Generally when a plants declares they got fuel failure it implies to the public the plant is dirty. Being dirty inflames the minds of most people.This has severe public relations issues So that is why nobody openly discloses fuel failures.
August 14, 2019
SUBJECT: GRAND GULF NUCLEAR STATION – INTEGRATED INSPECTION REPORT 05000416/2019002
PLANT STATUS Unit 1 began the inspection period at full power. On April 6, 2019, operators reduced power to approximately 56 percent for control rod pattern adjustments. Full power operation resumed on April 8, 2019. On April 9, 2019, to allow for repair of a high pressure feedwater heater leak, power was reduced to approximately 66 percent. Power was increased to approximately 94 percent on April 12, 2019, with the high pressure feedwater heaters isolated. On April 16, 2019,Sounds like fuel failures. I have reason to believe there is generic issues with fuel failure.
power was reduced to approximately 65 percent to perform power suppression testing. Following repairs to the feedwater heater and power suppression testing, the unit reached full power on April 21, 2019. On May 12, 2019, due to a significant loss of plant service water, operators manually shut down the unit. Following repairs to the plant service water electrical distribution system, the unit was started up on May 19, 2019, and full power was achieved on May 30, 2019. On June 26, 2019, in order to support replacement of a recirculation flow control valve controller, operators reduced power to approximately 96 percent. On June 27, 2019, the unit reached full power and remained at or near full power for the remainder of the inspection period.
OTHER ACTIVITIES – TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 92723 - Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period (1 Sample) From December 9, 2016, through February 7, 2019, the NRC issued 10 Severity Level IV traditional enforcement violations associated with impeding the regulatory process. These violations, which are listed below, were issued in the following NRC Inspection Reports:
• 05000416/2016007 (ADAMS Accession No. ML16348A222), dated December 9, 2016 • 05000416/2017002 (ADAMS Accession No. ML17220A152), dated August 3, 2017 • 05000416/2017007 (ADAMS Accession No. ML17339A154), dated December 1, 2017 • 05000416/2018004 (ADAMS Accession No. ML19038A437), dated February 7,2019
Specifically, the violations included:
(1) Failure to Obtain NRC Approval for Changes to the Reactor Protection System, NRC-identified NCV 05000416/2016007-02;
(2) Failure to Obtain NRC Approval for Changes to Diesel Generator Trips and Flood Mitigation Strategy, NRC-identified NCV 05000416/2016007-03;
(3) Failure to Evaluate Delaying Inspection of Diesel Fuel Oil Storage Tank, NRC-identified NCV 05000416/2016007-04;(4) Failure to submit an annual effluent report in accordance with 10 CFR 72.44(d)(3); licensee-identified NCV documented in Inspection Report 05000416/2017002;
(5) Failure to report the results of the visual inspections of all accessible, susceptible locations of the steam dryer to the NRC staff within 60 days following startup in accordance with License Condition 2.C(46)(f), licensee-identified NCV documented in Inspection Report 05000416/2017002;
(6) Failure to submit a long-term steam dryer inspection plan based on industry operating experience along with the baseline inspection results for NRC review and approval in accordance with License Condition 2.C(46)(g), licensee-identified NCV documented in Inspection Report 05000416/2017002;
(7) Failure to notify the NRC within 4 hours of the occurrence of any event or condition that resulted in actuation of the reactor protection system when the reactor was critical in accordance with 10 CFR 50.72(b)(2)(iv)(B), licensee-identified NCV documented in Inspection Report 05000416/2017002;
(8) Failure to Update the Final Safety Analysis Report, NRC-identified NCV 05000416/2017007-04;
(9) Failure to make a timely event report for an event or condition that could have prevented fulfillment of a safety function (accident mitigation), licensee-identified NCV documented in Inspection Report 05000416/2018001;
(10) Failure to Update the Updated Final Safety Analysis Report, NRC-identified NCV 05000416/2018004-01.
In April 2019 the inspectors performed Inspection Procedure 92723, “Follow-up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period.” The inspectors reviewed the licensee’s cause evaluations and corrective actions associated with these issues in order to determine whether the licensee’s actions met the Inspection Procedure 92723 inspection objectives, which include: (1) providing assurance that the cause(s) of multiple Severity Level IV traditional enforcement violations are understood by the licensee; (2) providing assurance that the extent of condition and extent of cause of multiple Severity Level IV traditional enforcement violations are identified; and (3) providing assurance that licensee corrective actions to traditional enforcement violations are sufficient to address the cause(s).
INSPECTION RESULTS Observation: Follow-up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period 92723 Background
The inspectors noted that from January 1 to December 31, 2013, the NRC issued three Severity Level IV traditional enforcement violations associated with impeding the regulatory process, as documented in Annual Assessment Letter 05000416/2013001 (ADAMS Accession No. ML14063A338), dated March 4, 2014. Inspection Procedure 92723 was performed in response to four Severity Level IV traditional enforcement violations, as documented in Inspection Report 05000416/2014005 (ADAMS Accession No. ML15033A479), dated February 2, 2015. These violations involved accuracy and completeness of the Updated Final Safety Analysis Report, accuracy and completeness of information in the license renewal process, failure to report changes to the emergency plan, and failure to obtain a license amendment as required.The inspectors also noted that from January 1 to December 31, 2015, the NRC issued seven Severity Level IV traditional enforcement violations associated with impeding the regulatory process, as documented in Annual Assessment Letter 05000416/2015006 (ADAMS Accession No. ML16061A361), dated March 2, 2016. Inspection Procedure 92723 was again performed in response to these Severity level IV traditional enforcement violations, as documented in NRC Inspection Report 05000416/2016003 (ADAMS Accession No. ML16315A372), dated November 10, 2016. These violations involved two failures to update the Final Safety Analysis Report; a failure to maintain a safety-related cable tray overfill analysis record; an incomplete and inaccurate response to NRC Bulletin 88-04; a failure to obtain a license amendment; and two failures to make required event notifications or reports.
Considering these facts, the inspectors sought to understand why failures to update the Final Safety Analysis Report, failures to make required reports, and failures to obtain license amendments were issues that have continued to be identified and documented as recently as 2019.
Licensee Evaluation
The inspectors reviewed the licensee’s collective evaluations (completed at the “Condition Analysis” level) associated with the 10 CFR 50.59 issues and reporting issues, which included 10 CFR 50.71(e) and reporting issues. The inspectors also reviewed individual/combined evaluations associated with each of the 10 non-cited violations. The inspectors were not able to review in detail the latest revisions of the collective evaluation associated with Condition Report CR-GGN-2019-01002 (associated with 50.59 issues) and the adverse condition analysis associated with Condition Report CR-GGN-2018-01595 (associated with a late 8-hour notification) because preliminary versions of the evaluations were provided during the inspection. Evaluations reviewed included:
• CR-GGN-2019-01002, “50.59 Evaluations not Conducted as Required,” which evaluated the causes of 10 CFR 50.59 related violations (three issues with four total examples). CR-GGN-2017-01483 had previously been completed to address this group of issues. The individual issues included within this collective evaluation were evaluated by the following cause evaluations:
1. CR-GGN-2019-01007, dated March 14, 2019, which revised the licensee’s evaluations associated with CR-GGN-2016-09757 (two revisions); these cause evaluations were associated with violation (3), as listed above.
2. CR-GGN-2019-01185, dated March 20, 2019, which revised the licensee’s evaluations associated with CR-GGN-2016-08298 (two revisions); these cause evaluations were associated with violations (1) and (2), as listed above.
• CR-GGN-2019-01003, “Failure to Submit Reports to the NRC,” which evaluated the causes of failures to make reports to the NRC (five issues/examples) and failures toupdate the Final Safety Analysis Report (two issues with four total examples). CR-GGN-2017-07970 had previously been completed to address this group of issues. The individual issues included within this collective evaluation were evaluated by the following cause evaluations:
1. CR-GGN-2017-03404, dated May 22, 2017, and later revised on March 1, 2019; this cause evaluation was associated with violations (5) and (6), as listed above
2. CR-GGN-2017-12284, dated February 20, 2018, and later revised on March 1, 2019; this cause evaluation was associated with violation (8), as listed above
3. CR-GGN-2018-01595, dated March 27, 2018, and later revised March 1, 2019; this cause evaluation was associated with violation (9), as listed above
4. CR-GGN-2019-01047, dated March 22, 2019; this cause evaluation was associated with violation (10), as listed above
5. CR-GGN-2019-01390, dated March 1, 2019, which elevated the level of evaluation of CR-GGN-2017-03092, which was documented on March 27, 2017, at the “C” significance level; these were associated with violation (4), as listed above
6. CR-GGN-2019-01391, dated March 14, 2019, which elevated the level of evaluation of CR-GGN-2017-03331, which was documented on April 4, 2017, at the “C” significance level; these were associated with violation (7), as listed above
Assessment
Considering all the cause evaluations and relevant condition reports the inspectors identified 16 examples where the responsible manager failed to ensure all available and relevant information was acquired by reviews of pertinent industry events in accordance with step 4[2]e of Procedure EN-LI-118, “Cause Evaluation Process,” Revision 23. The licensee documented Condition Reports CR-GGN-2019-02684, CR-GGN-2019-02716, CR-GGN-2019-02733 to address these concerns. These examples included:
• Failure to review all relevant condition reports (such as CR-GGN-2015-05057) in the relevant internal operating experience section of the adverse condition analyses associated with CR-GGN-2019-01002 and CR-GGN-2019-01003
• Failure to review 17 relevant condition reports in the relevant internal operating experience section of the adverse condition analysis associated with CR-GGN-2017-12284
• Failure to include relevant internal operating experience detailed review attachments with the adverse condition analyses associated with CR-GGN-2017-12284, CR-GGN-2017-03404, CR-GGN-2019-01391, and CR-GGN-2018-01595
• Failure to perform internal operating experience repeat event reviews with the adverse condition analyses associated with CR-GGN-2018-01390, CR-GGN-2019-01047, and CR-GGN-2019-01391
• Failure to perform an adequate review of external operating experience with the adverse condition analyses associated with CR-GGN-2017-03404 and CR-GGN-2018-01390
• Failure to include relevant external operating experience detailed review attachments with the adverse condition analyses associated with CR-GGN-2017-12284, CR-GGN-2017-03404, CR-GGN-2019-01391, and CR-GGN-2018-01595
The inspectors also identified other issues during the review:
• The inspectors identified that Attachment 9.2, “UFSAR Change Process Flow Chart,” of Procedure EN-LI-113-01, “Updated Final Safety Analysis Report Change Process,” Revision 3, included numerous incorrect procedure step references. The licensee documented CR-GGN-2019-02674 to address the concern.
• The inspectors identified that a corrective action was not implemented to address a missed barrier identified as a factor in adverse condition analysis CR-GGN-2018-01595. This was associated with providing a procedure barrier to operators and licensing personnel when completing reportability evaluations. The licensee initiated CR-GGN-2019-02690 to address this observation.
• The licensee initiated CR-GGN-2019-02732 in response to the inspectors' questions on licensing basis document change request (LBDCR)/Updated Final Safety Analysis Report tracking not being defined.
Conclusions
The inspectors could not conclude that the inspection objectives were met because substantially relevant operating experience was not adequately considered and evaluated by the licensee when determining causes, extent of conditions, extent of causes, or corrective actions. Specifically, the inspectors identified that the conditions, scope, and causes associated with the two main collective evaluations and the previously performed root cause CR-GGN-2015-05057, which was associated with previous examples of incorrect maintenance of design and license basis documents, revealed substantive commonalities involving implementation and control of design change and license basis document changes; however, the CR-GGN-2015-05057 root cause analysis was not appropriately evaluated as relevant operating experience in the current evaluations. Corrective actions to prevent recurrence of root causes would be expected to prevent recurrence of the same performance deficiency.
Additionally, the licensee continues to identify LBDCR performance issues. Specifically, engineering changes with LBDCRs are still being evaluated to ensure all LBDCRs from 2000-2013 are appropriately tracked and coordinated. Also, a trend of incorrectly implemented LBDCRs during a software conversion is still being evaluated to determine causes and to ensure that conversion issues have been identified.
Finally, the inspectors could not conclude that the inspection objectives were met because the collective evaluations and additional causal analyses were being revised as of the completion of the inspection. As a result of this inspection, the licensee voluntarily determined that the conclusions of its collective evaluations needed to be reconsidered. The licensee planned to re-evaluate and revise its collective evaluations (CR-GGN-2019-01002 and CR-GGN-2019-01003) associated with the 10 violations and review the previous CR-GGN-2015-05057 root cause analysis to ensure that the causes, extent of conditions, extent of causes, and corrective actions were adequate. The licensee initiated CR-GGN-2019-02717 to document that adverse condition analyses associated with CR-GGN-2019-01002 and CR-GGN-2019-01003 did not adequately evaluate issues with configuration control of design and licensing basis documentation. The licensee informed the inspectors that a cause evaluation will be completed to address this concern.
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