One wonders how long the NRC was seeing this?
Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period
a. Inspection Scope The inspectors performed Inspection Procedure (IP) 92723, “Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period,” based on the results of the NRC’s annual review of station performance as documented in the 2015 assessment letter dated March 2, 2016, (ML16061A361). In 2015, the NRC issued the following seven Severity Level (SL) IV traditional enforcement violations in the area of impeding the regulatory process:
• NCV 05000416/2015002-03, “Failure to Update the Final Safety Analysis Report after the Extended Power Uprate”
• NCV 05000416/2015007-05, “Failure to Maintain a Safety-Related Cable Tray Overfill Analysis Record”
• NCV 05000416/2015007-07, “Failure to Update the Final Safety Analysis Report”
• NCV 05000416/2015007-08, “Incomplete and Inaccurate Response to NRC Bulletin 88-04”
• NCV 05000416/2015007-09, “Failure to Obtain a License Amendment for Use of Probabilistic Methods to Evaluate Tornado Missile Hazards”
• NCV 05000416/2015008-04, “Failure to Make Required Event Notification”
• NCV 05000416/2015004-03, “Failure to Make a Required Eight-Hour Report for Loss of Safety Function”
The inspectors reviewed the licensee’s cause evaluation and corrective actions associated with these issues in order to determine whether the licensee’s actions met the IP 92723 inspection objectives to provide assurance that: (1) the cause(s) of the violations are understood by the licensee, (2) the extent of condition and extent of cause of the violations are identified, and (3) licensee corrective actions to the violations are sufficient to address the cause(s).
What a horrible mess...how deep in the hole will they allow a plant go. I worry about the NRC...will allow numerous plants to decay into having capacity factor problems and being unsafe. There will be numerous plants sitting on the edge of being unsafe. The totality of this will be to keep the NRC to be very busy with putting out small fires, all this work will numb and over overwhelm the involved inspectors.
IR 05000416/2016003; 07/01/2016 - 09/30/2016, Grand Gulf Nuclear Station; Equipment Alignment, Heat Sink Performance, Problem Identification and Resolution.
The inspection activities described in this report were performed between July 1, 2016, and September 30, 2016, by the resident inspectors at Grand Gulf Nuclear Station and inspectors from the NRC’s Region IV office and other NRC offices. Four findings of very low safety significance (Green) are documented in this report. Three of these findings involved violations of NRC requirements. Further, inspectors documented a licensee-identified violation of very low safety significance in this report. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, “Significance Determination Process.” Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, “Aspects within the Cross-Cutting Areas.” Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRC’s program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, “Reactor Oversight Process.” Cornerstone: Initiating Events
• Green. The inspectors identified a finding for the licensee’s failure to aggressively and fully communicate an operational decision-making instruction implementation action plan, particularly the trigger points and those actions if trigger points are exceeded, to the appropriate operations shift personnel via operations management in accordance with Procedure EN-OP-111, “Operational Decision-Making Issue Process.” Specifically, on July 3, 2016, Grand Gulf Nuclear Station operations management created an operational decision-making instruction, but did not communicate to onshift operators the trigger points and actions associated with uncontrolled power oscillations that occurred on June 17, 2016. The licensee implemented immediate corrective actions by communicating the operational decision-making instruction trigger points to all onshift operators, as well as creating an offnormal event procedure. This finding was entered into the licensee’s corrective action program as Condition Report CR-GGN-2016-06032. The failure to follow Procedure EN-OP-111 to aggressively and fully communicate an operational decision-making instruction implementation action plan, particularly the trigger points and those actions if trigger points are exceeded, to the appropriate operations shift personnel via operations management was a performance deficiency. This performance deficiency is more than minor, and therefore a finding, because it is associated with the human performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, operations management did not communicate operational decision-making instruction trigger points and actions to ensure appropriate operator response to limit the liklihood of events that upset plant stability, similar to the reactor pressure and power oscillations that occurred on June 17, 2016. Using Inspection Manual Chapter 0609, Appendix A, “The Significance Determination Process (SDP) for Findings At-Power,” and Inspection Manual Chapter 0609, Appendix A, Exhibit 1, “Initiating Events Screening Questions,” the inspectors determined that the finding was of very low safety significance (Green) because the finding did not cause a reactor trip.
The inspectors determined that the finding has a change management cross-cutting aspect within the human performance area because licensee management failed to use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, the licensee failed to use the operational decisionmaking instruction process effectively such that the operational decision-making instruction was communicated and could be implemented as intended [H.3]. (Section 4OA2.2.3)
Cornerstone: Mitigating Systems • Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, “Corrective Action,” which states, in part, “conditions adverse to quality are promptly identified and corrected.” Specifically, prior to April 2012, the licensee did not correct identified deficiencies affecting work order instructions and acceptance criteria to perform surveillance requirements associated with safety-related fuel pool cooling and cleanup heat exchangers. In response to this issue, the licensee revised the associated procedure to provide appropriate quantitative and qualitative acceptance criteria. This finding was entered into the licensee’s corrective action program as Condition Report CR-GGN-2016-07257. The failure to promptly correct procedures and work order instructions used to perform program testing of safety-related heat exchangers was a performance deficiency. Specifically, the licensee did not promptly correct identified inadequate work order instructions or acceptance criteria to perform surveillance requirements associated with safety-related fuel pool cooling and cleanup heat exchangers from April 2012 until September 30, 2016. The inspectors determined that it was reasonable for the licensee to be able to foresee and prevent occurrence this deficiency. This performance deficiency is more than minor, and therefore a finding, because it is associated with the procedure quality attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., fuel damage). Specifically, the inspectors concluded that without appropriate quantitative and qualitative acceptance criteria, the availability, reliability, and capability of the fuel pool cooling and cleanup heat exchangers would not be effectively ensured through the performance of surveillance requirements. The inspectors evaluated this finding using NRC Inspection Manual Chapter 0609, Attachment 0609.04, “Phase 1 – Initial Screening and Characterization of Findings.” The inspectors determined that the finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not represent a loss of a safety function of a system or a single train for greater than its technical specification allowed outage time, and did not screen potentially risk significant due to external events. The finding has a crosscutting aspect in the area of human performance, documentation, because the licensee did not create and maintain complete, accurate, and up-to-date documentation for the safety-related heat exchanger testing program [H.7]. (Section 1R07) • Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, “Corrective Action,” for failure to promptly identify a condition adverse to quality. Specifically, operations personnel failed to identify oscillations in the reactor core isolation cooling transmitter logic system during technical specification surveillance control panel walk-downs. This resulted in an automatic isolation of the reactor core isolation cooling system from its steam supply. Approximately six hours after the isolation, maintenance personnel performed a flow transmitter system fill and vent, and the system was returned to an operable condition. This finding was entered into the licensee’s corrective action program as Condition Report CR-GGN-2016-03070.
The failure to promptly identify oscillations in the reactor core isolation cooling transmitter logic system was a performance deficiency. This performance deficiency is more than minor, and therefore a finding, because it is associated with the human performance attribute of the Mitigating Systems Cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, operations personnel failed to identify oscillations in the reactor core isolation cooling transmitter logic system, which resulted in an isolation and unavailability of the reactor core isolation cooling system. Using Inspection Manual Chapter 0609, Appendix A, “The Significance Determination Process (SDP) for Findings At-Power,” and Inspection Manual Chapter 0609, Appendix A, Exhibit 2, “Mitigating Systems Screening Questions,” the inspectors determined that the finding is of very low safety significance (Green) because it was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; did not represent a loss of system and/or function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-ofservice for longer than their technical specification allowed outage time; and did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensee’s maintenance rule program.
In addition, the inspectors determined that the finding has a challenge the unknown crosscutting aspect within the human performance area because the licensee failed to stop when faced with uncertain conditions and evaluate and manage risk before proceeding. Specifically, when performing multiple sets of operator control panel walk-downs, which should have resulted in the identification of oscillations in the reactor core isolation cooling transmitter logic system, the operators failed to recognize and correlate that the small oscillations were an abnormal system condition and could lead to a reactor core isolation cooling system isolation [H.11]. (Section 1R04)
• Green. The inspectors reviewed a self-revealed, non-cited violation of Technical Specification 5.4.1.a for the failure to establish a procedure for combating malfunctions of the reactor pressure control system. Specifically, on June 17, 2016, operators combated a malfunction in the reactor pressure control system associated with an unexpected turbine stop valve closure without having appropriate procedures. The licensee implemented immediate corrective actions by creating a standing order that gave clear guidance on how to control issues that cause oscillations, and has since created an offnormal event procedure for reactor pressure control system malfunctions. This finding was entered into the licensee’s corrective action program as Condition Report CR-GGN-2016-04834. The failure to establish a procedure for combating malfunctions of the reactor pressure control system was a performance deficiency. This performance deficiency is more than minor, and therefore a finding, because it is associated with the procedure quality attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, operators were combating a malfunction in the reactor pressure control system associated with an unexpected turbine stop valve closure without having a procedure. As a result, the operators were unable to reconcile the pressure control malfunction, did not manually scram the reactor, and ultimately caused an automatic reactor scram. Using Inspection Manual Chapter 0609, Appendix A, “The Significance Determination Process (SDP) for Findings At-Power,” and Inspection Manual Chapter 0609, Appendix A, Exhibit 2, “Mitigating Systems Screening Questions,” the inspectors determined that the finding resulted in themismanagement of reactivity by operators and required an evaluation using Inspection Manual Chapter 0609, Appendix M, “Significance Determination Process Using Qualitative Criteria.” A senior reactor analyst performed an evaluation to bound the increase in core damage frequency of the finding. Based on the results of this evaluation, the final significance of the finding was determined to be very low safety significance (Green).
In addition, the inspectors determined that the finding has an identification cross-cutting aspect within the problem identification and resolution area because the licensee failed to identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, the licensee failed to identify that they were missing an offnormal event procedure for malfunctions of the reactor pressure control system following a 2015 half scram that occurred while conducting the same testing as that which led to this event
[P.1]. (Section 4OA2.2.2) Licensee-Identified Violations
A violation of very low safety significance that was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee’s corrective action program. This violation and associated corrective action tracking numbers are listed in Section 4OA7 of this report.
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