IR 05000416/2017010

Grand Gulf Nuclear Station - NRC Team Inspection Report 05000416/2017010

ML17136A174
Person / Time
Site:	Grand Gulf
Issue date:	05/16/2017
From:	Kozal J W NRC/RGN-IV/DRP/RPB-C
To:	Emily Larson Entergy Operations
JASON KOZAL
References
IR 2017010
Download: ML17136A174 (14)

Text

May 16, 2017

Mr. Eric Larson, Site Vice President Entergy Operations, Inc Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150

SUBJECT: GRAND GULF NUCLEAR STATION - NRC TEAM INSPECTION REPORT 05000416/2017010

Dear Mr. Larson:

On March 10, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Grand Gulf Nuclear Station. On April 27, 2017, the NRC inspectors discussed the results of this inspection with Mr. Greg Hawkins, Director, Regulatory Assurance and Performance Improvement, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report. The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication, Staffing, and Multi-Unit Dose Assessment Plans, your compliance with the Commission's rules and regulations, and your compliance with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel. The NRC inspectors did not identify any findings or violations of more than minor significance associated with this inspection. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/

Jason Kozal, Branch Chief Project Branch C Division of Reactor Projects Docket No. 50-416 License No. NPF-29

Enclosure:

Inspection Report 05000416/2017010 w/

Attachment:

Supplemental Information

SUNSI Review By: JRG/dll ADAMS Yes No Non-Sensitive Sensitive Publicly Available Non-Publicly Available Keyword: NRC-002 OFFICE SPE:DRP/A PE:DRP/A PE:DRP/C RI:DRP/GG BC:DRP/C NAME RAlexander TSullivan MStafford NDay JKozal SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ DATE 04/26/17 05/01/17 04/28/17 05/02/17 5/16/17 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000416 License: NPF-29 Report: 05000416/2017010 Licensee: Entergy Operations, Inc. Facility: Grand Gulf Nuclear Station, Unit 1 Location: 7003 Baldhill Road Port Gibson, MS 39150 Dates: March 6 - 10, 2017 Inspectors: R. Alexander, Sr. Project Engineer (Team Leader) N. Day, Resident Inspector M. Stafford, Project Engineer T. Sullivan, Project Engineer Approved By: Jason Kozal Chief, Project Branch C Division of Reactor Projects 2

SUMMARY

IR 05000416/2017010; 03/06/2017 - 03/10/2017; Grand Gulf Nuclear Station; Temporary Instruction 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, issued December 23, 2015.

The inspection activities described in this report were performed between March 6 and March 10, 1017, by a resident inspector at Grand Gulf Nuclear Station and three inspectors from the Region IV office. No findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6.

A. NRC-Identified and Self-Revealing Findings

None

B. Licensee-Identified Violations

None 3

REPORT DETAILS

4. Other Activities

4OA5 Other Activities (TI 2515/191) The objective of Temporary Instruction (TI) 2515/191 "Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency

Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans" is to verify that licensees have adequately implemented the mitigation strategies as described in the licensee's Final Integrated Plan (ADAMS Accession No ML16145A523) and the NRC's plant safety evaluation (ADAMS Accession No. ML16253A322) and to verify that the licensees installed reliable water-level measurement instrumentation in their spent fuel pools. The purpose of this TI is also to verify the licensees have implemented Emergency Preparedness (EP) enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability and enhancements to ensure that staffing is sufficient and communications can be maintained during such an event. The inspection verified that plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (ADAMS Accession No. ML12229A174) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (ADAMS Accession No. ML12056A044) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012 request for information letter and multi-unit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ADAMS Accession No. ML12339A262). The team discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify that the strategies could be implemented as stated in the licensee's submittals and the NRC staff-prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the team's inspection activities are described in the following sections. 1. Mitigation Strategies for Beyond-Design-Basis External Events

a. Inspection Scope

The team examined the licensee's established guidelines and implementing procedures for the beyond-design-basis mitigation strategies. The team assessed how the licensee coordinated and documented the interface/transition between existing off-normal and Emergency Operating Procedures with the newly developed mitigation strategies. The team selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures; familiarity of operators with the procedure objectives 4 and specific guidance; staging and compatibility of equipment; and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios. The team verified that a preventive maintenance program had been established for the FLEX portable equipment and that periodic equipment inventories were in place and being conducted. Additionally, the team examined the introductory and planned periodic/refresher training provided to the Operations and Security staffs most likely to be tasked with implementation of the FLEX mitigation strategies. The team also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel. b. Assessment Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA-12-049. The inspectors verified that the licensee satisfactorily: Developed and issued FLEX Support Guidelines (FSG) to implement the FLEX strategies for postulated external events; Integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs are clear when using existing plant procedures; Protected FLEX equipment from site-specific hazards; Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability; Trained their staff to assure personnel proficiency in the mitigation of beyond-design-basis events; and Developed means to ensure that the necessary off-site FLEX equipment will be available from off-site locations. The inspectors verified that any non-compliances with current licensing requirements and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings were identified.

5 2. Spent Fuel Pool (SFP) Instrumentation

a. Inspection Scope

The team examined the licensee's newly installed spent fuel pool instrumentation. Specifically, the inspectors verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation and that the cabling for the power supplies and the indications for each channel are physically and electrically separated. Additionally, environmental conditions and accessibility of the instruments were evaluated. b. Assessment Based on samples selected for review, the inspectors determined that the licensee satisfactorily installed and established control of the SFP instrumentation as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA-12-051. The inspectors verified that the licensee satisfactorily: Installed the SFP instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittal and safety evaluation; Installed the SFP instrumentation display in the location, environmental conditions, and with the accessibility as described in the plant specific submittals; and Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation.

The inspectors verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings were identified. 3. Staffing and Communication Request for Information

a. Inspection Scope

Through discussions with plant staff, review of documentation, and plant walk downs, the team verified that the licensee has implemented required changes to staffing, communications equipment and facilities to support an Extended Loss of All AC Power (ELAP) scenario as described in the licensee's staffing assessment and the NRC safety assessment. The team also verified that the licensee has implemented dose assessment (including releases from spent fuel pools) capability using the licensee's site-specific dose assessment software and approach as described in the licensee's dose assessment submittal.

6 b. Assessment The inspectors reviewed information provided in the licensee's multi-unit dose submittal and in response to the NRC's March 12, 2012, request for information letter. The inspectors verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an ELAP scenario to the site and impedes access to the site.

The inspectors verified the following: The licensee satisfactorily implemented required staffing change(s) to support an ELAP scenario; Emergency preparedness communications equipment and facilities are sufficient for dealing with an ELAP scenario; and Dose assessment capabilities (including releases from spent fuel pools) using the licensee's site-specific dose assessment software and approach.

The inspectors verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit Exit Meeting Summary On March 10, 2017, the inspectors presented the inspection results in a management debrief to Mr. B. Roach, Senior Manager, Site Projects and Nuclear Services, and other members of the site staff.

The inspectors confirmed that proprietary information was not provided or examined during the inspection. The inspectors completed an exit meeting conducted with Mr. G. Hawkins, Director, Regulatory and Performance Improvement, and other members of the site staff, via telephone on April 27, 2017, to discuss the final results of the inspection. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

C. Bottemiller, Entergy Corporate Licensing

T. Coutu, Director, Regulatory Assurance and Performance Improvement

J. Dorsey, Manager, Security

D. Ellis, Senior Emergency Planner, Emergency Preparedness

V. Fallacara, Acting Site Vice President

B. Flowers, FLEX Marshal, Operations

M. Greenough, Design Engineer, Engineering

F. Guynn, Project Manager, Entergy Corporate Fukushima Projects

G. Hawkins, Director, Regulatory Assurance and Performance Improvement

R. Meyer, Shift Manager, Operations

J. Nadeau, Manager, Regulatory Assurance

B. Roach, Senior Manager, Site Projects and Nuclear Services

C. Roberts, Procedure Writer, Operations

S. Sweet, Licensing Engineer, Regulatory Assurance

F. Weaver, Shift Manager, Operations Training

B. Wentz, Senior Manager, Operations

NRC Personnel

M. Young, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed 2515/191 TI Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, issued December 23, 2015

Section 4OA5: Other Activities

Corrective Action Documents (CR-GGN-) 2015-06134 2016-02246 2016-04372 2016-06961 2016-07339 2016-07383 2016-07408 2016-08592 2017-01846 2017-02030 2017-02062 2017-02063 2017-02165 2017-02159 2017-02181 2017-02265 2017-02197 2017-02289* 2017-02292* 2017-02298* 2017-02439* 2017-02306* 2017-02342 2017-02344* 2017-02384* 2017-02390* 2017-02410* 2017-02412* 2017-02440* 2017-02441* 2017-02442* 2017-02444* 2017-02446* 2017-02460* 2017-02465* 2017-02467* 2017-02500* 2017-03096* 2017-03294* * - indicates condition report written by the licensee as a result of the NRC inspection

Drawings

Number Title Revision C0020 Site and Yard Work Erosion Control and Generator Site Drainage Plan 20 C7639 Flex Storage Building Equipment Layout 0 C7640 Grading and Drainage Plan for Flex Storage Building Site 1 NEW C7641 Flex Storage Building Site 4 NEW C7643 Flex Storage Buildings Deployment Paths Outside PA 0 C7652, SH 3 Flex Storage Building Site Plan NEW

Procedures

Number Title Revision 02-S-01-35 Outside Rounds 81 04-1-01-P41-1 Standby Service Water System 143 04-1-03-A30-1 Cold Weather Protection 23 05-1-02-I-4 Loss of AC Power 50 05-1-02-I-7 Extended Loss of AC Power (ELAP) 0 05-1-02-VI-2 Hurricanes, Tornadoes and Severe Weather 130 05-S-01-FSG-001 Long Term Reactor Vessel Cooling 1

Procedures

Number Title Revision 05-S-01-FSG-002 Alternate RCIC Suction Source 1 05-S-01-FSG-003 Alternate Reactor Vessel Cooling 0 05-S-01-FSG-004 ELAP DC Bus Load Shed and Management 0 05-S-01-FSG-005 Initial Assessment and FLEX Equipment Staging 0 05-S-01-FSG-007 Loss of Control/Instrumentation Power 0 05-S-01-FSG-011 Alternate Spent Fuel Pool Makeup and Cooling 1 05-S-01-FSG-012 Alternate Containment Cooling and Hydrogen Control 0 05-S-01-FSG-013 Transition from FLEX Equipment 0 05-S-01-FSG-100 Beyond Design Bases External Event (BDBEE) with an Extended Loss of Offsite and Onsite Power (ELAP) Emergency Response 0 05-S-01-FSG-101 Emergency Communication for Beyond Design Basis External Events 1

EN-DC-324 Preventive Maintenance Program 17

EN-EP-313 Offsite Dose Assessment Using the Unified RASCAL Interface 0

EN-HU-106 Procedure and Work Instruction Use and Adherence

3

EN-LI-102 Corrective Action Program 27

EN-MA-101-03 Maintenance Work Preparation Process 7

EN-OP-104 Operability Determination Process 11

EN-OP-201-02 Grand Gulf Nuclear Station FLEX Program Document 0

Work Orders

Number Title Revision / Date

416741-01 Model Work Order (MWO)

416741-01 1FLEXC001 pump 6 month

416742-01

MWO 416742-01 1FLEXC002 pump 6 month

416743

MWO 416743 1FLEXC001 oil sample 1 year

416744

MWO 416744 1FLEXC002 oil sample 1 year

416745

MWO 416745 1FLEXC001 pump 1 year

416746

MWO 416746 1FLEXC002 pump 1 year

416786-01

MWO 416786-01 1FLEXS009 diesel gen 6 month

Work Orders

Number Title Revision / Date

416787-01

MWO 416787-01 1FLEXS010 diesel gen 6 month

416788

MWO 416788 1FLEXS009 oil sample 1 year

416789

MWO 416789 1FLEXS010 oil sample 1 year

416790-01

MWO 416790-01 1FLEXS009 diesel gen 1 year

416791-01

MWO 416791-01 1FLEXS010 diesel gen 1 year

417790-01

MWO 417790-01 1FLEXS011 diesel gen 6 month

417791

MWO 417791 1FLEXS011 oil sample 1 year

417792

MWO 417792 1FLEXS011 diesel gen 1 year

443343-01

MWO 443343-01 1FLEXS022 diesel gen 6 month

443419

MWO 443419 1FLEXS022 oil sample 1 year

443436

MWO 443436 1FLEXS022 diesel gen 1 year

445390-01

MWO 445390-01 1FLEXC001 pump 1 month

445390-07

MWO 445390-07 1FLEXS009 diesel gen 1 month

445390-08

MWO 445390-08 1FLEXS011 diesel gen 1 month

445483-01

MWO 445483-01 1FLEXC002 pump 1 month

445483-07

MWO 445483-07 1FLEXS010 diesel gen 1 month

445483-09

MWO 445483-09 1FLEXS022 diesel gen 1 month

471187-01 FLEX Standby PM - 1 Year Operational Test - 1FLEXS011 March 30, 2017

52684632-01 FLEX Standby PM - 1 Year Operational Test - 1FLEXS011 March 22, 2017

52688177-01 1FLEXS022 FLEX Standby PM - 1 Year Operational Inspection March 21, 2017

Calculations

EC 50275

EC 50287

EC 64812

CC-N1FLEX-14002

Miscellaneous

Documents/Reports Number Title Revision / Date

EOF Inventory/Operability Check/Housekeeping Inspection (Not Dated)

GGNS EOF Inventory Sheet FLEX Equipment (Not Dated)

Miscellaneous

Documents/Reports Number Title Revision / Date

Entergy GGNS FLEX Validation February 5, 2016

Grand Gulf Station On-Shift Staffing Analysis, Final Report December 13, 2012

SFPI Conduit Separation White Paper (Not Dated) 06-IC-1G41-A-0001 SFP Level Instrument Channel Functional Test 100

GGNS-SA-14-00002 Further Development of Grand Gulf FLEX Strategy Analytical Bases and Conceptual Design 0

GGNS-SA-15-00001 SAFER Response Plant for Grand Gulf Nuclear Station 1

GNRO-2015/00054 Response to March 12, 2012, Request for Information (RFI) Pursuant to Title 10 of the Code of Federal Regulation 50.54(f) Regarding Recommendations of the Near-Term Task Force (NTTF) Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5 Recommendation 9.3,

Emergency Preparedness - Staffing, Requested Information Items 1, 2 and 6 - Phase 2 Staffing Assessment October 21, 2015

SDC-P41 System Design Criteria for Standby Service Water System P41 4