Junk Plant Grand Gulf-What a Absolute NRC Disgrace

Delay, Delay, Delay....

The NRC paper tiger...

Remember the abysmal capacity factor in the last two years, the four month shutdown over not following procedures and the recent slow start-up over unclear procedures.

No wonder the staff is so demoralized over a management philosophy such as what caused the below...

GRAND GULF NUCLEAR STATION – NRC TRIENNIAL FIRE PROTECTIONINSPECTION REPORT 05000416/2017008

Dear Mr. Larson:

On April 21, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Grand Gulf Nuclear Station and discussed the results of this inspection with you and other members of your staff.  The results of this inspection are documented in the enclosed report.

NRC-Identified and Self-Revealing Findings

 Cornerstone:  Mitigating Systems

• Green.  The team identified a non-cited violation of License Condition 2.C.(41) for failure to correct a condition adverse to fire protection in a timely manner.  Specifically, the licensee failed to complete evaluations of multiple spurious operations (MSO) concerns identified in 2011.  The licensee entered this finding into their corrective action program as Condition Report CR-GGN-2017-03996. 

The failure to correct a condition adverse to fire protection in a timely manner was a performance deficiency.  The performance deficiency was more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.  Specifically, untimely resolution of these MSO actuations placed the facility at risk of being unable to safely shutdown the facility in response to a fire. 

The finding was screened in accordance with Inspection Manual Chapter (IMC) 0609, “Significance Determination Process,” Attachment 4, “Initial Characterization of Findings,” dated June 19, 2012.  Because the finding affected the ability to achieve and maintain post-fire safe shutdown, the team reviewed the finding using IMC 0609, Appendix F, Attachment 1, “Fire Protection Significance Determination Process Worksheet,” dated September 20, 2013.  The finding was screened as a Green finding of very low safety significance in accordance with Task 1.3, “Ability to Achieve Safe Shutdown,” Question A.  Although the licensee failed to completely evaluate the impact of MSOs that could potentially result in the loss of suppression pool inventory, the team determined that for all fire areas one division of the residual heat removal system and the supporting standby service water system remained available along with suppression pool level indication.  The team confirmed that suppression pool makeup for the standby service water system would remain available.  For the postulated control room fire that led to control room evacuation, a senior reactor analyst performed a Phase 3 evaluation to determine the risk significance of this finding.  The senior reactor analyst determined this finding was of very low safety significance.  The finding had a cross-cutting aspect in the Conservative Bias component of the Human Performance area because the licensee failed to use decision making-practices that emphasize prudent choices over those that are simply allowable.  Specifically, the licensee reclassified a condition report to be non-adverse allowing resolution to be given a lower priority prior to completing the evaluations required to provide a technical basis for that decision [H.14].  (Section 1R05.01.b)

• Green.  The team identified a Green non-cited violation of Technical Specification 5.4.1.a for the failure to implement and maintain adequate written procedures covering a fire in the control room.  Specifically, the licensee failed to maintain an alternative shutdown procedure that ensured operators could safely shut down the plant under all postulated fire scenarios within the time limits established by the thermal hydraulic analysis.  The licensee entered this finding into their corrective action program as Condition Report CR-GGN-2017-04011.  As an immediate compensatory measure, the license issued Standing Order 17-0010 to provide operators additional guidance.  

The failure to implement and maintain adequate written procedures covering timed operator actions during a fire in the control room was a performance deficiency.  The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.  Specifically, the alternative shutdown procedure failed to ensure operators could safely shut down the plant under all postulated fire scenarios within the time limits established by the thermal hydraulic analysis.  The team evaluated this finding using Inspection Manual Chapter 0609, Appendix F, “Fire Protection Significance Determination Process,” dated September 20, 2013, because it affected the ability to reach and maintain safe shutdown conditions in case of a fire.  A senior reactor analyst performed a Phase 3 evaluation to determine the risk significance of this finding since it involved a postulated control room fire that led to control room evacuation.  The senior reactor analyst determined this finding was of very low safety significance.  

The finding did not have a cross-cutting aspect since it was not indicative of present performance in that the performance deficiency occurred more than 3 years ago.  (Section 1R05.05.b.1)

• Green.  The team identified a Green non-cited violation of License Condition 2.C.(41) for the failure to implement and maintain in effect all provisions of the approved fire protection program.  Specifically, the licensee failed to adequately isolate control circuits for safe shutdown equipment to ensure independence from the effects of a fire in the control room.  The licensee entered this finding into their corrective action program as Condition Report CR-GGN-2017-04028.  As an immediate compensatory measure, the licensee issued Standing Order 17-0010 to provide operators additional guidance. 

The failure to adequately isolate control circuits for safe shutdown equipment from the effects of a control room fire was a performance deficiency.  The performance deficiency was more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.  Specifically, the spurious actuation of safety relief valves would adversely affect the safe shutdown equipment relied upon to achieve and maintain safe shutdown conditions.  The team evaluated this finding using Inspection Manual Chapter 0609, Appendix F, “Fire Protection Significance Determination Process,” dated September 20, 2013, because it affected the ability to reach and maintain safe shutdown conditions in case of a fire.  A senior reactor analyst performed a Phase 3 evaluation to determine the risk significance of this finding since it involved a postulated control room fire that led to control room evacuation.  The senior reactor analyst determined this finding was of very low safety significance.  

The finding did not have a cross-cutting aspect since it was not indicative of present performance in that the performance deficiency occurred more than 3 years ago.  (Section 1R05.05.b.2)

• Green.  The team identified a Green non-cited violation of Technical Specification 5.4.1.a for the failure to maintain adequate written procedures covering a fire in the control room.  Specifically, the licensee failed to ensure that all steps in Procedure 05-1-02-II-1, “Shutdown from the Remote Shutdown Panel,” could be performed as written.  Specifically, the licensee’s procedure did not provide specific guidance to the control room staff on how to actuate the low pressure core spray pump breaker lockout relay.  The licensee initiated Condition Report CR-GGN-2017-03368 to address the deficiency and immediately implemented Standing Order 17-0009, which provides specific guidance to the control room staff on how to actuate the low pressure core spray pump breaker lockout relay.

The failure to provide a procedure that operators understood to implement the requirements of the approved fire protection program for a fire in the control room was a performance deficiency.  The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.  Specifically, the alternative shutdown procedure failed to ensure operators could safely shut down the plant during a control room fire causing circuit faults.  The team evaluated this finding using Inspection Manual Chapter 0609, Appendix F, “Fire Protection Significance Determination Process,” dated September 20, 2013, because it affected the ability to reach and maintain safe shutdown conditions in case of a fire.  A senior reactor analyst performed a Phase 3 evaluation to determine the risk significance of this finding since it involved a postulated control room fire that led to control room evacuation.  The Senior Reactor Analyst determined this finding was of very low safety significance.  

The finding did not have a cross-cutting aspect since it was not indicative of present performance in that the performance deficiency occurred more than 3 years ago.  (Section 1R05.05.b.3)