ML082910566
| ML082910566 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 10/17/2008 |
| From: | Geoffrey Miller NRC/RGN-IV/DRP |
| To: | Douet J Entergy Operations |
| References | |
| EA-08-295 IR-08-004 | |
| Download: ML082910566 (48) | |
See also: IR 05000416/2008004
Text
October 17, 2008
James R. Douet, Vice President of Operations
Grand Gulf Nuclear Station
Entergy Operations, Inc.
P.O. Box 756
Port Gibson, MS 39150
SUBJECT: GRAND GULF NUCLEAR STATION - NRC INTEGRATED INSPECTION
REPORT 05000416/2008004
Dear Mr. Douet:
On September 20, 2008 the U.S. Nuclear Regulatory Commission (NRC) completed an
integrated inspection at your Grand Gulf Nuclear Station. The enclosed report documents the
inspection results, which were discussed on September 29, 2008, with you and other members
of your staff. The inspection examined activities conducted under your license as they relate to
safety and compliance with the Commissions rules and regulations and with the conditions of
your license. The inspectors reviewed selected procedures and records, observed activities,
and interviewed personnel.
One violation is cited in the enclosed Notice of Violation and the circumstances surrounding this
violation are described in detail in the enclosed report. The violation involved your failure to
perform an adequate inspection of probable maximum precipitation door seals protecting
safety-related equipment (EA-08-295). Although determined to be of very low safety
significance (Green), this violation is being cited because not all the criteria specified in
Section VI.A.1 of the NRC Enforcement Policy for a noncited violation were satisfied.
Specifically, Grand Gulf Nuclear Station failed to restore compliance within a reasonable time
after the violation was first identified in NRC Inspection Report 05000416/2008002. Please note
that you are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. The NRC will use your response, in part, to
determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements.
This report documents two additional NRC identified findings of very low safety significance
(Green). Both of these findings were determined to involve violations of NRC requirements.
However, because of the very low safety significance and because they were entered into your
corrective action program, the NRC is treating these findings as noncited violations consistent
with Section VI.A.1 of the NRC Enforcement Policy. If you contest the subject or severity of a
noncited violation, 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 a copy to the Regional
UNITED STATES
NUCLEAR REGULATORY COMMISSION
R E GI ON IV
612 E. LAMAR BLVD., SUITE 400
ARLINGTON, TEXAS 76011-4125
Entergy Operations, Inc.
- 2 -
Administrator, U.S. Nuclear Regulatory Commission - Region IV, 612 E. Lamar Blvd, Suite 400,
Arlington, TX 76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Grand Gulf
Nuclear Station.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter
and its enclosure will be made available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records (PARS) component of
NRCs document system (ADAMS), accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Chief Projects Branch C
Division of Reactor Projects
Docket: 50-416
License: NPF-29
Enclosure:
Inspection Report 05000416/2008004
w/Attachment: Supplemental Information
cc w/enclosure
Senior Vice President
Entergy Nuclear Operations
P.O. Box 31995
Jackson, MS 39286-1995
Senior Vice President and COO
Entergy Operations, Inc.
P.O. Box 31995
Jackson, MS 39286-1995
Vice President, Oversight
Entergy Services, Inc.
P.O. Box 31995
Jackson, MS 39286-1995
Chief, Energy and Transportation Branch
Environmental Compliance and
Enforcement Division
Mississippi Department of
Environmental Quality
P.O. Box 10385
Jackson, MS 39289-0385
President
Claiborne County
Board of Supervisors
P.O. Box 339
Port Gibson, MS 39150
Senior Manager
Nuclear Safety & Licensing
Entergy Nuclear Operations
P.O. Box 31995
Jackson, MS 39286-1995
Manager, Licensing
Entergy Operations, Inc.
Grand Gulf Nuclear Station
P.O. Box 756
Port Gibson, MS 39150
Attorney General
Department of Justice
State of Louisiana
P.O. Box 94005
Baton Rouge, LA 70804-9005
Entergy Operations, Inc.
- 3 -
Office of the Governor
State of Mississippi
Jackson, MS 39201
Attorney General
Asst. Attorney General
State of Mississippi
P.O. Box 22947
Jackson, MS 39225-2947
State Health Officer
State Health Board
P.O. Box 1700
Jackson, MS 39215
Associate General Counsel
Entergy Nuclear Operations
P.O. Box 31995
Jackson, MS 39286-1995
Richard Penrod, Senior Environmental
Scientist/State Liaison Officer
Office of Environmental Services
Northwestern State University
Russsell Hall, Room 201
Natchitoches, LA 71497
Entergy Operations, Inc.
- 4 -
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
DRP Director (Dwight.Chamberlain@nrc.gov)
DRP Deputy Director (Anton.Vegel@nrc.gov)
DRS Director (Roy.Caniano@nrc.gov)
DRS Deputy Director (Troy.Pruett@nrc.gov)
Senior Resident Inspector Rich.Smith@nrc.gov)
Resident Inspector (Andy.Barrett@nrc.gov)
Branch Chief, DRP/C (Geoffrey.Miller@nrc.gov)
Senior Project Engineer, DRP/C (Wayne.Walker@nrc.gov)
GG Site Secretary (Nancy.Spivey@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
K. S. Fuller, RC/ACES (KSF)
C. A. Carpenter, D:OE (CAC)
OEMAIL Resource
Senior Enforcement Specialist (Mark.Haire@nrc.gov)
Only inspection reports to the following:
Mark Cox, OEDO RIV Coordinator (Mark.Cox@nrc.gov)
ROPreports
SUNSI Review Completed: _WCW__ ADAMS: Yes No Initials: _WCW_
Publicly Available Non-Publicly Available
Sensitive Non-Sensitive
R:\\_REACTORS\\GG\\2008\\GG2008-04RP-RLS.doc ML 082910566
RIV:RI:DRP/C
SRI:DRP/C
C:SPE:DRP/C C:DRS/EB1
C:DRS/PSB1
C:DRS/PSB2
AJBarrett
RLSmith
WCWalker
RLBywater
MPShannon
GEWerner
/RA/
/RA/
/RA/
/RA/
10/ /08
10/ /08
10/14/08
10/14/08
10/14/08
10/15/08
C:DRS/OB
C:DRS/EB2
SES/ACES
C:DRP/C
RLantz
NFOKeefe
MSHaire
GBMiller
/RA/
/RA GW for/
/RA/
/RA/
10/14/08
10/14/08
10/14/08
10/15/08
OFFICIAL RECORD COPY
T=Telephone E=E-mail F=Fax
ENCLOSURE 1
Entergy Operations, Inc.
Docket: 50-416
Grand Gulf Nuclear Station
License: NPF-29
During an NRC inspection conducted on June 22 through September 20, 2008, a violation of
NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation
is listed below:
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings,
states, in part, that activities affecting quality shall be accomplished in accordance with
prescribed procedures.
Contrary to this requirement, from March 16 through July 9, 2008, the licensee failed to
accomplish an activity affecting quality in accordance with prescribed procedures.
Specifically, the licensee failed to perform an adequate inspection of probable maximum
precipitation door seals protecting safety-related equipment as prescribed in Procedure
07-5-14-310, Inspection of Mechanical Seals on Doors, revision 5.
This violation is associated with a Green SDP finding.
Pursuant to the provisions of 10 CFR 2.201, Entergy Operations, Inc. is hereby required to
submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator,
Region IV, and a copy to the NRC Resident Inspector at the facility that is the subject of this
Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This
reply should be clearly marked as a "Reply to a Notice of Violation; EA-08-295" and should
include: (1) the reason for the violation, or, if contested, the basis for disputing the violation or
severity level, (2) the corrective steps that have been taken and the results achieved, (3) the
corrective steps that will be taken to avoid further violations, and (4) the date when full
compliance will be achieved. Your response may reference or include previous docketed
correspondence, if the correspondence adequately addresses the required response. If an
adequate reply is not received within the time specified in this Notice, an order or a Demand for
Information may be issued as to why the license should not be modified, suspended, or
revoked, or why such other action as may be proper should not be taken. Where good cause is
shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs document system (ADAMS), accessible from the
NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction. If personal privacy or proprietary information is
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of your
response that deletes such information. If you request withholding of such material, you must
- 2 -
ENCLOSURE 1
specifically identify the portions of your response that you seek to have withheld and provide in
detail the bases for your claim of withholding (e.g., explain why the disclosure of information will
create an unwarranted invasion of personal privacy or provide the information required by 10
CFR 2.390(b) to support a request for withholding confidential commercial or financial
information). If safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.
Dated this 17th day of October 2008
- 1 -
ENCLOSURE 2
U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
Dockets:
50-416
Licenses:
Report:
Licensee:
Entergy Operations, Inc.
Facility:
Grand Gulf Nuclear Station
Location:
Waterloo Road
Port Gibson, MS
Dates:
06/22/2008 - 09/21/2008
Inspectors:
R. Smith, Senior Resident Inspector
A. Barrett, Resident Inspector
E. Uribe, Reactor Inspector
I. Anachondo, NSPDP
P. Elkmann, Senior Emergency Preparedness Inspector
G. Guerra, Emergency Preparedness Inspector
Approved By:
Dwight D. Chamberlain, Director
Division of Reactor Projects
- 2 -
ENCLOSURE 2
SUMMARY OF FINDINGS
IR 05000416/2008004; 6/22/2008 - 9/21/2008; Grand Gulf Nuclear Station; Maintenance
Effectiveness, Maintenance Risk Assessments and Emergent Work Control, and Problem
Identification and Resolution.
This report covers a 3-month period of inspection by resident inspectors and announced
baseline inspections by regional inspectors. Three Green findings were identified by the
inspectors. One of findings was cited violation and two were noncited violations. The
significance of most findings is indicated by their color (Green, White, Yellow, Red) using
Inspection Manual Chapter 0609, Significance Determination Process. Findings for which the
significance determination process does not apply may be Green or be assigned a severity level
after NRC management review. The NRCs program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 4, dated December 2006.
A.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
Green. The inspectors identified a Green noncited violation of 10 CFR 50.65(a)(2)
involving the failure to adequately monitor the performance of four Maintenance Rule
systems. Several discrepancies in the Maintenance Rule Program were discovered by
the inspectors, including unevaluated condition monitoring failures in the neutron
monitoring system and an unevaluated functional failure in the standby gas treatment
system. Plant personnel implemented additional corrective actions to fully investigate
the potential extent of this condition and the apparent weakness in the condition report
screening process used for the Maintenance Rule program. As a result, the
Maintenance Rule expert panel classified four systems as needing increased monitoring
and goal setting, moving these systems from an a(2) to an a(1) status. The licensee
entered this issue into the corrective action program as Condition Report CR-GGN-
2008-02219.
This finding is more than minor since it was similar to Inspection Manual Chapter 0612,
Appendix E, Example 7.b in that the problem involved degraded equipment
performance. This finding was characterized under the significance determination
process as having very low safety significance because the maintenance rule aspect of
the finding did not cause an actual loss of safety function of the system nor did it cause a
component to be inoperable. The cause of this finding has a crosscutting aspect in the
area of human performance associated with work practices because licensee personnel
failed to use proper self-checking and peer-checking to identify repetitive maintenance
rule functional failures and also failed to properly document condition report screening
activities H.4(a) (Section 1R12).
Green. The inspectors identified a Green noncited violation of 10 CFR 50.65 (a)(4),
involving the failure to perform risk assessments following multiple declared tornado
watches affecting Grand Gulf Nuclear Station during the landfall of Hurricane Gustav.
On the morning of September 3, 2008, the inspectors noted that the licensee had not
evaluated the increased risk from a declared tornado watch for the Claiborne County
area. The inspectors brought this to the attention of plant personnel and a risk
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ENCLOSURE 2
assessment was performed and plant risk was changed from a Green to a Yellow risk
condition. The inspectors then reviewed the tornado watches declared by the National
Weather Service that affected Claiborne County during the landfall of Hurricane Gustav,
and noted that six separate tornado watches had been declared over the previous three
days. A review of the control room logs showed no documentation of changes in plant
risk condition. The licensee entered this issue into the corrective action program as
Condition Report CR-GGN-2008-04397.
This finding is more than minor because the risk assessments failed to consider unusual
external conditions that were present or imminent. Using Manual Chapter 0609,
Appendix K, Maintenance Risk Assessment and Risk Management Significance
Determination Process, Flowchart 1, Assessment of Risk Deficit and consulting with
the regional senior risk analyst, the inspectors determined the finding of very low safety
significance due to a calculated incremental core damage probability deficit of 4.38E-08.
This finding has a crosscutting aspect in the area of human performance associated with
work practices in that plant personnel failed to follow the risk management procedure
H.4(b) (Section 1R13).
Green. The inspectors identified a Green cited violation of 10 CFR Part 50 Appendix B,
Criterion V, Instructions, Procedures, and Drawings, involving the failure to perform an
adequate inspection of probable maximum precipitation door seals protecting safety
related equipment. The licensee had previously received a noncited violation for
inadequate inspections of probable maximum precipitation door seals in NRC Inspection
Report 05000416/2008002. On July 9, 2008, the inspectors found the entrance door to
the Train B standby service water pump house not meeting the standards of the
maintenance procedure because the door seals failed to make contact with the door.
The extent of condition review found seven additional door seals degraded, including the
doors to the diesel generator building and control building. The door seal on the Train B
standby service water pump house identified by the inspectors on July 9, 2008, had not
been identified by plant personnel during an extent of condition review on February 29,
2008. The licensee entered this issue into the corrective action program as Condition
Report CR-GGN-2008-03216.
The finding is more than minor since it affects the protection against external factors
attribute of mitigating system cornerstone. The door seals also represent a degrading
condition that if left uncorrected could affect the availability, reliability, and capability of
mitigating systems required to respond to initiating events to prevent undesirable
consequences. Using the Manual Chapter 0609, Significance Determination Process,
Phase 1 Worksheet, the inspectors used the seismic, flooding, and severe weather
Table 4b and determined it would affect multi-trains of safety equipment. The inspectors
consulted the regional senior reactor analyst, who performed a Phase 3 analysis using
many bounding and conservative assumptions. The result was a delta-CDF of 3.3E-7/yr
and a delta-LERF of 6.6E-8/yr. These results confirmed that the finding had very low
safety significance (Green). The cause of this finding has a crosscutting aspect in the
area of problem identification and resolution in that the licensee failed to take adequate
corrective actions to ensure degraded probable maximum precipitation door seals were
properly evaluated and repaired in a timely manner P.1(d) (Section 4OA2).
B.
Licensee-Identified Violations
None.
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ENCLOSURE 2
REPORT DETAILS
Summary of Plant Status
Grand Gulf Nuclear Station (GGNS) began the inspection period at full rated thermal power. On
July 5, 2008, operators reduced power to 90 percent for planned control rod exercise and
control blade friction testing. The plant returned to full rated power the same day. On August 1,
2008, operators commenced a power reduction to 76 percent for a planned control rod
sequence exchange, control rod exercise and control blade friction testing. The plant returned
to 98 percent of rated power on August 4, 2008 and remained there until equipment issues with
the leading edge flow meter (LEFM) could be resolved. On August 10, 2008, after the plant
resolved the issue with the LEFM, they returned to full rated power. On August 28, 2008,
operators commenced a power reduction to 66 percent for a planned control rod sequence
exchange, control rod exercise and control blade friction testing. The plant returned to full rated
power on August 29, 2008. The plant remained at or near full rated thermal power until
September 14, 2008, when the plant began coasting down in power for scheduled Refueling
Outage 16 and remained in a power coast down until the end of the quarter.
REACTOR SAFETY
Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness
1R01 Adverse Weather Protection (71111.01)
.1
Summer Seasonal Readiness Preparations
a.
Inspection Scope
The inspectors reviewed the licensees preparations for summer weather for selected
systems, including conditions that could lead to loss of offsite power and conditions that
could result from high temperatures. During the inspection, the inspectors focused on
plant specific design features and the licensees procedures used to mitigate or respond
to adverse weather conditions. Additionally, the inspectors reviewed the Updated Final
Safety Analysis Report (UFSAR) and performance requirements for systems selected for
inspection, and verified that operator actions were appropriate as specified by plant
specific procedures. Specific documents reviewed during this inspection are listed in the
Attachment. The inspectors also reviewed corrective action program items to verify that
the licensee was identifying adverse weather issues at an appropriate threshold and
entering them into their corrective action program in accordance with station corrective
action procedures. The inspectors reviews focused specifically on the following plant
systems:
Standby Service Water System
Engineering Safety Feature Transformers
This inspection constitutes one seasonal adverse weather sample as defined in
Inspection Procedure 71111.01-05.
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ENCLOSURE 2
b.
Findings
No findings of significance were identified.
.2
Readiness For Impending Adverse Weather Condition - Hurricane Gustav which
Produced High Wind Conditions, and Tornado Watches/Warnings for the Site
a.
Inspection Scope
Since Hurricane Gustav, with potential tornados and high winds, was forecast in the
vicinity of the facility for September 1, 2008, the inspectors reviewed the overall
preparations and protections for the expected weather conditions. Starting on
August 26, 2008, the inspectors walked down the site standby service water cooling
towers and pump houses, in addition to the emergency AC power systems, because
their safety-related functions could be affected or required as a result of the hurricane
high winds or tornado-generated missiles or the loss of offsite power. The inspectors
evaluated the plant staffs preparations against the sites procedures and determined
that the staffs actions were adequate. During the inspection, the inspectors focused on
plant specific design features and procedures used to respond to specified adverse
weather conditions. The inspectors also toured the plant grounds to look for any loose
debris that could become missiles during a tornado. The inspectors evaluated operator
staffing and accessibility of controls and indications for those systems required to control
the plant. Additionally, the inspectors reviewed the UFSAR and performance
requirements for systems selected for inspection, and verified that operator actions were
appropriate as specified by plant specific procedures. The inspectors also reviewed a
sample of corrective action program items to verify that the identified adverse weather
issues at an appropriate threshold and dispositioned them through the corrective action
program in accordance with station corrective action procedures. Specific documents
reviewed during this inspection are listed in the attachment.
This inspection constitutes one readiness for impending adverse weather condition
sample as defined in Inspection Procedure 71111.01-05.
b.
Findings
No findings of significance were identified.
1R04 Equipment Alignment (71111.04)
.1
Quarterly Partial System Walkdowns
a.
Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant
systems:
July 29, 2008, the inspectors walked down the control room air conditioning
(CRAC) Train B and standby fresh air (SBFA) Train B during planned outage on
CRAC Train A and SBFA Train A
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ENCLOSURE 2
September 15, 2008, the inspectors walked down the Division I standby diesel
generator during a planned outage of the Division II standby diesel generator
The inspectors selected these systems based on their risk significance relative to the
reactor safety cornerstones at the time they were inspected. The inspectors attempted
to identify any discrepancies that could impact the function of the system, and, therefore,
potentially increase risk. The inspectors reviewed applicable operating procedures,
system diagrams, UFSAR, Technical Specification (TS) requirements, Administrative
TS, outstanding work orders, condition reports, and the impact of ongoing work activities
on redundant trains of equipment in order to identify conditions that could have rendered
the systems incapable of performing their intended functions. The inspectors also
walked down accessible portions of the systems to verify system components and
support equipment were aligned correctly and operable. The inspectors examined the
material condition of the components and observed operating parameters of equipment
to verify that there were no obvious deficiencies. The inspectors also verified that the
licensee had properly identified and resolved equipment alignment problems that could
cause initiating events or impact the capability of mitigating systems or barriers and
entered them into the corrective action program with the appropriate significance
characterization. Documents reviewed are listed in the attachment.
These activities constituted two partial system walkdown samples as defined by
Inspection Procedure 71111.04-05.
b.
Findings
No findings of significance were identified.
.2
Semi-Annual Complete System Walkdown
a.
Inspection Scope
On June 24, 2008, the inspectors completed a system alignment inspection of the high
pressure core spray system to verify the functional capability of the system. This system
was selected because it was considered both safety-significant and risk-significant in the
licensees probabilistic risk assessment. The inspectors walked down the system to
review mechanical and electrical equipment line ups, electrical power availability, system
pressure and temperature indications, as appropriate, component labeling, component
lubrication, component and equipment cooling, hangers and supports, operability of
support systems, and to ensure that ancillary equipment or debris did not interfere with
equipment operation. A review of a sample of past and outstanding work orders (WOs)
was performed to determine whether any deficiencies significantly affected the system
function. In addition, the inspectors reviewed the corrective action program (CAP)
database to ensure that system equipment alignment problems were being identified
and appropriately resolved. The documents used for the walkdown and issue review are
listed in the attachment.
These activities constituted one complete system walkdown sample as defined by
Inspection Procedure 71111.04-05.
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ENCLOSURE 2
b.
Findings
No findings of significance were identified.
1R05 Fire Protection (71111.05)
.1
Routine Resident Inspector Tours (71111.05Q)
a.
Inspection Scope
The inspectors conducted fire protection walkdowns which were focused on availability,
accessibility, and the condition of firefighting equipment in the following risk-significant
plant areas:
Division II Diesel Generator Room (Room 1D303)
High Pressure Core Spray Room (Room 1A109) and Residual Heat Removal
Train B Pipe Penetration Room (Room 1A205)
Service Water Train B Pump House and Valve Room (Rooms 2M110 and
2M112)
Auxiliary Building 208 and 245 elevations (Rooms 1A532, 1A602, 1A603, 1A604
and 1A605)
Control Building HVAC areas (Rooms OC302 and OC303)
Containment Building 135 elevation (1A311 and 1A313)
The inspectors reviewed areas to assess if the licensee had implemented a fire
protection program that adequately controlled combustibles and ignition sources within
the plant, effectively maintained fire detection and suppression capability, maintained
passive fire protection features in good material condition, and had implemented
adequate compensatory measures for out of service, degraded or inoperable fire
protection equipment, systems, or features in accordance with the licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk
as documented in the plants Individual Plant Examination of External Events with later
additional insights, their potential to impact equipment which could initiate or mitigate a
plant transient, or their impact on the plants ability to respond to a security event. Using
the documents listed in the attachment, the inspectors verified that fire hoses and
extinguishers were in their designated locations and available for immediate use; that
fire detectors and sprinklers were unobstructed, that transient material loading was
within the analyzed limits; and fire doors, dampers, and penetration seals appeared to
be in satisfactory condition. The inspectors also verified that minor issues identified
during the inspection were entered into the licensees corrective action program.
These activities constituted six quarterly fire protection inspection samples as defined by
Inspection Procedure 71111.05-05.
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ENCLOSURE 2
b.
Findings
No findings of significance were identified.
1R06 Flooding (71111.06)
.1
a.
Inspection Scope
The inspectors reviewed selected risk important plant design features and licensee
procedures intended to protect the plant and its safety related equipment from internal
flooding events. The inspectors reviewed flood analyses and design documents,
including the UFSAR, engineering calculations, and abnormal operating procedures for
licensee commitments. The specific documents reviewed are listed in the attachment.
In addition, the inspectors reviewed licensee drawings to identify areas and equipment
that may be affected by internal flooding caused by the failure or misalignment of nearby
sources of water, such as the fire suppression or the circulating water systems. The
inspectors also reviewed the licensees corrective action documents with respect to past
flood-related items identified in the corrective action program to verify the adequacy of
the corrective actions. The inspectors performed a walkdown of the following plant
areas to assess the adequacy of watertight doors and verify drains and sumps were
clear of debris and were operable, and that the licensee complied with its commitments:
Low Pressure Core Spray Room
RHR Train C Pump Room
This inspection constitutes one internal flooding sample as defined in Inspection
Procedure 71111.06-05.
b.
Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program (71111.11)
.1
Resident Inspector Quarterly Review (71111.11Q)
a.
Inspection Scope
On July 2, 2008, the inspectors observed a crew of licensed operators in the plants
simulator during licensed operator requalification examinations to verify that operator
performance was adequate, evaluators were identifying and documenting crew
performance problems and training was being conducted in accordance with licensee
procedures. The inspectors evaluated the following areas:
Licensed operator performance
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ENCLOSURE 2
Crews clarity and formality of communications
Ability to take timely actions in the conservative direction
Prioritization, interpretation, and verification of annunciator alarms
Correct use and implementation of abnormal and emergency procedures
Control board manipulations
Oversight and direction from supervisors
Ability to identify and implement appropriate TS actions and Emergency Plan
Actions and notifications
The crews performance in these areas was compared to pre-established operator action
expectations and successful critical task completion requirements.
This inspection constitutes one quarterly licensed operator requalification program
sample as defined in Inspection Procedure 71111.11.
b.
Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness (71111.12)
.1
Routine Quarterly Evaluations (71111.12Q)
a.
Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk
significant systems:
Emergency Switchgear and Battery Room Ventilation System (Z77)
Riley Temperature switches for various safety related systems (E31, T46, X77,
and Y47)
The inspectors reviewed events such as where ineffective equipment maintenance has
resulted in valid or invalid automatic actuations of engineered safeguards systems and
independently verified the licensee's actions to address system performance or condition
problems in terms of the following:
Implementing appropriate work practices
Identifying and addressing common cause failures
Scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule
- 10 -
ENCLOSURE 2
Characterizing system reliability issues for performance
Charging unavailability for performance
Trending key parameters for condition monitoring
Ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or reclassification
Verifying appropriate performance criteria for structures, systems, and
components (SSCs)/functions classified as (a)(2) or appropriate and adequate
goals and corrective actions for systems classified as (a)(1)
The inspectors assessed performance issues with respect to the reliability, availability,
and condition monitoring of the system. In addition, the inspectors verified maintenance
effectiveness issues were entered into the corrective action program with the appropriate
significance characterization. Documents reviewed are listed in the attachment.
This inspection constitutes two quarterly maintenance effectiveness samples as defined
in Inspection Procedure 71111.12-05.
b.
Findings
Introduction. The inspectors identified a Green noncited violation (NCV) of
10 CFR 50.65(a)(2) involving the failure to adequately monitor the performance of four
maintenance rule scoped systems.
Description. In April 2008, the inspectors identified several discrepancies in the
maintenance rule program, including several unevaluated condition monitoring failures in
the neutron monitoring system and an unevaluated functional failure in the standby gas
treatment system. In addition, the inspectors discovered several condition reports
documenting equipment issues that had no functional failure evaluations. Due to the
absence of documented evidence to determine how these events were erroneously
screened or overlooked in the routine condition reports screening process, plant
personnel implemented additional corrective actions to fully investigate the potential
extent of this condition and the apparent weakness in the condition reports screening
process used for the GGNS Maintenance Rule Program. During this review, several
maintenance rule scoped systems were identified as having repetitive component
failures of Riley temperature switches that spanned multiple systems. These systems
included the electrical switchgear and battery room ventilation system, the diesel
generator building ventilation system, and the standby service water pump house
ventilation system. Further review also identified a repetitive functional failure of an
Asco solenoid valve in the emergency switchgear and battery room ventilation system.
As a result, the maintenance rule expert panel classified these systems as needing
increased monitoring and goal setting, moving these systems from an a(2) to an a(1)
status.
Analysis. The inspectors determined that the finding is a performance deficiency in that
the licensee failed to apply goals and increase the monitoring of systems impacted by
repetitive component failures. The finding was more than minor because it was similar
to Inspection Manual Chapter 0612, Appendix E, Example 7.b, in that the problem
involved degraded equipment performance. This finding was characterized under the
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ENCLOSURE 2
significance determination process as having very low safety significance because the
maintenance rule aspect of the finding did not cause an actual loss of safety function of
the system nor did it cause a component to be inoperable. The cause of this finding has
a crosscutting aspect in the area of human performance associated with work practices
because licensee personnel failed to use proper self-checking and peer-checking to
identify repetitive maintenance rule functional failures and also failed to properly
document condition report screening activities H.4(a).
Enforcement. 10 CFR Part 50.65(a)(1) requires, in part, that licensees shall monitor the
performance or condition of systems, structures and components (SSCs) within the
scope of the rule against licensee-established goals in a manner sufficient to provide
reasonable assurance the SSCs are capable of fulfilling their intended safety functions.
10 CFR Part 50.65(a)(2) requires, in part, that the monitoring specified in paragraph
(a)(1) is not required where it has been demonstrated the performance or condition of an
SSC is being effectively controlled through the performance of appropriate preventive
maintenance such that the SSC remains capable of performing its intended function.
Contrary to the above, the licensee failed to demonstrate that the performance or
condition of four maintenance rule scoped systems had been effectively controlled
through the performance of appropriate preventive maintenance. Specifically, the
licensee failed to properly evaluate the repetitive failures of system components which
demonstrated that the performance of the systems were not being effectively controlled
and goal setting and monitoring was required. However, because this inspection finding
was characterized by the Significance Determination Process as having very low risk
significance (Green) and has been entered in the licensees CAP as CR-GGN-2008-
02219, this violation is being treated as an NCV, consistent with Section IV.A.1 of the
NRC Enforcement Policy: NCV 05000416/2008004-01, Failure to Monitor Performance
of Four Maintenance Rule Systems.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
.1
Maintenance Risk Assessments and Emergent Work Control
a.
Inspection Scope
The inspectors reviewed the licensee's evaluation and management of plant risk for the
maintenance and emergent work activities affecting risk-significant and safety-related
equipment listed below to verify that the appropriate risk assessments were performed
prior to removing equipment for work:
Division 2 diesel generator out of service due pre-modification work on
July 10, 2008
Reactor protection system Train B work the week of July 21, 2008
Tornado watch including Claiborne County on September 3, 2008
Division 1 diesel generator out of service due to lube oil leak on September 9,
2008 and site entering orange risk due to tornado warning in the area on
September 13, 2008
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ENCLOSURE 2
These activities were selected based on their potential risk significance relative to the
reactor safety cornerstones. As applicable for each activity, the inspectors verified that
risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate
and complete. When emergent work was performed, the inspectors verified that the
plant risk was promptly reassessed and managed. The inspectors reviewed the scope
of maintenance work, discussed the results of the assessment with the licensee's
probabilistic risk analyst or shift technical advisor, and verified plant conditions were
consistent with the risk assessment. The inspectors also reviewed TS requirements and
walked down portions of redundant safety systems, when applicable, to verify risk
analysis assumptions were valid and applicable requirements were met.
These activities constituted four samples as defined by Inspection
Procedure 71111.13-05.
b.
Findings
Introduction. The inspectors identified a Green noncited violation of 10 CFR 50.65(a)(4)
involving the failure to perform risk assessments following multiple declared tornado
watches affecting Grand Gulf Nuclear Station during the landfall of Hurricane Gustav.
Description. On the morning of September 3, 2008, the inspectors noted that the
licensee had not evaluated the increased risk from a declared tornado watch for the
Claiborne county area. The inspector brought this to the attention of plant personnel and
a risk assessment was performed and plant risk was changed from a Green to a
Yellow risk condition. The inspectors then reviewed the tornado watches declared by
the National Weather Service that affected Claiborne County during the landfall of
Hurricane Gustav, and noted the following six separate tornado watches had been
declared over the previous three days:
Tornado Watch 878 at 1550 on 9/1/2008
Tornado Watch 880 at 2345 on 9/1/2008
Tornado Watch 881 at 0635 on 9/2/2008
Tornado Watch 882 at 1550 on 9/2/2008
Tornado Watch 884 at 2340 on 9/2/2008
Tornado Watch 885 at 0620 on 9/3/2008
A review of the control room logs showed no documentation of changes in plant risk
condition. The inspector questioned operations personnel and determined that no risk
evaluations had been completed.
Analysis. The inspectors determined that the finding is a performance deficiency
because the licensee failed to perform risk assessments involving changing
environmental conditions that could have negatively impacted offsite power availability.
Per Manual Chapter 0612, Appendix B, the deficiency was greater than minor because
the risk assessments failed to consider unusual external conditions that are present or
imminent. Using Manual Chapter 0609, Appendix K, Maintenance Risk Assessment
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ENCLOSURE 2
and Risk Management Significance Determination Process, Flowchart 1, Assessment
of Risk Deficit and consulting with the regional senior reactor analyst, the inspectors
determined the finding of very low safety significance due to a calculated incremental
core damage probability deficit of 4.38E-08. This finding has a crosscutting aspect in the
area of human performance associated with work practices in that plant personnel failed
to follow the risk management procedure H.4(b).
Enforcement. 10 CFR 50.65 (a)(4), states that, before performing maintenance activities
(including but not limited to surveillance, postmaintenance testing, and corrective and
preventive maintenance), the licensee shall assess and manage the increase in risk that
may result from the proposed maintenance activities. Contrary to the above, the
inspectors identified that, on several occasions, plant personnel failed to assess and
mange risk from proposed maintenance activities during unusual external conditions
(i.e., severe weather). Because this finding is characterized by the Significance
Determination Process as having very low risk significance (Green) and has been
entered into the licensees CAP as CR-GGN-2008-04397, this violation is being treated
as an NCV, consistent with Section VI.A of the Enforcement Policy: NCV 05000416/2008004-02, Failure to Perform an Adequate Risk Assessment during
Adverse Weather Conditions.
1R15 Operability Evaluations (71111.15)
.1
Operability Evaluations
a.
Inspection Scope
The inspectors reviewed the following issues:
CR-GGN-2008-02819, Residual heat removal Pump A failed to start due to
failure to properly rack breaker
CR-GGN-2008-03584, Containment penetration not drained of water prior to
performing pneumatic containment isolation valve local leak rate testing
CR-GGN-2008-03854, Leading edge flow meter (LEFM) out of service due to
Meter 1 pathways #1 and #8 signal reject rate exceeded
CR-GGN-2008-04271, Standby service water pump house ventilation screens
found in a degraded condition
CR-GGN-2008-04505, Division 3 battery bank having a loose connection on the
positive lead on battery cell number one
CR-GGN-2008-04121, Reactor core isolation cooling steam bypass valve
The inspectors selected these potential operability issues based on the risk-significance
of the associated components and systems. The inspectors evaluated the technical
adequacy of the evaluations to ensure that TS operability was properly justified and the
subject component or system remained available such that no unrecognized increase in
risk occurred. The inspectors compared the operability and design criteria in the
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ENCLOSURE 2
appropriate sections of the TS and Updated Safety Analysis Report (USAR) to the
licensees evaluations, to determine whether the components or systems were operable.
Where compensatory measures were required to maintain operability, the inspectors
determined whether the measures in place would function as intended and were
properly controlled. The inspectors determined, where appropriate, compliance with
bounding limitations associated with the evaluations. Additionally, the inspectors also
reviewed a sampling of corrective action documents to verify that the licensee was
identifying and correcting any deficiencies associated with operability evaluations.
Documents reviewed are listed in the attachment.
This inspection constitutes six samples as defined in Inspection Procedure 71111.15-05
b.
Findings
No findings of significance were identified.
1R18 Plant Modifications (71111.18)
.1
a.
Inspection Scope
The inspectors reviewed the following temporary modification:
Change to LEFM software constants
The inspectors compared the temporary configuration changes and associated
10 CFR 50.59 screening and evaluation information against the design basis, the
UFSAR, and the TSs, as applicable, to verify that the modification did not affect the
operability or availability of the affected system. The inspectors also compared the
licensees information to operating experience information to ensure that lessons learned
from other utilities had been incorporated into the licensees decision to implement the
temporary modification. The inspectors, as applicable, performed field verifications to
ensure that the modifications were installed as directed; the modifications operated as
expected; modification testing adequately demonstrated continued system operability,
availability, and reliability; and that operation of the modifications did not impact the
operability of any interfacing systems. Lastly, the inspectors discussed the temporary
modification with operations, engineering, and training personnel to ensure that the
individuals were aware of how extended operation with the temporary modification in
place could impact overall plant performance. Documents reviewed are listed in the
attachment.
This inspection constitutes one sample as defined in Inspection Procedure 71111.18-05.
b.
Findings
No findings of significance were identified.
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ENCLOSURE 2
1R19 Postmaintenance Testing (71111.19)
.1
Postmaintenance Testing
a.
Inspection Scope
The inspectors reviewed the following postmaintenance (PM) activities to verify that
procedures and test activities were adequate to ensure system operability and functional
capability:
Standby liquid control system Pump B surveillance following maintenance
Reactor protection system motor generator Set B retest following preventive
maintenance
Valve 1P11F131, refuel water transfer pump suction from suppression pool
primary containment isolation valve (PCIV), inservice stroke test following
replacement of valve actuator and solenoid
Reactor vessel pressure high (RHR Isolation) Switch 1B21N679D, retest after
replacement of failed card
Division 1 diesel generator postmaintenance operability run after a repair of an oil
leak on the right bank number five cylinder
These activities were selected based upon the structure, system, or component's ability
to impact risk. The inspectors evaluated these activities for the following (as applicable):
the effect of testing on the plant had been adequately addressed; testing was adequate
for the maintenance performed; acceptance criteria were clear and demonstrated
operational readiness; test instrumentation was appropriate; tests were performed as
written in accordance with properly reviewed and approved procedures; equipment was
returned to its operational status following testing (temporary modifications or jumpers
required for test performance were properly removed after test completion), and test
documentation was properly evaluated. The inspectors evaluated the activities against
TS, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC
generic communications to ensure that the test results adequately ensured that the
equipment met the licensing basis and design requirements. In addition, the inspectors
reviewed corrective action documents associated with postmaintenance tests to
determine whether the licensee was identifying problems and entering them in the CAP
and that the problems were being corrected commensurate with their importance to
safety. Documents reviewed are listed in the attachment.
This inspection constitutes five samples as defined in Inspection Procedure 71111.19.
b.
Findings
No findings of significance were identified.
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ENCLOSURE 2
1R22 Surveillance Testing (71111.22)
.1
Routine Surveillance Testing
a.
Inspection Scope
The inspectors reviewed the test results for the following activities to determine whether
risk-significant systems and equipment were capable of performing their intended safety
function and to verify testing was conducted in accordance with applicable procedural
and TS requirements:
06-EL-1E61-SA-0002, Hydrogen Ignition System Semi-Annual Tests
06-ME-1M61-V-0001, Local Leak Rate Test Flow Air Using Low Flow Rotameter
Panel or River Bend Volumetric Leak Rate Monitor
06-OP-1C1-V-0003, APRM Functional Test
06-CH-1B21-O-002, Reactor Coolant Routine Chemistry and
06-CH-1B21-W-0008, Reactor Coolant Dose Equivalent Iodine
06-OP-1E12-Q-0024, LPCI/RHR Subsystem B Quarterly Functional Test
The inspectors observed in-plant activities and reviewed procedures and associated
records to determine whether: any preconditioning occurred; effects of the testing were
adequately addressed by control room personnel or engineers prior to the
commencement of the testing; acceptance criteria were clearly stated, demonstrated
operational readiness, and were consistent with the system design basis; plant
equipment calibration was correct, accurate, and properly documented; as left setpoints
were within required ranges; the calibration frequency was in accordance with TS, the
USAR, procedures, and applicable commitments; measuring and test equipment
calibration was current; test equipment was used within the required range and
accuracy; applicable prerequisites described in the test procedures were satisfied; test
frequencies met TS requirements to demonstrate operability and reliability; tests were
performed in accordance with the test procedures and other applicable procedures;
jumpers and lifted leads were controlled and restored where used; test data and results
were accurate, complete, within limits, and valid; test equipment was removed after
testing; where applicable, test results not meeting acceptance criteria were addressed
with an adequate operability evaluation or the system or component was declared
inoperable; where applicable for safety-related instrument control surveillance tests,
reference setting data were accurately incorporated in the test procedure; where
applicable, actual conditions encountering high resistance electrical contacts were such
that the intended safety function could still be accomplished; prior procedure changes
had not provided an opportunity to identify problems encountered during the
performance of the surveillance or calibration test; equipment was returned to a position
or status required to support the performance of the safety functions; and all problems
identified during the testing were appropriately documented and dispositioned in the
corrective action program. Documents reviewed are listed in the attachment.
This inspection constitutes four routine surveillance testing samples and one inservice
testing sample as defined in Inspection Procedure 71111.22.
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ENCLOSURE 2
b.
Findings
No findings of significance were identified.
2.
1EP2 Alert and Notification System Evaluation (71114.02)
.1
Alert and Notification System Evaluation
a.
Inspection Scope
The inspectors discussed with licensee staff the status of offsite siren and tone alert
radio systems to determine the adequacy of licensee methods for testing the alert and
notification system in accordance with 10 CFR Part 50, Appendix E. The licensee=s alert
and notification system testing program was compared with criteria in NUREG-0654,
ACriteria for Preparation and Evaluation of Radiological Emergency Response Plans and
Preparedness in Support of Nuclear Power Plants,@ Revision 1, Federal Emergency
Management Agency (FEMA) Report REP-10, AGuide for the Evaluation of Alert and
Notification Systems for Nuclear Power Plants,@ and the licensee=s current
FEMA-approved alert and notification system design report. The inspectors also
reviewed the references listed in the attachment to this report.
This inspection constitutes one sample as defined in Inspection Procedure 71114.02.
b.
Findings
No findings of significance were identified.
1EP3 Emergency Response Organization Augmentation Testing (71114.03)
.1
Emergency Response Organization Augmentation Testing
a.
Inspection Scope
The inspectors discussed with licensee staff the status of offsite siren and tone alert
radio systems to determine the adequacy of licensee methods for testing the alert and
notification system in accordance with 10 CFR Part 50, Appendix E. The licensee=s alert
and notification system testing program was compared with criteria in NUREG-0654,
ACriteria for Preparation and Evaluation of Radiological Emergency Response Plans and
Preparedness in Support of Nuclear Power Plants,@ Revision 1, Federal Emergency
Management Agency (FEMA) Report REP-10, AGuide for the Evaluation of Alert and
Notification Systems for Nuclear Power Plants,@ and the licensee=s current
FEMA-approved alert and notification system design report. The inspectors also
reviewed the references listed in the attachment to this report.
This inspection constitutes one sample as defined in Inspection Procedure 71114.03.
b.
Findings
No findings of significance were identified.
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ENCLOSURE 2
1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies (71114.05)
.1
Correction of Emergency Preparedness Weaknesses and Deficiencies
a.
Inspection Scope
The inspectors reviewed the licensee=s CAP requirements in Procedure EN-LI-102,
Corrective Action Process, Revision 12. The inspectors reviewed summaries of 233
condition reports assigned to the emergency preparedness department between
June 2006 and July 2008, and selected twenty-five for detailed reviews against program
requirements. The inspectors evaluated the response to the corrective action requests
to determine the licensee=s ability to identify, evaluate, and correct problems in
accordance with the licensee program requirements, 10 CFR 50.47(b)(14), and 10 CFR
Part 50, Appendix E. The inspectors also reviewed licensee after-action reports, quality
assurance audits, drill and exercise evaluation reports, and licensee assessments as
listed in the attachment to this report, to evaluate the licensees ability to identify
emergency preparedness weaknesses and deficiencies.
This inspection constitutes one sample as defined in Inspection Procedure 71114.05.
b.
Findings
No findings of significance were identified.
1EP6 Drill Evaluation (71114.06)
.1
Training Observation
a.
Inspection Scope
The inspectors observed a simulator training evolution for licensed operators on
August 7, 2008, which required emergency plan implementation by a licensee
operations crew. This evolution was planned to be evaluated and included in
performance indicator data regarding drill and exercise performance. The inspectors
observed event classification and notification activities performed by the crew. The
inspectors also attended the post-evolution critique for the scenario. The focus of the
inspectors activities was to note any weaknesses and deficiencies in the crews
performance and ensure that the licensee evaluators noted the same issues and entered
them into the CAP. As part of the inspection, the inspectors reviewed the scenario
package and other documents listed in the attachment.
This inspection constitutes one sample as defined in Inspection Procedure 71114.06.
b.
Findings
No findings of significance were identified.
4.
OTHER ACTIVITIES
Other Activities [OA]
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ENCLOSURE 2
4OA1 Performance Indicator Verification (71151)
.1
Safety System Functional Failures
a.
Inspection Scope
The inspectors sampled licensee submittals for the Safety System Functional Failures
performance indicator for the period from the third quarter of 2007 through the second
quarter 2008. To determine the accuracy of the performance indicator (PI) data reported
during those periods, PI definitions and guidance contained in revision 5 of the Nuclear
Energy Institute Document 99-02, Regulatory Assessment Performance Indicator
Guideline, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73"
definitions and guidance were used. The inspectors reviewed the licensees operator
narrative logs, operability assessments, maintenance rule records, maintenance work
orders, CRs, event reports and NRC Integrated Inspection reports for the period of July
2007 through June 2008 to validate the accuracy of the submittals. The inspectors also
reviewed the licensees CR database to determine if any problems had been identified
with the PI data collected or transmitted for this indicator and none were identified.
Specific documents reviewed are described in the Attachment to this report.
This inspection constitutes one safety system functional failures sample as defined by
b.
Findings
No findings of significance were identified.
.2
Reactor Coolant System Specific Activity
a.
Inspection Scope
The inspectors sampled licensee submittals for the Reactor Coolant System (RCS)
Specific Activity performance indicator for the period from the third quarter of 2007
through the second quarter 2008. To determine the accuracy of the PI data reported
during those periods, PI definitions and guidance contained in revision 5 of the Nuclear
Energy Institute Document 99-02, Regulatory Assessment Performance Indicator
Guideline, were used. The inspectors reviewed the licensees RCS chemistry samples,
TS requirements, issue reports, event reports and NRC Integrated Inspection reports for
the period of July 2007 through June 2008 to validate the accuracy of the submittals.
The inspectors also reviewed the licensees CR database to determine if any problems
had been identified with the PI data collected or transmitted for this indicator and none
were identified. In addition to record reviews, the inspectors observed a chemistry
technician obtain and analyze a reactor coolant system sample. Specific documents
reviewed are described in the Attachment to this report.
This inspection constitutes one reactor coolant system specific activity sample as
defined by Inspection Procedure 71151.
b.
Findings
No findings of significance were identified.
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ENCLOSURE 2
.3
Reactor Coolant System Leakage
a.
Inspection Scope
The inspectors sampled licensee submittals for the RCS Leakage PI for the period from
the third quarter of 2007 through the second quarter 2008. To determine the accuracy of
the PI data reported during those periods, PI definitions and guidance contained in
revision 5 of the Nuclear Energy Institute Document 99-02, Regulatory Assessment
Performance Indicator Guideline, were used. The inspectors reviewed the licensees
operator logs, RCS leakage tracking data, issue reports, event reports and NRC
Integrated Inspection reports for the period of July 2007 through June 2008 to validate
the accuracy of the submittals. The inspectors also reviewed the licensees CR
database to determine if any problems had been identified with the PI data collected or
transmitted for this indicator and none were identified. Specific documents reviewed are
described in the Attachment to this report.
This inspection constitutes one RCS leakage sample as defined by Inspection
Procedure 71151.
b.
Findings
No findings of significance were identified.
.4
Drill/Exercise Performance, Emergency Response Organization Drill Participation and
Alert and Notification System
a.
Inspection Scope
The inspectors reviewed licensee evaluations for the three emergency preparedness
cornerstone PIs of drill and exercise performance, emergency response organization
participation, and alert and notification system reliability, for the period October 2007
through June 2008. The definitions and guidance of Nuclear Energy Institute
Report 99-02, ARegulatory Assessment Indicator Guideline,@ Revisions 4 and 5, and the
licensees PI Procedure EN-EP-201, APerformance Indicators,@ Revisions 6 and 7, were
used to verify the accuracy of the licensee=s evaluations for each PI reported during the
assessment period. The inspector also performed Temporary Instruction 2515/175,
Emergency Response Organization, Drill/Exercise Performance Indicator, Program
Review.
The inspectors reviewed a one hundred percent sample of drill and exercise scenarios
and licensed operator simulator training sessions, notification forms, and attendance and
critique records associated with training sessions, drills, and exercises conducted during
the verification period. The inspectors reviewed selected emergency responder
qualification, training, and drill participation records. The inspectors reviewed alert and
notification system testing procedures, maintenance records, and a one hundred percent
sample of siren test records. The inspectors also reviewed other documents listed in the
attachment to this report.
This inspection constitutes three samples as defined by Inspection Procedure 71151.
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ENCLOSURE 2
b.
Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems (71152)
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical
Protection
.1
Selected Issue Followup Inspection: Probable Maximum Precipitation (PMP) Door Seals
a.
Inspection Scope
The inspectors reviewed condition reports documenting probable maximum precipitation
(PMP) door seals for (1) complete and accurate identification of the problem in a timely
manner; (2) consideration of extent of condition; (3) classification and prioritization of the
resolution of the problem; (4) identification of root and contributing causes of the
problem; (5) identification of corrective actions; and (6) completion of corrective actions
in a timely manner. The inspectors then performed a walk down of doors in the Train B
standby service pump house and determined that the seals for those doors appeared to
be degraded. The inspectors brought this to the attention of plant personnel. The plant
performed an inspection of these door seals and an extent of condition and determined
that eight out of eleven PMP doors seals protecting safety related equipment did not
meet procedural requirements.
The above constitutes completion of one in-depth problem identification and resolution
sample.
b.
Findings
Introduction. The inspectors identified a Green violation of 10 CFR Part 50 Appendix B,
Criterion V, Instructions, Procedures, and Drawings, involving the failure to perform an
adequate inspection of PMP door seals protecting safety related equipment.
Description. The licensee had previously received a noncited violation for inadequate
inspections of PMP door seals in NRC Inspection Report 05000416/2008002. On
July 9, 2008, the inspectors were performing a follow up inspection of the PMP door
seals at Grand Gulf from issues previously identified by the NRC in February 2008. The
inspectors found the entrance door to the standby service water Train B pump house not
meeting the standards of the maintenance procedure because the door seals failed to
make contact with the door. The inspectors notified plant personnel of their concerns
and an inspection of the standby service water pump house door seal determined that
the PMP seal was in a degraded condition. The extent of condition review found seven
additional door seals degraded, including the doors to the diesel generator building and
control building.
The plant had entered the previous NRC identified violation from February 2008 into the
corrective action program and completed actions to address non-compliant PMP door
seals by performing an inspection of all PMP door seals and replacing those seals
determined to be degraded. The plant also initiated compensatory actions for the
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ENCLOSURE 2
degraded seals, staging sand bags in the area and requiring monitoring of the affected
doors during heavy rainfall. The door seal on the standby service water Train B pump
house identified by the inspectors on July 9, 2008, had not been identified by plant
personnel during an extent of condition review on February 29, 2008. Based on the
replacement of four degraded PMP seals, the plant canceled their compensatory actions
on March 16, 2008. The licensee performed an apparent cause evaluation (ACE), which
included an extent of condition of all PMP seals. They concluded that they needed to
formally put in place a periodic replacement time frame for the seals which was
determined to be every five years. Additionally, they revised the inspection procedure by
adding a clarifying note to the maintenance procedure for inspection of PMP door seals.
Plant personnel restored compliance on July 9, 2008, when they reestablished the
previous discussed compensatory actions. The licensee performed another ACE and
determined that the PMP seals needed to be inspected quarterly and replacement of the
seals should be performed every three years.
The plant performed an engineering evaluation showing the amount of water that might
have entered the affected areas with the degraded door seals and presented this to the
inspectors. The site determined that under conservative assumptions, if a PMP event
occurred with the door seals in their degraded conditions, not enough water would have
entered the affected areas to disable the ability of the mitigating systems to perform their
safety function. The inspectors reviewed the analysis and decided that the plants
assumptions and conclusion were satisfactory.
Analysis. The inspectors determined that the failure to properly inspect and repair door
seals that protect safety-related equipment from a PMP event is a performance
deficiency. The finding is more than minor since it affects the protection against external
factors attribute of mitigating system cornerstone. The door seals also represent a
degrading condition that if left uncorrected could affect the availability, reliability, and
capability of mitigating systems required to respond to initiating events to prevent
undesirable consequences. Using the Manual Chapter 0609, Significance
Determination Process, Phase 1 Worksheet, the inspectors used the seismic, flooding,
and severe weather Table 4b and determined it would affect multi-trains of safety
equipment. The inspectors consulted the regional senior reactor analyst, who performed
a Phase 3 analysis using many bounding and conservative assumptions. The result was
a delta-CDF of 3.3E-7/yr and a delta-LERF of 6.6E-8/yr. These results confirmed that
the finding had very low safety significance (Green). The cause of this finding has a
crosscutting aspect in the area of problem identification and resolution in that the
licensee failed to take adequate corrective actions to ensure degraded PMP door seals
were properly evaluated and repaired in a timely manner P.1(d).
Enforcement. 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and
Drawings, states, in part, that activities affecting quality shall be accomplished in
accordance with prescribed procedures. Contrary to this requirement, from March 16
through July 9, 2008, the licensee failed to accomplish an activity affecting quality in
accordance with prescribed procedures. Specifically, the licensee failed to perform an
adequate inspection of PMP door seals protecting safety-related equipment as
prescribed in Procedure 07-S-14-310, Inspection of Mechanical Seals on Doors,
Revision 5. This finding has been entered into the licensees CAP as CR-GGN-2008-
03216. Due to the licensees failure to restore compliance from the previous
NCV 05000416/2008002-01 within a reasonable time after the violation was identified,
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ENCLOSURE 2
this violation is being cited as a Notice of Violation consistent with Section VI.A of the
Enforcement Policy: VIO 05000416/2008004-03, Failure to Perform an Adequate
Inspection of PMP Door Seals Protecting Safety Related Equipment.
.2
Routine Review of items Entered Into the CAP
a.
Inspection Scope
As part of the various baseline inspection procedures discussed in previous sections of
this report, the inspectors routinely reviewed issues during baseline inspection activities
and plant status reviews to verify that they were being entered into the licensees CAP at
an appropriate threshold, that adequate attention was being given to timely corrective
actions, and that adverse trends were identified and addressed. Attributes reviewed
included: the complete and accurate identification of the problem; that timeliness was
commensurate with the safety significance; that evaluation and disposition of
performance issues, generic implications, common causes, contributing factors, root
causes, extent of condition reviews, and previous occurrences reviews were proper and
adequate; and that the classification, prioritization, focus, and timeliness of corrective
actions were commensurate with safety and sufficient to prevent recurrence of the issue.
Minor issues entered into the licensees CAP as a result of the inspectors observations
are included in the attached list of documents reviewed.
These routine reviews for the identification and resolution of problems did not constitute
any additional inspection samples. Instead, by procedure they were considered an
integral part of the inspections performed during the quarter and documented in
Section 1 of this report.
b.
Findings
No findings of significance were identified.
.3
Daily CAP Reviews
a.
Scope
In order to assist with the identification of repetitive equipment failures and specific
human performance issues for follow-up, the inspectors performed a daily screening of
items entered into the licensees CAP. This review was accomplished through
inspection of the stations daily condition report packages.
These daily reviews were performed by procedure as part of the inspectors daily plant
status monitoring activities and, as such, did not constitute any separate inspection
samples.
b.
Findings
No findings of significance were identified.
- 24 -
ENCLOSURE 2
.4
Annual Sample Review
a.
Inspection Scope
The inspectors reviewed summaries of 233 condition reports associated with licensee
emergency preparedness and selected twenty-five condition reports for detailed review.
The reports were reviewed to ensure the full extent of issues were identified, that an
appropriate evaluation was performed, and appropriate corrective actions were identified
and prioritized. The inspectors evaluated the condition reports against the requirements
of licensee Procedure EN-LI-102, Corrective Action Process, Revision 12. The
inspectors also reviewed two condition reports generated during the inspection to
determine whether the issues were accurately characterized and assigned an
appropriate significance.
b.
Findings
No findings of significance were identified.
4OA3 Followup of Events and Notices of Enforcement Discretion (71153)
.1
Sulfuric Acid Storage Tank A Unisolable Leak
a.
Inspection Scope
The inspectors reviewed the plants response to an un-isolable leak from an acid storage
tank. On August 11, 2008, the plant personnel identified a 2-3 gallon per minute sulfuric
acid leak from the acid storage Tank A into the berm area around the tank. The
inspectors attended meetings, reviewed recovery, safety, and contingency plans.
Additionally, they evaluated the decision process involving emergency action levels.
Plant personnel along with vendor assistance stopped the leak by pumping the acid from
the leaking tank to two other storage tanks on site. The inspectors also observed the
interactions with the vendor that assisted the in the recovery. Documents reviewed in
this inspection are listed in the Attachment.
This inspection constitutes one sample as defined in Inspection Procedure 71153-05.
b.
Findings
No findings of significance were identified.
.2
Suspected Resin Intrusion
a.
Inspection Scope
The inspectors reviewed the response by plant personnel to a suspected resin intrusion
from the reactor water cleanup demineralizer system. On September 18, 2008, while
the plant was coasting down in power prior to RF16, the control room operators
identified that the expected coast down power trend flattened out, showing an effective
positive power increase in the reactor. The operators had recently attempted to place
the reactor water clean up (RWCU) filter/demineralizer in service, but then removed it
from service after the post-strainer showed a high differential pressure. The operators
- 25 -
ENCLOSURE 2
entered the off-normal event procedure for resin intrusion, suspecting that the power
increase had been caused by a resin intrusion from the RWCU system while placing the
filter in service. After further review, the reactor engineering staff concluded that the
coast down power trend had been displaying the flattening characteristic for some time,
hence would not be a result of placing the RWCU filter in service. The inspectors
responded to the control room and reviewed the RWCU system pressure and flow
trends, reactor power trends, plant chemistry trends, and the operators execution of the
off-normal event procedure. Documents reviewed in this inspection are listed in the
Attachment.
This inspection constitutes one sample as defined in Inspection Procedure 71153-05.
.3
(Closed) LER 05000416/2008-001-00 Manual Reactor SCRAM Due to Loss of Main
Electrical Output Transformer Cooling
On January 12, 2008, at 1626 hours0.0188 days <br />0.452 hours <br />0.00269 weeks <br />6.18693e-4 months <br />, the plant operators initiated a manual reactor scram from 99 percent power due to loss of cooling to the main transformers. The
cause of this event was the loss of cooling to the main transformers caused by loss of
auxiliary power to the main transformer cooling system. Inspection of the complete
circuit for main transformer auxiliary power showed that the Phase B power cables were
burned in two at the transfer switch panel. The cause of the Phase B power cable failure
was attributed to failure of an electrical compression connection on a lug connection.
This particular cable and connection had been inservice since plant start-up. The root
causes were determined to be use of a compression connection for high current
applications versus the preferred crimp type connection and an inadequate preventive
maintenance strategy to provide early detection. Corrective actions included an
inspection of the power panel and replacement of all damaged cabling. Documents
reviewed as part of this inspection are listed in the attachment. No findings of
significance were identified. This LER is closed.
.4
(Closed) LER 05000416/2008-002-00 Reactor SCRAM Due to Main Generator Trip
Caused by Unit Differential Lockout
On March 21,2008 at 1525 hours0.0177 days <br />0.424 hours <br />0.00252 weeks <br />5.802625e-4 months <br />, the plant experienced an actuation of the Reactor
Protection System (RPS) which resulted in an automatic scram from 100 percent power.
The scram was due to main turbine control valve fast closure. The cause of the event
was a main generator trip as the result of a Phase C unit differential lockout.
Troubleshooting which included inspection of the high voltage circuit and check of
calibration of both Relays A and B was initiated; however, no definitive cause for the trip
was identified. As a result of trouble shooting the licensee took the following corrective
actions. The low voltage CT circuit wiring and terminations were inspected to the extent
possible. The main generator neutral bushing Phase C in the circuit had a replacement
CT wired into the circuit. As a precaution, the suspect Phase C unit differential relay
was replaced. No evidence of an actual fault condition was found and no evidence of
animal intrusion in the high voltage bus work was found. Additionally, the calibration of
Relays A and B was checked and found to be acceptable. Documents reviewed as part
of this inspection are listed in the attachment. No findings of significance were identified.
This LER is closed.
- 26 -
ENCLOSURE 2
.5
(Closed) LER 05000416/2008-003-00 Increased Bus Voltage Results in Breaker Trip on
Over Current of a High Pressure Core Spray Pump Low Flow Valve Resulting in a Non-
Compliance with Technical Specification 3.6.1.3, Primary Containment Isolation Valve
Function
On March 05, 2008 at 1619, with the plant at about 99 percent reactor power,
emergency core cooling system (ECCS) surveillance testing was being performed of the
high pressure core spray (HPCS) pump and system. The HPCS low flow Valve 1E22-
F012 (also a primary containment isolation valve), while stroking from closed to open
position, de-energized and the HPCS loss or overload status light energized. The valve
was found in the non-closed position and the power supply breaker for the motor
actuator for the valve was found tripped open. This condition was considered a violation
of TS 3.6.1.3, Primary Containment Isolation Valve, due to exceeding the limiting
condition of operation (LCO) required action completion time of four hours to isolate the
penetration. The cause of Valve 1E22-F012 failure to close was due to its supply
breaker instantaneous over current trip settings being set too low, thus rendering the
valve inoperable. The investigation revealed that this condition had existed since the
early 1990s when bus voltages had been increased to a higher value to account for
under voltage events. Corrective actions were implemented which included replacement
of the Valve 1E22-F012 power supply breaker and increasing the instantaneous over
current trip settings. Breaker settings for the other ECCS motor operator valves that
were susceptible to this condition were checked and found to be acceptable.
Documents reviewed as part of this inspection are listed in the attachment. The
enforcement aspects of this finding were discussed in NRC Inspection Report 05000416/2008002 in Section 4OA3. This LER is closed.
4OA5 Other Activities
.1
Quarterly Resident Inspector Observations of Security Personnel and Activities
a.
Inspection Scope
During the inspection period the inspectors conducted observations of security force
personnel and activities to ensure that the activities were consistent with licensee
security procedures and regulatory requirements relating to nuclear plant security.
These observations took place during both normal and off-normal plant working hours.
These quarterly resident inspector observations of security force personnel and activities
did not constitute any additional inspection samples. Rather, they were considered an
integral part of the inspectors normal plant status reviews and inspection activities.
b.
Findings
No findings of significance were identified.
- 27 -
ENCLOSURE 2
4OA6 Management Meetings
.1
Exit Meeting Summary
On August 20, 2008, the branch chief conducted a regulatory performance meeting with
Mr. M. Krupa, Director Nuclear Safety Assurance, and other members of the licensee
staff to review corrective actions taken related to the White performance indicator for
unplanned scrams per 7000 critical hours in the first quarter of 2008.
On August 22, 2008, the emergency preparedness inspector presented the results of the
inspection of the onsite emergency preparedness program to Mr. R. Douet, Vice
President, Operations, and other members of his staff, who acknowledged the findings.
The inspectors confirmed that proprietary, sensitive, or personal information examined
during the inspection had been returned to the identified licensee custodian.
On September 29, 2008, the inspectors presented the inspection results to Mr. R. Douet
and other members of the licensee staff. The licensee acknowledged the issues
presented. The inspectors asked the licensee whether any materials examined during
the inspection should be considered proprietary. No proprietary information was
identified.
- 1 -
ATTACHMENT
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
D. Barfield, Director, Engineering
J. Browning, General Manager, Plant Operations
M. Causey, Maintenance Rule Engineer
R. Collins, Manager, Corrective Actions and Assessments
D. Coulter, Licensing Specialist, Plant Licensing
P. Different, Senior Lead Engineer, Reactor Engineering
R. Douet, Vice President, Operations
B. Edwards, Minority Owner Specialist
R. Gardner, Manger, Maintenance
E. Harris, Manager, Quality Assurance
R. Jackson, Licensing Specialist, Plant Licensing
D. Jones, Manager, System Engineering
M. Krupa, Director, Nuclear Safety and Assurance
G. Lantz, Supervisor, Design Engineering
M. Larson, Acting Manager, Plant Licensing
M. McAdory, Senior Operations Instructor
J. Owens, Licensing Specialist, Plant Licensing
W. Parman, Manager, Component Engineering
M. Rohrer, Manager, Planning, Scheduling and Outages
T. Tankersley, Manager, Training
T. Thornton, Manager, Design Engineering
F. Wilson, Manager, Operations
M. Wilson, Manager, Emergency Preparedness
R. Wilson, Superintendent, Radiation Protection
D. Wilson, Supervisor, Design Engineering
P. Worthington, Supervisor, Engineering
NRC Personnel
A. Barrett, Resident Inspector
G. Guerra, Senior Project Engineer
R. Smith, Senior Resident Inspector
- 2 -
ATTACHMENT
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened
None
Opened and Closed 05000416/2008004-01
Failure to Monitor Performance of Four Maintenance Rule
Systems05000416/2008004-02
Failure to Perform an Adequate Risk Assessment during
Adverse Weather Conditions05000416/2008004-03
Failure to Perform an Adequate Inspection of PMP Door
Seals Protecting Safety Related Equipment
Closed
05000416/2008-001-00
LER
Manual Reactor SCRAM Due to Loss of Main Electrical
Output Transformer Cooling
05000416/2008-002-00
LER
Reactor SCRAM Due to Main Generator Trip Caused by Unit
Differential Lockout
05000416/2008-003-00
LER
Increased Buss Voltages Results in Breaker Trip on Over
Current of a High Pressure Core Spray Pump Low Flow
Valve Resulting in Non-Compliance with Technical
Specification 3.6.1.3, Primary Containment Isolation Valve
Function
Discussed
None
- 3 -
ATTACHMENT
LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
Condition Report
CR-GNN-2008-1852
Procedures
NUMBER
TITLE
REVISION
08-S-04-120
Chemistry Evolutions at Standby Service Water
11
ENS-EP-302
Severe Weather Response
08
05-1-02-VI-2
Off Normal Event Procedure Hurricanes, Tornados,
and Severe Weather
110
Work Orders
Other
WTGNN-2008-0138
PL-159, Summer Reliability Plan, Revision 0
GGNS 2008 Summer Reliability Plan
SD Myers-The Transformer Consultants, TC-9018, Engineering Safety Feature Transformer 21
[07/2005-04/2008]
SD Myers-The Transformer Consultants,
TC-9016, Engineering Safety Feature (ESF) Transformer 12 [07/2005-11/2007]
TC-9017, Engineering Safety Feature (ESF) Transformer 11 [07/2005-07/2007]
TC-9018, Engineering Safety Feature (ESF) Transformer 21 [07/2005-07/2007]
Inside Entergy Newsletter:
Title
Plant
Date
Summer Reliability Planning
Grand Gulf
12/17/2002
Summer Reliability - We all Play a Part
Grand Gulf
05/20/2003
- 4 -
ATTACHMENT
Section 1R04: Equipment Alignment
Condition Report
Procedures
NUMBER
TITLE
REVISION
04-1-01-E22-1
High Pressure core Spray System
110
04-1-01-P75-1
Standby Diesel Generator System
076
05-1-02-I-4
Loss of AC Power
035
04-S-01-Z51-1
Control Room HVAC System
044
Work Orders
Other
Drawing M-1065, P&ID Condensate and Refueling Water Storage and Transfer System,
Revision 42
Drawing M-1086, P&ID High Pressure Core Spray System, Revision 30
Drawing M-1070, P&ID Standby Diesel Generator System, Revision 33
Drawing M-0049, P&ID Control Room HVAC System, Revision 42
Section 1R05: Fire Protection
Work Order
Other
Fire Pre-Plan DG-03, Division II Diesel Generator Room 1D303, Revision 04
Fire Pre-Plan A-06, HPCS Room 1A109, Revision 00
Fire Pre-Plan C-09 Control Building HVAC areas, Rooms OC302 and OC303 Revision 02
Fire Pre-Plan A-04, RHR B Pipe Penetration Room 1A205, Revision 01
- 5 -
ATTACHMENT
Fire Pre- Plan SSW-02, SSW B Pump and Valve Room 2M110/2M112, Revision 01
Fire Pre-Plan A-48, Auxiliary Building Elevation 208 Rooms 1A532, 1A602, 1A603, and 1A604,
Revision 01, Areas 9 & 10 Auxiliary Building Elevation 208
Fire Pre-Plan A-49, Auxiliary Building Elevation 245 Room 1A605, Revision 01
Fire Pre-Plan A-49, Auxiliary Building Elevation 245 Room 1A605, Revision 01
Section 1R06: Flooding
Condition Report
Procedures
NUMBER
TITLE
REVISION
05-1-02-VI-1
Off-Normal Event Procedure Flooding Safety Related
105
07-S-14-310
Inspection of Mechanical Seals on Doors Safety
Related
4
07-1-24-T10-1
Periodic Leak Check of Airtight Door Sealing
Surfaces Safety Related
4
Work Orders
Other
Drawing M-1094C, PI&D Floor and Equipment Drains System, Revision 21
Drawing M-109B, PI&D Floor and Equipment Drains System, Revision 21
Drawing M-1098E, PI&D Embedded and Suspended Drains Turbine Bldg., Revision 13
UFSAR, Water Level (Flood) Design, Section 3.4, Revision 8
UFSAR, Seismic Category I Components Protected from Environmental Floods, Table 3.4-2,
Revision 2.
Section 1R11: Licensed Operator Requalification Program
Other
GSMS-LOR-AEX01, C Level Instrument Failure/ FW Heater 6A Tube Leak/ FW Line Rupture
- 6 -
ATTACHMENT
in Drywell, Revision 05
GSMS-LOR-AEX08, RCIC Isolation/ A RFP Trip/ Loss of Feedwater/ ATWS, Revision 05
Section 1R12: Maintenance Effectiveness
Condition Reports
Procedures
NUMBER
TITLE
REVISION
1
Maintenance Rule Scope and Basis
1
Maintenance Rule Monitoring
1
Maintenance Rule a(1) Process
1
Maintenance Rule Periodic Assessment
1
Other
Maintenance Rule Program (a)(1) Evaluation for T46 ESF Electrical SWGR Rooms Cooling
System
Maintenance Rule Program (a)(1) Evaluation for Y47 SSW Ventilation System
Maintenance Rule Program (a)(1) Evaluation for X77 Diesel Generator Ventilation System
Maintenance Rule Program (a)(1) Evaluation for Z77 Emergency Switchgear and Battery Room
Ventilation System
Maintenance Rule Control Rod Drive System C11 (a)(1) Action Plan
Section 1R13: Maintenance Risk Assessments and Emergent Work Control
Condition Reports
- 7 -
ATTACHMENT
Procedures
NUMBER
TITLE
REVISION
On-line Work Management Process
3
01-S-18-6
Risk Assessment of Maintenance Activities
5
Other
EN-WM-101, On-Line Emergent Work Deletion Approval Form for CR-2008-03117
EN-WM-101, On-Line Emergent Work Addition Approval Form for CR-2008-03117
EN-WM-101, On-Line Emergent Work Addition Approval Form for IRM D
EN-WM-101, On-Line Emergent Work Addition Approval Form for Containment Channel B
Hydrogen Analyzer
EN-WM-101, On-Line Emergent Work Addition Approval Form for RPS B Normal and Alternate
Feeder Breakers
EN-WM-101, On-Line Emergent Work Addition Approval Form for Division 1 Diesel Generator
oil leak
Grand Gulf Nuclear Power Station - Weekly Risk Profile, Week July 7, 2008
Grand Gulf Nuclear Power Station - Weekly Risk Profile, Week July 21, 2008
Grand Gulf Nuclear Power Station - Weekly Risk Profile, Week September 8, 2008
Section 1R15: Operability Evaluations
Condition Reports
Procedures
NUMBER
TITLE
REVISION
06-EL-1L11-R-0001
125 Volt Battery Bank Physical Condition Check
102
04-S-04-2
Operation of Electrical Circuit Breakers
43
04-S-04-2
Operation of Electrical Circuit Breakers
44
Process Applicability Determination
07
- 8 -
ATTACHMENT
07-S-74-P71-1
LLRT Valve Alignment Procedure for Plant Chilled
Water Penetration
04
Work Orders
Other
P&ID M-1109D
Letter from Cameron to Grand Gulf Nuclear Station, August, 8, 2008, Revision 1
Section 1R18: Plant Modifications
Condition Reports
Other
PR-638 Cross Correlation Discussion Presentation
Section 1R19: Post Maintenance Testing
Condition Reports
Procedures
NUMBER
TITLE
REVISION
06-OP-1C41-Q-0001
Standby Liquid Control Functional Test
116
07-S-12-39
General Cleaning and Inspection of Non-Rotating
Electrical Equipment
7
07-S-12-40
General Cleaning and Inspection of Rotating
Electrical Equipment
2
- 9 -
ATTACHMENT
07-S-12-55
Insulation Resistance Testing - Meggering
10
06-ME-1M61-V-0003
Local Leak Rate Test - Low Pressure Water
104
06-OP-1P11-Q-0001
Condensate and Refueling Water Storage and
Transfer System Valve Operability Test
116
04-1-01-P75-1
Standby Diesel Generator System
76
06-OP-1P75-M0001
Standby Diesel Generator 11 Functional Test
129
02-S-01-28
Diesel Generator Start Information Sheet Division 1
DG, September 9, 2008
002
Work Orders
Other
EN-WM-101, On-Line work Addition/Deletion Approval Form for 1B21N679D, August 21, 2008
Clearance 1C16-1, P75-067-P75 Lube Oil A, 1-P75-Engine 1P75-E001A
Section 1R22: Surveillance Testing
Condition Report
Procedures
NUMBER
TITLE
REVISION
06-CH-1B21-O-002
Reactor Coolant Routine Chemistry
106
06-CH-1B21-W-0008
Reactor Coolant Dose Equivalent Iodine
104
06-EL-1E61-SA-0002
Hydrogen Ignition System Semi-Annual Test
105
06-ME-1M61-V-0001
Local Leak Rate Test Flow Air using Low Flow
Rotameter Panel or River Bend Volumetric Leak
Rate Monitor
110
06-OP-1C1-V-0003
APRM Functional Test
114
08-S-04-9
Obtaining Liquid Samples
15
- 10 -
ATTACHMENT
06-OP-1E12-Q-0024
LPCI/RHR Subsystem B Quarterly Functional Test
110
Work Orders
Other
CEP-IST-2, In-service Testing Plan, Revision 310
In-service Testing Performance database report for E12C002B
Section 1EP2: Alert and Notification System Evaluation
Procedures
NUMBER
TITLE
REVISION
EPIP 10-S-02-2
Maintaining the VIP 2000
8
EPIP 10-S-03
Emergency Preparedness Department
Responsibilities
14
Other
ANS Maintenance Rules and Expectations
Desk Guide, Alert Notification System Emergency Activation, January 2006
Section 1EP3: Emergency Response Organization Augmentation Testing
Procedure
NUMBER
TITLE
REVISION
EPIP 01-S-10-6
Emergency Response Organization
18-19
Quarterly Off-Hours Unannounced VIP 2000 Test Evaluation Reports
2006 - June 27, August 15, December 5
2007 - March 6, June 28, September 26, December 18
2008 - March 31, June 23
- 11 -
ATTACHMENT
Section 1EP5: Correction of Emergency Preparedness Weaknesses and Deficiencies
Condition Reports
Procedure
NUMBER
TITLE
REVISION
EPIP 10-S-26
Offsite Emergency Response
12
Quality Assurance Audits/Surveillances
Quality Assurance Audit QA-7-2006-GGNS-001, July 5, 2006
Quality Assurance Audit QA-7-2008-GGNS-1, July 29, 2008
Quality Assurance Surveillance QS-2006-GGNS-005, September 21, 2006
Quality Assurance Surveillance QS-2006-GGNS-007, October 10, 2006
Quality Assurance Surveillance QS-2007-GGNS-003, January 11, 2007
Quality Assurance Surveillance QS-2007-GGNS-012, September 4, 2007
Evaluation Reports for Drills Conducted
2006 - October 10, October 26, December 6
2007 - Feb 21, May 29, May 30, July 9, August 14, September 17, September 19, October 2,
October 18 (Yellow Team), October 18 (Red Team), October 23, November 5, November 7,
December 4, December 11
2008 - February 6, April 16, May 5, May 14, June 9, June 12
Other
Snapshot Assessment Report, LO-GG-2008-0036, July 25, 2008
Emergency Preparedness Corporate Assessment, July 5, 2006
- 12 -
ATTACHMENT
Standing Order 07-01, Siren Maintenance Issues, Revision 0, July 2, 2007
Standing Order 07-03, Maintaining ERO Qualifications
Section 1EP6: Drill Evaluation
Procedures
NUMBER
TITLE
REVISION
10-S-04-4
Emergency Preparedness Instruction
07
EN- EP-201
Performance Indicators
07
EN- LI-114
Performance Indicator Process
03
Other
GSMS-LOR-00195, Emergency Plan Exercises (EP-2, 2A, 3, 4), Revision 05
2008 NRC Performance Indicator Designated Events Memo, January 30, 2008
2008 NRC Performance Indicator Designated Events Memo, March 5, 2008
2008 NRC Performance Indicator Designated Events Memo, March 13, 2008
2008 NRC Performance Indicator Designated Events Memo, March 18, 2008
2008 NRC Performance Indicator Designated Events Memo, July 16, 2008
2008 NRC Performance Indicator Designated Events Memo, August 11, 2008
Section 4OA1: Performance Indicator Verification
Procedures
NUMBER
TITLE
REVISION
Performance Indicator Process
03
06-CH-1B21-W-0008
Reactor Coolant Dose Equivalent Iodine
104
Other
Third Quarter 2007 Core Thermal Power
March 2008 Core Thermal Power
November 2007 Core Thermal Power
June 2008 Core Thermal Power
- 13 -
ATTACHMENT
LER 2007-001
LER 2007-002
LER 2007-003
LER 2008-001
LER 2008-002
LER 2008-003
Section 4OA2: Problem Identification and Resolution
Condition Reports
Procedures
NUMBER
TITLE
REVISION
EPIP 10-S-01
Activation of the Emergency Plan - Classification
17
EPIP 10-S-03
Emergency Preparedness Department
Responsibilities
14
EPIP 10-S-06
Emergency Response Organization and Offsite
Notification
44
EPIP 10-S-12
Protective Action Recommendations
37-38
GSMS-LOR-00195
Emergency Plan Exercises
5
Other
Grand Gulf Nuclear Station Emergency Plan, Revision 59
Section 4OA3: Followup of Events and Notices of Enforcement Discretion
Condition Reports
Procedures
NUMBER
TITLE
REVISION
01-S-12-20
Hazardous Material Emergency Response Plan
05
- 14 -
ATTACHMENT
05-1-02-V-12
Condensate/Reactor Water High Conductivity
22
04-1-01-G33-1
Reactor Water Cleanup System
135
Work Order
Other
Acid Leak Recovery Schedule
LER 05000416/2008-001-00, Manual Reactor SCRAM Due to Loss of Main Electrical Output
Transformer Cooling
LER 2008-002-00, Reactor SCRAM Due to Main Generator Trip Caused by Current
Transformer Lockout
LER 05000416/2008-003-00, Increased Bus Voltage Results in Breaker Trip on Over Current of
a High Pressure Core Spray Pump Low Flow Valve Resulting in a Non-Compliance with
Technical Specification 3.6.1.3, Primary Containment Isolation Valve Function
LIST OF ACRONYMS USED
Apparent Cause Evaluation
Corrective Action Program
CR
Condition Report
CRAC
Control Room Air Conditioner
Division of Reactor Projects
Federal Emergency Management Agency
LCO
Limiting Condition for Operation
Leading Edge Flow Meter
LER
Licensee Event Report
Non-Cited Violation
NEI
Nuclear Energy Institute
NRC
U.S. Nuclear Regulatory Commission
Primary Containment Isolation Valve
Performance Indicator
Postmaintenance
Probable Maximum Precipitation
Reactor Water Clean Up
SBFA
Standby Fresh Air
Systems, Structures, and Components
TS
Technical Specification
Updated Final Safety Analysis Report
Updated Safety Analysis Report
Work Order