) contained minimal instructions on how to accomplish the intended task. As a result, craft personnel had to either identify the relevant procedures to use or rely heavily on skill-of-the-craft.

While no findings were identified, the inspectors were concerned that the lack of thorough work instructions could contribute to human performance errors. Examples of work orders that the inspectors had concerns with include Work Order 52754394 and 00522779 as well as Condition Reports CR-GGN-2019-00202, 02092, 02399,

===02639, and 04601.

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01) ===

Main article: IP 02639
(1) The inspectors evaluated the licensee's SCRAM response to a partial loss of plant service water on May 12, 2019.

Event Report (IP Section 03.02) (1 Sample)===

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000416/2019-001-00, Automatic Reactor Shutdown due to Activation of Generator Lockout, (ADAMS Accession No. ML19112A058). As documented in the inspection results section below, the inspectors identified a Green finding associated with this event for the licensees failure to follow the station procedures for design control. No additional findings were identified as a result of reviewing this LER. The inspectors also concluded that no violation of NRC requirements occurred.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

92723 - Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period

Main article: IP 92723

From December 9, 2016, through February 7, 2019, the NRC issued 10 Severity Level IV traditional enforcement violations associated with impeding the regulatory process. These violations, which are listed below, were issued in the following NRC Inspection Reports:

(1) Failure to Obtain NRC Approval for Changes to the Reactor Protection System, NRC-identified NCV 05000416/2016007-02;
(2) Failure to Obtain NRC Approval for Changes to Diesel Generator Trips and Flood Mitigation Strategy, NRC-identified NCV 05000416/2016007-03;
(3) Failure to Evaluate Delaying Inspection of Diesel Fuel Oil Storage Tank, NRC-identified NCV 05000416/2016007-04;
(4) Failure to submit an annual effluent report in accordance with 10 CFR 72.44(d)(3);

licensee-identified NCV documented in Inspection Report 05000416/2017002;

(5) Failure to report the results of the visual inspections of all accessible, susceptible locations of the steam dryer to the NRC staff within 60 days following startup in accordance with License Condition 2.C(46)(f), licensee-identified NCV documented in Inspection Report 05000416/2017002;
(6) Failure to submit a long-term steam dryer inspection plan based on industry operating experience along with the baseline inspection results for NRC review and approval in accordance with License Condition 2.C(46)(g), licensee-identified NCV documented in Inspection Report 05000416/2017002;
(7) Failure to notify the NRC within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the occurrence of any event or condition that resulted in actuation of the reactor protection system when the reactor was critical in accordance with 10 CFR 50.72(b)(2)(iv)(B), licensee-identified NCV documented in Inspection Report 05000416/2017002;
(8) Failure to Update the Final Safety Analysis Report, NRC-identified NCV 05000416/2017007-04;
(9) Failure to make a timely event report for an event or condition that could have prevented fulfillment of a safety function (accident mitigation), licensee-identified NCV documented in Inspection Report 05000416/2018001;
(10) Failure to Update the Updated Final Safety Analysis Report, NRC-identified NCV 05000416/2018004-01.

In April 2019 the inspectors performed Inspection Procedure 92723, Follow-up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period. The inspectors reviewed the licensees cause evaluations and corrective actions associated with these issues in order to determine whether the licensees actions met the Inspection Procedure 92723 inspection objectives, which include:

(1) providing assurance that the cause(s) of multiple Severity Level IV traditional enforcement violations are understood by the licensee;
(2) providing assurance that the extent of condition and extent of cause of multiple Severity Level IV traditional enforcement violations are identified; and
(3) providing assurance that licensee corrective actions to traditional enforcement violations are sufficient to address the cause(s).

INSPECTION RESULTS

Observation: Follow-up Inspection for Three or More Severity Level IV 92723 Traditional Enforcement Violations in the Same Area in a 12-Month Period Background The inspectors noted that from January 1 to December 31, 2013, the NRC issued three Severity Level IV traditional enforcement violations associated with impeding the regulatory process, as documented in Annual Assessment Letter 05000416/2013001 (ADAMS Accession No. ML14063A338), dated March 4, 2014. Inspection Procedure 92723 was performed in response to four Severity Level IV traditional enforcement violations, as documented in Inspection Report 05000416/2014005 (ADAMS Accession No. ML15033A479), dated February 2, 2015. These violations involved accuracy and completeness of the Updated Final Safety Analysis Report, accuracy and completeness of information in the license renewal process, failure to report changes to the emergency plan, and failure to obtain a license amendment as required.

The inspectors also noted that from January 1 to December 31, 2015, the NRC issued seven Severity Level IV traditional enforcement violations associated with impeding the regulatory process, as documented in Annual Assessment Letter 05000416/2015006 (ADAMS Accession No. ML16061A361), dated March 2, 2016. Inspection Procedure 92723 was again performed in response to these Severity level IV traditional enforcement violations, as documented in NRC Inspection Report 05000416/2016003 (ADAMS Accession No. ML16315A372), dated November 10, 2016. These violations involved two failures to update the Final Safety Analysis Report; a failure to maintain a safety-related cable tray overfill analysis record; an incomplete and inaccurate response to NRC Bulletin 88-04; a failure to obtain a license amendment; and two failures to make required event notifications or reports.

Considering these facts, the inspectors sought to understand why failures to update the Final Safety Analysis Report, failures to make required reports, and failures to obtain license amendments were issues that have continued to be identified and documented as recently as 2019.

Licensee Evaluation The inspectors reviewed the licensees collective evaluations (completed at the Condition Analysis level) associated with the 10 CFR 50.59 issues and reporting issues, which included 10 CFR 50.71(e) and reporting issues. The inspectors also reviewed individual/combined evaluations associated with each of the 10 non-cited violations. The inspectors were not able to review in detail the latest revisions of the collective evaluation associated with Condition Report CR-GGN-2019-01002 (associated with 50.59 issues) and the adverse condition analysis associated with Condition Report CR-GGN-2018-01595 (associated with a late 8-hour notification) because preliminary versions of the evaluations were provided during the inspection. Evaluations reviewed included:

  • CR-GGN-2019-01002, 50.59 Evaluations not Conducted as Required, which evaluated the causes of 10 CFR 50.59 related violations (three issues with four total examples). CR-GGN-2017-01483 had previously been completed to address this group of issues. The individual issues included within this collective evaluation were evaluated by the following cause evaluations:

1. CR-GGN-2019-01007, dated March 14, 2019, which revised the licensees evaluations associated with CR-GGN-2016-09757 (two revisions); these cause evaluations were associated with violation (3), as listed above.

2. CR-GGN-2019-01185, dated March 20, 2019, which revised the licensees evaluations associated with CR-GGN-2016-08298 (two revisions); these cause evaluations were associated with violations

(1) and (2), as listed above.
  • CR-GGN-2019-01003, Failure to Submit Reports to the NRC, which evaluated the causes of failures to make reports to the NRC (five issues/examples) and failures to update the Final Safety Analysis Report (two issues with four total examples).

CR-GGN-2017-07970 had previously been completed to address this group of issues.

The individual issues included within this collective evaluation were evaluated by the following cause evaluations:

1. CR-GGN-2017-03404, dated May 22, 2017, and later revised on March 1, 2019; this cause evaluation was associated with violations (5)and (6), as listed above 2. CR-GGN-2017-12284, dated February 20, 2018, and later revised on March 1, 2019; this cause evaluation was associated with violation (8), as listed above 3. CR-GGN-2018-01595, dated March 27, 2018, and later revised March 1, 2019; this cause evaluation was associated with violation (9), as listed above 4. CR-GGN-2019-01047, dated March 22, 2019; this cause evaluation was associated with violation (10), as listed above 5. CR-GGN-2019-01390, dated March 1, 2019, which elevated the level of evaluation of CR-GGN-2017-03092, which was documented on March 27, 2017, at the C significance level; these were associated with violation (4), as listed above 6. CR-GGN-2019-01391, dated March 14, 2019, which elevated the level of evaluation of CR-GGN-2017-03331, which was documented on April 4, 2017, at the C significance level; these were associated with violation (7), as listed above Assessment Considering all the cause evaluations and relevant condition reports the inspectors identified 16 examples where the responsible manager failed to ensure all available and relevant information was acquired by reviews of pertinent industry events in accordance with step 4[2]e of Procedure EN-LI-118, Cause Evaluation Process, Revision 23. The licensee documented Condition Reports CR-GGN-2019-02684, CR-GGN-2019-02716, CR-GGN-2019-02733 to address these concerns. These examples included:

  • Failure to review 17 relevant condition reports in the relevant internal operating experience section of the adverse condition analysis associated with CR-GGN-2017-12284
  • The inspectors identified that Attachment 9.2, UFSAR Change Process Flow Chart, of Procedure EN-LI-113-01, Updated Final Safety Analysis Report Change Process, Revision 3, included numerous incorrect procedure step references. The licensee documented CR-GGN-2019-02674 to address the concern.
  • The inspectors identified that a corrective action was not implemented to address a missed barrier identified as a factor in adverse condition analysis CR-GGN-2018-01595. This was associated with providing a procedure barrier to operators and licensing personnel when completing reportability evaluations. The licensee initiated CR-GGN-2019-02690 to address this observation.
  • The licensee initiated CR-GGN-2019-02732 in response to the inspectors' questions on licensing basis document change request (LBDCR)/Updated Final Safety Analysis Report tracking not being defined.

Conclusions The inspectors could not conclude that the inspection objectives were met because substantially relevant operating experience was not adequately considered and evaluated by the licensee when determining causes, extent of conditions, extent of causes, or corrective actions. Specifically, the inspectors identified that the conditions, scope, and causes associated with the two main collective evaluations and the previously performed root cause CR-GGN-2015-05057, which was associated with previous examples of incorrect maintenance of design and license basis documents, revealed substantive commonalities involving implementation and control of design change and license basis document changes; however, the CR-GGN-2015-05057 root cause analysis was not appropriately evaluated as relevant operating experience in the current evaluations. Corrective actions to prevent recurrence of root causes would be expected to prevent recurrence of the same performance deficiency.

Additionally, the licensee continues to identify LBDCR performance issues. Specifically, engineering changes with LBDCRs are still being evaluated to ensure all LBDCRs from 2000-2013 are appropriately tracked and coordinated. Also, a trend of incorrectly implemented LBDCRs during a software conversion is still being evaluated to determine causes and to ensure that conversion issues have been identified.

Finally, the inspectors could not conclude that the inspection objectives were met because the collective evaluations and additional causal analyses were being revised as of the completion of the inspection. As a result of this inspection, the licensee voluntarily determined that the conclusions of its collective evaluations needed to be reconsidered. The licensee planned to re-evaluate and revise its collective evaluations (CR-GGN-2019-01002 and CR-GGN-2019-01003) associated with the 10 violations and review the previous CR-GGN-2015-05057 root cause analysis to ensure that the causes, extent of conditions, extent of causes, and corrective actions were adequate. The licensee initiated CR-GGN-2019-02717 to document that adverse condition analyses associated with CR-GGN-2019-01002 and CR-GGN-2019-01003 did not adequately evaluate issues with configuration control of design and licensing basis documentation. The licensee informed the inspectors that a cause evaluation will be completed to address this concern.

Failure to Update the UFSAR Cornerstone Severity Cross-Cutting Report Aspect Section Not Severity Level IV Not 71111.05Q Applicable NCV 05000416/2019002-01 Applicable Closed The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.71(e) for the licensee's failure to update the Updated Final Safety Analysis Report, Section 9A.5.

The inspectors identified over 20 discrepancies between the fire zone description in the Updated Final Safety Analysis Report and the licensee's implementing documents, including Procedure 06-OP-SP64-R-0047, Fire Rated Assembly Visual Inspection, Revision 116. The licensee periodically updated fire protection implementing procedures but did not update the Updated Final Safety Analysis Report, when needed, to reflect those changes.

Description:

While reviewing the fire rated assembly visual inspection criteria contained in Procedure 06-OP-SP64-R-0047, the inspectors identified discrepancies between the procedure and the Updated Final Safety Analysis Report (UFSAR), Section 9A.5.

Specifically, the inspectors compared the fire barrier descriptions of 125 out of 266 fire zones described in UFSAR, Section 9A.5, with the surveillance requirements contained in Procedure 06-OP-SP64-R-0047. From this review, the inspectors identified discrepancies with 24 fire zones. The inspectors found that in some instances, the procedure classified various barriers as 3-hour fire barriers required by the technical requirements manual, while the UFSAR described them as non-rated barriers.

For example, Procedure 06-OP-SP64-R-0047 described the ceiling as a fire-rated barrier for Fire Zones 1A115 and 1A116 that was required to remain functional per the technical requirements manual. Fire Zones 1A115 and 1A116 both included the ceiling as a required barrier in the procedure because the ceiling interfaces with a fire zone in a different fire area; however, the UFSAR descriptions for Fire Zones 1A115 and 1A116 both stated that the ceiling is a non-rated barrier in those fire zones. Likewise, the west walls for Fire Zones 1A130 and 1A131 separated these zones from a different fire area and were described as required fire barriers in Procedure 06-OP-SP64-R-0047; however, the UFSAR stated that these walls were not rated barriers.

While reviewing the revision history of this procedure, the inspectors learned that the licensee had previously identified numerous discrepancies with this procedure and documented the issues in Condition Report CR-GGN-2000-00585 on April 28, 2000. Corrective actions included revising the procedure to reflect the fire barriers required to remain operable per Technical Requirements Manual 6.2.8, but the licensee did not ensure that the UFSAR was revised to remain consistent with the procedure.

Corrective Actions: The licensee performed an apparent cause analysis and initiated a review to identify all discrepancies between the UFSAR and Procedure 06-OP-SP64-R-0047.

Corrective actions planned included evaluating all the identified discrepancies and revising the procedure and/or the UFSAR as warranted by the nature of each discrepancy.

Corrective Action References: The licensee entered the issue into their corrective action program as Condition Report CR-GGN-2019-02719, 2019-02427, and 2019-02471

Performance Assessment:

The inspectors determined this violation was associated with a minor performance deficiency.

Enforcement:

The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter noncompliance.

Severity: This violation was determined to be Severity Level IV in accordance with the NRC Enforcement Policy, Example 6.1.d.3. The inspectors determined that there was a material impact on safety or licensed activities because if utilized, lack of up-to-date information in the UFSAR could have a nonconservative impact on design analyses.

Violation: As required by 10 CFR 50.71, Maintenance of Records, Making of Reports, Section (e), 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. Contrary to the above, since April 28, 2000, the licensee did not update the Final Safety Analysis Report to assure that the information included in the report contains the latest information developed.

Specifically, the licensee failed to update the Final Safety Analysis Report with the most up-to-date fire barrier descriptions both during and after the resolution of Condition Report CR-GGN-2000-00585.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Follow Design Control Procedure Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.6] - Design 71152 FIN 05000416/2019002-02 Margins Closed A self-revealed, Green finding was identified when an actuation of the generator protection negative phase sequence trip caused a generator lockout and a reactor scram. The licensee failed to ensure that a recent change in the applicable trip setpoint was managed in accordance with Procedure EN-DC-115, Engineering Change Process, Revision 21. The licensee failed to identify, evaluate, and manage a reduction in operating margin associated with the negative phase sequence trip setpoint. The setpoint was reduced from 9 percent to 5 percent as part of a digital upgrade modification; however, the licensee failed to fully evaluate the change. As a result, routine grid operations above 5 percent negative phase sequence were unmanaged and ultimately led to an unplanned reactor scram.

Description:

On February 23, 2019, an automatic reactor scram occurred as a result of a turbine trip. The licensee determined that a generator lockout caused the turbine trip and that the generator lockout was caused when the generator negative phase sequence protection portion of the generator protective relays 1N41M711A/B and 1N41M712A/B actuated. The relays actuated when the generator phase unbalance exceeded the trip setpoint of 5 percent.

The licensee entered the issue in their corrective action program as Condition Report CR-GGN-2019-01504.

In February 1981, the generator negative phase sequence setpoint was determined to be 9 percent as documented in Calculation PR0204, Revision 0. Although the calculation determined that a setpoint of 5 percent was acceptable, physical device limitations precluded the setpoint to be set any lower than 9 percent. This setpoint was revisited on May 5, 2012, when Revision 2 to Calculation PR0204 was issued as part of Engineering Change (EC) 20838. As part of this calculation, the trip threshold was retained at 9 percent based on industry guidance and previous settings.

In May 2016, the licensee initiated a project to upgrade the analog generator protective relaying scheme to digital. The licensee hired a contractor to perform the engineering change as documented in EC 67304 using the licensees change control program and procedures.

As a part of this modification, Calculation EC-N1N41-17001 determined that the negative phase sequence trip setpoint should be changed to 5 percent; however, there was no discussion or evaluation on the effects that reducing the setpoint from 9 percent to 5 percent would have on operating margin. Had the licensee thoroughly reviewed the setpoint change, operating experience available at the time would have identified that the local electrical grid is routinely operated at greater than 5 percent unbalance. Such a review would have prompted a more thorough evaluation of the impacts of lowering the setpoint to a value that could routinely be exceeded during normal power operations.

At the time EC 67304 was issued, licensee Procedure EN-DC-115, "Engineering Change Process," Revision 21, required that the responsible engineer describe the impact on plant operating margins. One of the impact screening criteria in Attachment 9.4 of Procedure EN-DC-115 included, Change protective relay settings, generator exciter or Automatic Voltage Regulator (AVR) settings. Although this box was checked in conjunction with the licensee's implementation of EC 67304, the inspectors could find neither an evaluation for the effects of changing this setpoint nor an evaluation for the effects of a reduced operating margin as a result of the setpoint reduction.

The licensee performed a root cause evaluation and concluded that the root cause was that engineering leadership did not ensure standards and expectations for adherence to a systematic and rigorous configuration change process were met to maintain operating margins and achieve an acceptable result to prevent an unplanned scram. Contributing causes were determined to be the failure of electrical design engineers to follow the configuration control process as described in Procedure EN-DC-115.

The licensee determined, based on previous operating experience and equipment limitations, that a setpoint of 9 percent was acceptable to provide an adequate level of protection to the generator equipment while still maintaining an acceptable operational margin to prevent spurious trips on generator negative phase sequence from normal grid operating conditions.

As a result, the licensee issued EC 81801 to change the trip setpoint back to 9 percent, which was completed under Work Order 00519151 on February 27, 2019.

Corrective Actions: Licensee corrective actions included performing a root cause evaluation, which resulted in procedure changes and training of applicable engineering staff. The negative phase setpoint was changed back to 9 percent.

Corrective Action References: The licensee entered the issue into their corrective action program as Condition Report CR-GGN-2019-01504.

Performance Assessment:

Performance Deficiency: The licensees failure to follow the configuration control process as described in licensee Procedure EN-DC-115 is a performance deficiency. Because the licensee did not effectively evaluate the impact of reducing generator protective relay setpoints, operating margins were not managed as required by Procedure EN-DC-115.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Initiating Events cornerstone. Specifically, the performance deficiency contributed to an unplanned automatic reactor scram.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, because the finding only caused a reactor trip but not the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition, the finding was determined to be of very low safety significance (Green).

Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense-in-depth, and safety related equipment. Specifically, the licensee failed to carefully guard margins and did not employ a systematic and rigorous process to control operational margins when developing, reviewing, approving, and implementing EC 67304.

Enforcement:

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

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On July 11, 2019, the inspectors presented the integrated inspection results to Mr. E. Larson, Site Vice President, and other members of the licensee staff.
  • On March 15, 2019, the inspectors presented the onsite inspection week debrief to Mr. T. Burnett, Director, Corporate Emergency Preparedness, Entergy, and other members of the licensee staff.
  • On April 25, 2019, the inspectors presented the Inspection Procedure 92723 results to Mr. E. Larson, Site Vice President, and other members of the licensee staff.
  • On May 30, 2019, the inspectors presented the emergency preparedness exercise inspection results to Mr. E. Larson, Site Vice President, and other members of the licensee staff.
  • On June 7, 2019, the inspectors presented the radiation protection inspection results to Mr. E. Larson, Site Vice President, and other members of the licensee staff.
  • On July 1, 2019, the inspectors presented the heat sink performance inspection results to Mr. M. Lingenfelter, Director Engineering, and other members of the licensee staff.

THIRD PARTY REVIEWS Inspectors reviewed Institute on Nuclear Power Operations reports that were issued during the inspection period.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.07T Calculations 707752 Air Handling Unit, Pump Room Cooler - Vane Axial Fan A

MC-Q1E12- Water Hammer Analysis of the RHR System 0

10001

MC-Q1P41- GGNS Standby Service Water Ultimate Heat Sink Thirty Day 0

11001 Performance at EPU

MC-Q1P41- SSW Dynamic Venting (CR-GGN-2011-8690 and LO-GLO- 0

2001 2011-0055)

MC-Q1P41- Evaluation of Low SSW (P41) Flow to the Standby Diesel 1

215 Jacket Water Cooler

MC-Q1P41- Determination of Minimum Allowable SSW Flows (LOCA 14

97020 Lineup) to Safety Related Heat Exchangers

MC-Q1P41- Standby Service Water Flow Evaluation 0

99031

Drawings C-6024 Location of Settlement Markers and Permanent Bench 1

Marks, Unit 1

E12-B001 Envelope heat Exchanger - Residual Heat Removal System 1

Engineering 0000040821 Justification of Plugging 10% Tubes on the Diesel Generator 11/02/2012

Changes Jacket Water Cooler (1P75B004A/B) for CR-GGN-2012-

2060

0000063673 Evaluate for Minimum RHR Tube Wall Thickness and 03/21/2016

Maximum Number of Allowed Plugged Tubes

0000081755 Acceptance of Entergy Grand Gulf Failure Analysis Water 02/21/2019

Pipe System Final Report from SI

Miscellaneous 04-1-02-1H13- Alarm Response Instruction Panel NO: 1H13-P864 033

P864

08-S-03-10 Chemistry Sampling Program 056

460000403 Ceramic Cooling Tower Company - Standby Service Water 300

Cooling Towers

460000450 Transamerica Delaval Instruction Manual Volume 1, model 07/17/1980

DSRV-16-4 Diesel Engine/Generator

460000503 Joy Nuclear Non-Containment Axivane Fan Operators 11/22/2002

Handbook

Inspection Type Designation Description or Title Revision or

Procedure Date

CCE 202006- Commitment Change Evaluation - AECM-90/007 05/25/2004

0002

CCE 202006- Commitment Change Evaluation - AECM-90/007 05/02/2006

0002

CCE 202006- Commitment Change Evaluation - AECM-90/007 10/19/2006

0004

GEK-83280 Operation and Maintenance Instructions - Residual Heat 10/26/2005

Removal System Heat Exchangers

GNRO- Report of 10CFR50.59 Evaluations and Commitment 05/19/2008

2008/00044 Changes April 1, 2007 through March 31, 2008

NDE Reports 52749571.01 Eddy Current Inspection of DGJW P75B004B 02/25/2019

2749571.01 Eddy Current Inspection of DGJW P75B004B 02/05/2019

BOP-UT-15-001 UT Thickness Examination, 3/4-HBC-358, MIC-101B-116- 04/27/2015

059

BOP-UT-15-004 UT Thickness Examination, HBC-155 Pipping, MIC-1061B- 10/25/2015

098-101

BOP-UT-15-005 UT Thickness Examination, 3/4 HBC-154 Pipping, MIC- 07/01/2015

1061B-092-022

BOP-UT-15-006 UT Thickness Examination, 3/4 HBD-252 Drain Pipping, MIC- 07/01/2015

1061B-093-103

BOP-UT-15-010 UT Thickness Examination, Line 2 HBC-94, MIC-1061C- 11/25/2015

075-024

BOP-UT-15-011 UT Thickness Examination, Line 1 HBC-96, MIC-1061C- 10/25/2015

161-005

BOP-UT-15-014 UT Thickness Examination, 3/4 HBC-087, MIC-1061B-314- 10/25/2015

095

BOP-UT-15-018 UT Thickness Examination, 4 HBC-173, MIC-M1358K-057 10/25/2015

BOP-UT-19-001 UT Thickness Examination, 10 HBC-87 Down Stream of 01/07/2019

1P41F023A, 1P41 Standby Service Water

BOP-UT-19-008 UT Thickness Examination, 10-HBC-86-Elbow Downstream 04/25/2019

of 1P41F018A, 1P41 Standby Service Water

BOP-VE-16-032 Eddy Current Examination, RHR Heatexchanger 03/02/2016

BOP-VE-16-033 Eddy Current Examination, RHR Heatexchanger 03/02/2016

Inspection Type Designation Description or Title Revision or

Procedure Date

Operability 06-OP-1P41-Q- Standby Service Water Loop A Valve and Pump Operability 128

Evaluations 0004 Test

Procedures 04-1-01-P41-1 Standby Service Water System 146

04-1-02-1H13- Alarm Response Instruction Panel No.: 1H13-P601 166

P601

04-1-02-1H13- Alarm Response Instruction, Panel No. 1H13-P870 156

P870

04-1-02-1H13- Alarm Response Instruction Panel NO: 1H13-P870 156

P870

05-1-02-III-1 Inadequate Decay Heat Removal 046

06-OP-1P41-O- Standby Service Water Loop Siphon Line Operability Test 102

0001

06-OP-1P41-Q- Standby Service Water Loop B Valve and Pump Operability 125

0005 Test

07-S-07-211 Service Level 1 Coating Assessment 002

08-S-03-14 Chemical Additions to Plant Systems 026

08-S-03-28 SSW Emergency Water Treatment Guide 001

08-S-04-120 Chemistry Evolution at Standby Service Water 017

17-S-03-29 Generic Letter 89-13 Thermal Performance Data Collection 007

and Analysis

CEP-WP-RBMD- Repair of Base Material Defects 002

EN-DC-150 Condition Monitoring of Maintenance Rule Structures 014

EN-DC-184 NRC Generic Letter 89-13 Service Water Program 006

EN-DC-316 Heat Exchanger Performance and Condition Monitoring 011

EN-EP-S-039-G Testing Standard for Safety-Related Heat Exchangers 005

Cooled by Standby Service Water

EN-LI-100 Process Applicability Determination 011

EN-LI-100 Process Applicability Determination 026

EN-LI-101 10 CFR 50.59 Evaluations 009

EN-LI-101 10 CFR 50.59 Evaluations 017

EN-OP-104 Operability Determination Process 016

71114.01 Corrective Action CR-GGN- 2017-001874, 2017-001917, 2017-003233, 2017-003312,

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents 2017-003314, 2017-003687, 2017-003688, 2017-003906,

2017-004066, 2017-004067, 2017-004068, 2017-004133,

2017-006065, 2017-006802, 2017-006839, 2017-008121,

2017-008218, 2017-009814, 2017-010467, 2017-010730,

2017-010737, 2017-011841, 2017-011845, 2017-012598,

2017-012695, 2018-000429, 2018-001636, 2018-002759,

2018-002805, 2018-011059, 2018-011061, 2018-011077,

2018-012401, 2019-000501, 2019-000988, 2019-001023,

2019-001201, 2019-002014, 2019-002075, 2019-002190,

2019-002364, 2019-002369, 2019-002371, 2019-002375,

2019-002494

Drawings E-0300 34.5KV Substations (Units 1&2) Location Plan 2

Miscellaneous Grand Gulf Nuclear Station Emergency Plan 76, 77, 78

GGNS Repair Team Demonstration Controller-Evaluator 5/9/2019

Manual

2018-00221 GGN 2018 November 14 Blue Team ERO Training Drill 12/12/2018

Report

EN-TQ-125 Fire Drill Scenario of 12-2-2018 2/3/2018

GGNS-EP- Onsite Health Physics Drill Report 7/20/2018

2018HPDRILL-A

Procedures 01-S-10-3 Emergency Planning Department Responsibilities 24

10-S-01-1 Activation of the Emergency Plan, Revision 129 3/5/2019

10-S-01-11 Evacuation of Onsite Personnel, Revision 26 10/24/2017

10-S-01-12 Radiological Assessment and Protective Action 11/7/ 2017

Recommendations, Revision 47

10-S-01-17 Emergency Personnel Exposure Control, Revision 19 6/17/2011

10-S-01-20 Administration of Thyroid Blocking Agents, Revision 16 1/7/2015

10-S-01-26 Offsite Emergency Response, Revision 14 10/15/2013

10-S-01-35 Core Damage Assessment, Revision 6 8/9/2012

10-S-01-38 Equipment Important to Emergency Response, Revision 5 5/2/2017

10-S-01-5 Control of Emergency Response Equipment and Facilities, 3/13/2018

Revision 17

10-S-01-6 Notification of Offsite Agencies and Plant On-Call 1/10/2018

Emergency Personnel, Revision 56

Inspection Type Designation Description or Title Revision or

Procedure Date

EN-EP-306 Drills and Exercises, Revision 9 12/14/2017

EN-EP-308 Emergency Planning Critiques, Revision 5 5/11/2017

EN-EP-310 Emergency Response Organization Notification System, 1/17/2019

Revision 7

EN-EP-313 Offsite Dose Assessment Manual using the Unified RASCAL 3/31/2016

Interface, Revision 2

EN-EP-609 Emergency Operations Facility Operations, Revision 6 11/15/2018

EN-EP-610 Technical Support Center Operations, Revision 4 9/27/2017

EN-EP-611 Operations Support Center Operations, Revision 5 9/27/2017

EN-EP-801 Emergency Response Organization, Revision 16 11/30/2018

EN-FAP-EP-013 Emergency Preparedness Program Maintenance, Revision 2 3/29/2018

71124.02 Corrective Action CR-GGN- 2018-00330, 2018-00524, 2018-03376, 2018-03442, 2018-

Documents 03535, 2018-03571, 2018-04065, 2018-04681, 2018-06442,

2018-07122, 2018-08989

Miscellaneous 2017 Annual Radiation Protection Report

RF-21 GGNS Refueling Outage 21: 4/7/18 - 7/19/18, 103 Days 8/2018

Procedures EN-RP-105 Radiation Work Permits 15

EN-RP-110 ALARA Program 14

EN-RP-110-01 ALARA Deferral Initiatives 1

EN-RP-110-02 Elemental Cobalt Sampling 0

EN-RP-110-03 Collective Radiation Exposure Reduction Guidelines 4

EN-RP-110-04 Radiation Protection Risk Assessment Process 7

EN-RP-110-06 Outage Dose Estimating and Tracking 1

Self-Assessments LO-GLO-2018- Pre-NRC Inspection IP71124.02 ALARA Planning & Controls 09/23/18

27

71124.04 Corrective Action CR-GGN- 2018-03246, 2018-04298, 2018-04644, 2018-06062, 2018-

Documents 06432, 2018-06460, 2018-06616, 2019-03504,

Miscellaneous 2018 RBS Dose by Department 12/31/18

2019 RBS Dose by Department 05/30/19

Procedures EN-RP-131 Air Sampling 16

EN-RP-201 Dosimetry Administration 5

EN-RP-202 Personnel Monitoring 5

EN-RP-203 Dose Assessment 10

Inspection Type Designation Description or Title Revision or

Procedure Date

EN-RP-204-01 Effective Dose Equivalent (EDEX) Monitoring 3

EN-RP-205 Prenatal Monitoring 3

EN-RP-206 Dosimeter of Legal Record Quality Assurance 6

EN-RP-208 Whole Body Counting/In-Vitro Bioassay 7

Self-Assessments 2017 2017 Evaluation of Internal Dose Monitoring

2017 On-Site Assessment of Landauer 08/25/17

LO-LGO-0178 Pre-NRC Inspection IP71124.04 Dose Assessment

71152 Calculations EC-N1N41-17001 Generator Protection 0

PR0204 Generator Negative Sequence Protection 2

Corrective Action CR-GGN- 2019-01504

Documents

Engineering EC-20838 GGN EPU Main Generator Replacement

Changes EC-67304 Main Generator and Transformer Relay Protection

EC-81801 Main Generator and Transformer Relay Protection

Procedures EN-DC-115 Engineering Change Process 21

EN-DC-156 Technical and Quality Requirements for Engineering 13

Contracted Services

Work Orders WO 519151

71153 Corrective Action CR-GGN- 2017-12299, 2017-12314,

Documents

Miscellaneous LER 2017-007-00 Engineered Safety Feature System Actuations due to the 2/5/18

Loss of Engineered Safety Features Transformer 11

LER 2017-007-01 Engineered Safety Features System Actuations due to the 12/12/18

Loss of Engineered Safety Features Transformer 11

2723 Corrective Action CR-HQN-2017-1356

Documents CR-WF3-2019-3425

CR-GGN- 2014-03335, 2014-05539, 2015-05057, 2016-08295, 2016-

298, 2016-08327, 2016-08328, 2016-08329, 2016-09755,

2016-09756, 2016-09757, 2017-01483, 2017-03092, 2017-

03101, 2017-03331, 2017-03404, 2017-07970, 2017-09154,

2017-09747, 2017-12284, 2018-01595, 2018-04199, 2019-

232, 2019-00625, 2019-01002, 2019-01003, 2019-01007,

2019-01047, 2019-01179, 2019-01185, 2019-01306, 2019-

01390, 2019-01391, 2019-01916, 2019-01917, 2019-01919,

Inspection Type Designation Description or Title Revision or

Procedure Date

2019-01977, 2019-02077, 2019-02103, 2019-02417, 2019-

2441, 2019-02442, 2019-02458, 2019-02491, 2019-02493,

2019-02674, 2019-02684

Procedures 08-S-08-5 Plant Operations Manual Volume 8 - Environmental 111

Procedure Environmental Reporting

EN-CY-100 Conduct of Chemistry 0

EN-CY-100 Conduct of Chemistry 1

EN-DC-114 Project Management 16

EN-DC-115 Engineering Change Process 26

EN-DC-126 Engineering Calculation Process 8

EN-DC-132 Control of Engineering Documents 8

EN-DC-147 Engineering Reports 7

EN-DC-149 Acceptance of Vendor Documents 14

EN-HU-101 Human Performance Program 20

EN-LI-100 Process Applicability Determination 25

EN-LI-101 10 CFR 50.59 Evaluations 17

EN-LI-102 Corrective Action Program 27

EN-LI-102 Corrective Action Program 28

EN-LI-102 Corrective Action Program 36

EN-LI-103 Operating License Amendments 11

EN-LI-106 NRC Correspondence 19

EN-LI-112 10 CFR 72.48 Evaluations 13

EN-LI-113 Licensing Basis Document Change Process 17

EN-LI-113-01 Updated Final Safety Analysis Report Change Process 3

EN-LI-123 NRC Inspection Support 9

FWKB-CM- Effluent Specialist Workbook 1

EFFLUENT

The following items are requested for the:

Occupational Radiation Safety Inspection

Integrated Report 2019-002

at

Grand Gulf Nuclear Station

(June 3 -6, 2019)

Inspection areas are listed in the attachments below.

Please provide the requested information on or before May 23, 2019

Please submit this information using the same lettering system as below. For example, all contacts and phone numbers for

Inspection Procedure 71124.01 should be in a file/folder titled 1- A, applicable organization charts in file/folder 1- B, etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at least 30 days later than the onsite

inspection dates, so the inspectors will have access to the information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed below, please provide updated lists of

corrective action documents at the entrance meeting. The dates for these lists should range from the end dates of the original lists to

the day of the entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear to be redundant, there is no need to

provide duplicate copies. Enter a note explaining in which file the information can be found.

If you have any questions or comments, please contact Louis Carson at (817)200-1221, Louis.Carson@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995

(44 U.

S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget,

Control Number 3150-0011.

2. Occupational ALARA Planning and Controls (71124.02)

Date of Last Inspection: April 23, 2018

A. List of contacts and telephone numbers for ALARA program personnel

B. Applicable organization charts

C. Copies of audits, self-assessments, and LERs, written since date of last inspection, focusing on ALARA

D. Procedure index for ALARA Program

E. Please provide specific procedures related to the following areas noted below. Additional Specific Procedures may be

requested by number after the inspector reviews the procedure indexes.

1. ALARA Program

2. ALARA Committee

3. Radiation Work Permit Preparation

F. A summary list of corrective action documents (including corporate and sub-tiered systems) written since date of last

inspection, related to the ALARA program. In addition to ALARA, the summary should also address Radiation Work Permit

violations, Electronic Dosimeter Alarms, and RWP Dose Estimates

NOTE: The lists should indicate the significance level of each issue and the search criteria used. Please provide in document

formats which are searchable so that the inspector can perform word searches.

G. List of work activities greater than 1 rem, since date of last inspection

Include original dose estimate and actual dose.

H. Site dose totals and 3-year rolling averages for the past 3 years (based on dose of record)

I. Outline of source term reduction strategy

J. If available, provide a copy of the ALARA outage report for the most recently completed outages for each unit

K. Please provide your most recent Annual ALARA Report.

4. Occupational Dose Assessment (Inspection Procedure 71124.04)

Date of Last Inspection: November 21, 2016

A. List of contacts and telephone numbers for the following areas:

1. Dose Assessment personnel

B. Applicable organization charts

C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs written since date of last inspection,

related to:

1. Occupational Dose Assessment

D. Procedure indexes for the following areas:

1. Occupational Dose Assessment

E. Please provide specific procedures related to the following areas noted below. Additional Specific Procedures will be

requested by number after the inspector reviews the procedure indexes.

1. Radiation Protection Program

2. Radiation Protection Conduct of Operations

3. Personnel Dosimetry Program

4. Radiological Posting and Warning Devices

5. Air Sample Analysis

6. Performance of High Exposure Work

7. Declared Pregnant Worker

8. Bioassay Program

F. List of corrective action documents (including corporate and sub-tiered systems) written since date of last inspection,

associated with:

1. National Voluntary Laboratory Accreditation Program (NVLAP)

2. Dosimetry (TLD/OSL, etc.) problems

3. Electronic alarming dosimeters

4. Bioassays or internally deposited radionuclides or internal dose

5. Neutron dose

NOTE: The lists should indicate the significance level of each issue and the search criteria used. Please provide in document

formats which are searchable so that the inspector can perform word searches.

G. List of positive whole body counts since date of last inspection, names redacted if desired

H. Part 61 analyses/scaling factors

I. The most recent National Voluntary Laboratory Accreditation Program (NVLAP) accreditation report or, if dosimetry is

provided by a vendor, the vendors most recent results

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995

(44 U.

S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget,

Control Number 3150-0011.

ML19226A236

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

By: CYoung Yes No Publicly Available Sensitive NRC-002

OFFICE SRI:DRP/C RI:DRP/C ABC:DRS/EB1 C:DRS/EB2 C:DRS:EB2 TL:DRS/IPAT

NAME TSteadham NDay GGeorge NTaylor GWermer HFreeman

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

DATE 08/12/2019 08/12/2019 08/12/2019 08/13/2019 08/12/2019 08/12/2019

OFFICE C:DRS/RCB C:DNMS/RIB PE/DRP/C SRI/DRP/B SPE/DRP ABD:DRP/C

NAME MHaire GWarnick DProulx DDodson BTharakan CYoung

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

DATE 08/12/2019 08/12/2019 08/12/2019 08/12/2019 08/09/2019 08/14/2019

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