IR 05000416/2018004

NRC Integrated Inspection Report 05000416/2018004

ML19038A437
Person / Time
Site:	Grand Gulf
Issue date:	02/07/2019
From:	Jason Kozal NRC/RGN-IV/DRP/RPB-C
To:	Emily Larson Entergy Operations
References
IR 2018004
Download: ML19038A437 (64)

Text

February 7, 2019

SUBJECT:

GRAND GULF NUCLEAR STATION - NRC INTEGRATED INSPECTION REPORT 05000416/2018004

Dear Mr. Larson:

On December 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Grand Gulf Nuclear Station. On January 10, 2019, the NRC inspectors 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 inspectors documented five findings of very low safety significance (Green) in this report.

All of these findings involved violations of NRC requirements. Additionally, NRC inspectors documented one Severity Level IV violation with no associated finding. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

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, will be performed for nine previous violations in the area of impeding the regulatory process, as described in NRC Inspection Reports: 05000416/2016007 dated December 9, 2016; 05000416/2017002 dated August 3, 2017; 05000416/2017007 dated December 1, 2017; and 05000416/2018001 dated May 14, 2018. The additional Severity Level IV traditional enforcement violation documented in this report will be included in the scope of an Inspection Procedure 92723 inspection to assess your evaluation of the violations and review the adequacy of associated corrective actions.

If you contest the violations or significance of these NCVs, 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 copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Grand Gulf Nuclear Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Grand Gulf Nuclear Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Jason W. Kozal, Chief Project Branch C Division of Reactor Projects

Docket No. 50-416 License No. NPF-29

Enclosure:

Inspection Report 05000416/2018004 w/attachments:

1. Documents Reviewed 2. Focused Baseline Inspection Request for Information 3. Public Radiation Safety Inspection Request for Information

Enclosure U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number:

05000416

License Number:

NPF-29

Report Number:

05000416/2018004

Licensee:

Entergy Operations, Inc.

Facility:

Grand Gulf Nuclear Station, Unit 1

Location:

Port Gibson, Mississippi

Inspection Dates:

October 1, 2018 to December 31, 2018

Inspectors:

T. Steadham, Senior Resident Inspector

D. Bradley, Senior Resident Inspector, Callaway Plant

N. Day, Resident Inspector

B. Parks, Resident Inspector, River Bend Nuclear Station

C. Young, Senior Project Engineer

L. Carson II, Sr. Health Physicist

N. Greene, PhD, Sr. Health Physicist

B. Baca, Health Physicist

J. ODonnell, CHP, Health Physicist

S. Hedger, Emergency Preparedness Inspector

G. George, Senior Reactor Inspector

I. Anchondo, Reactor Inspector

W. Cullum, Reactor Inspector

M. Hayes, Operations Engineer

Approved By:

Jason W. Kozal

Branch Chief

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Grand Gulf Nuclear Station, Unit 1, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified and self-revealed violations, and additional items, are summarized in the tables below.

List of Findings and Violations

Failure to Update the Updated Final Safety Analysis Report Cornerstone Significance Cross-cutting Aspect Inspection Procedure Not Applicable Severity Level IV NCV 05000416/2018004-01 Closed Not Applicable 71111.04 -

Equipment Alignment The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.71(e) when the licensee failed to update the Updated Final Safety Analysis Report Table 9.2-16.

Failure to Implement Lubrication Oil Program for Quality Systems Cornerstone Significance Cross-cutting Aspect Inspection Procedure Mitigating Systems Green NCV 05000416/2018004-02 Closed H.2 - Human Performance,

Field Presence 71111.12 -

Maintenance Effectiveness The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a,

Procedures, for the licensees failure to implement procedures for the lubrication program for safety-related and quality components. Specifically, licensee Procedure SEP-LUB-GGN-001,

GGN Lubrication Program, Revision 1, requires appropriate storage, issuance, and recordkeeping for oils used in safety-related and quality systems. The licensee failed to implement the procedure, including unauthorized storage locations and 28 examples of inadequate records across four safety-related and quality systems.

Design Control for Reactor Core Isolation Cooling and Emergency Diesel Generators Cornerstone Significance Cross-cutting Aspect Inspection Procedure Mitigating Systems Green NCV 05000416/2018004-03 Closed H.12 -

Human Performance,

Avoid Complacency 71111.12 -

Maintenance Effectiveness The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B,

Criterion III, Design Control, for the licensees failure to correctly translate the design basis of the reactor core isolation cooling system and the emergency diesel generators into specifications and procedures. Specifically, the reactor core isolation cooling system and the emergency diesel generators required governor oil to be filtered; however, the licensee performed this task outside of a quality process and did not specify filtration as a critical characteristic in the commercial grade dedication process for the oil.

Failure to Adequately Lubricate Motor-Operated Valve Stem Nut Cornerstone Significance Cross-cutting Aspect Inspection Procedure Mitigating Systems Green NCV 05000416/2018004-04 Closed None 71111.13 -

Maintenance Risk Assessments and Emergent Work Control A self-revealed, Green, non-cited violation of Technical Specification 5.4.1.a, Procedures, was identified when the licensee failed to have adequate instructions to perform preventive maintenance. Specifically, the licensee failed to properly lubricate the Division 1 residual heat removal heat exchanger bypass valve E12F048A and the valve failed to stroke during a surveillance test.

Failure to Perform Complete Evaluations of the Licensee Interface with Offsite Organizations Cornerstone Significance Cross-cutting Aspect Inspection Procedure Emergency Preparedness Green NCV 05000416/2018004-05 Closed H.8 - Human Performance,

Procedure Adherence 71114.05-Maintenance of Emergency Preparedness The inspector identified a Green, non-cited violation of 10 CFR 50.54(t)(2) for the licensees failure to include an evaluation of the adequacy of the interfaces with State and local governments in a review of emergency preparedness program elements in Audit Reports QA-07-2017-GGNS-1 and QA-07-2018-GGNS-1. Specifically, audit personnel did not provide offsite officials with an opportunity to provide their view of the adequacy of the interface to the audit team, resulting in a failure to evaluate this interface.

Failure to Conduct Drills in Accordance with the Site Emergency Plan Cornerstone Significance Cross-cutting Aspect Inspection Procedure Emergency Preparedness Green NCV 05000416/2018004-06 Closed H.9 - Human Performance,

Training 71114.05-Maintenance of Emergency Preparedness The inspector identified a Green, non-cited violation of 10 CFR 50.54(q)(2) associated with the licensees failure to follow the stations emergency plan. Specifically, the licensee failed to follow Grand Gulf Nuclear Station Emergency Plan, Revisions 66 to 77, Section 8.3.2.c, which requires an annual drill to determine the effectiveness of the local fire department working in conjunction with the licensee fire brigade. The licensee failed to conduct correctly scoped annual fire brigade drills from 2012 to 2017.

Additional Tracking Items

Type Issue number Title Inspection Procedure Status VIO 05000416/2017012-01 Failure to Correct Instrument Calibration Process in a Timely Manner 71124.05 Closed LER 05000416/2016-002-01 Automatic Actuation of the Reactor Protection System Due to B Main Transformer Wiring 71153 Closed LER 05000416/2016-006-01 Multiple Valid Engineered Safety Feature Actuations 71153 Closed

PLANT STATUS

Unit 1 began this inspection period at approximately 95 percent power for startup activities and reached full power on October 3, 2018. On November 2, 2018, operators reduced power to approximately 50 percent for control rod pattern adjustments. Full power operation resumed on November 8, 2018. On November 16, 2018, to investigate high vibrations on condensate pump A, power was reduced to approximately 70 percent. The unit returned to full-rated power the following day. On December 12, 2018, operators manually shut down the unit due to turbine bypass valve A drifting open. Following repairs, the unit was started up on December 17, 2018, and reached full power on December 25, 2018, and remained at or near full power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01Adverse Weather Protection Seasonal Extreme Weather

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures.

71111.04Equipment Alignment Partial Walkdown

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Division 1 standby service water on November 19, 2018

(2) Control rod drive system on December 17, 2018

(3) Low pressure core spray on December 17, 2018

(4) Circulating water on December 17, 2018

(5) Division 2 standby gas treatment following system maintenance on December 18, 2018

71111.05AQFire Protection Annual/Quarterly Quarterly Inspection

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Auxiliary building 119 feet elevation, Fire Area 6, Zone 1A201, on October 25, 2018

(2) Auxiliary building 139 feet elevation, Fire Area 11, Zone 1A322, on October 25, 2018

(3) Standby service water pump room A, Fire Area 64, Zone 1M110, on November 19, 2018

(4) Auxiliary building railroad bay, Fire Area 17, Zone 1A325, on November 27, 2018

71111.07Heat Sink Performance Heat Sink

The inspectors evaluated control room air conditioning A thermal performance testing on October 23, 2018.

71111.11Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed and evaluated a simulated loss-of-coolant accident annual exam scenario on November 27, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated thyristor voltage regulator post modification testing during 100 percent power, high integrated risk conditions, on October 23, 2018.

Operator Exams (1 Sample)

The inspectors reviewed and evaluated requalification examination results on January 15, 2019.

71111.12Maintenance Effectiveness Routine Maintenance Effectiveness

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety-significant functions:

(1) R14 main transformers on November 26, 2018

(2) E22 high pressure core spray on November 26, 2018

(3) P45 floor and equipment drain systems on December 31, 2018

Quality Control (1 Sample)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issues:

(1) Oil used in safety-related and technical specification systems including reactor core isolation cooling, emergency diesel generators, residual heat removal, standby service water, low pressure core spray, and high pressure core spray, on October 11, 2018

71111.13Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Elevated risk due to residual heat removal B system outage on October 19, 2018

(2) Condensate pump A high vibration repairs on November 16, 2018

(3) Yellow risk due to reactor core isolation cooling outage on November 26, 2018

(4) Risk management actions for startup following Forced Outage 22-02 on December 14, 2018

(5) Severe weather due to tornado warning in Tensas Parish on December 27, 2018

71111.15Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Reactor core isolation cooling oil contamination, Condition Report CR-GGN-2018-10179, on October 11, 2018

(2) Corrosion found on 1A3, Division 1 safety batteries, Condition Report CR-GGN-2018-11724, on October 31, 2018

(3) Inadequate thread engagement on auxiliary building door guide, Condition Report CR-GGN-2018-12231, on November 15, 2018

(4) Reactor core isolation cooling operability following delayed injection after December 12, 2018, scram, Condition Report CR-GGN-2018-13050 on December 17, 2018

71111.17TEvaluations of Changes, Tests and Experiments

The inspectors evaluated the following from December 10, 2018, to December 14, 2018:

10 CFR 50.59 Evaluations

(1) Safety Evaluation (SE) 2016-002-R00, Evaluate Negative Pressure in the Reactor Vessel for the Pressure Temperature Curves in the PTLR

(2) SE-2016-003-00, Implementation of MELLLA+ and Residual Heat Removal Heat Exchanger Bypass Valve Timer

(3) SE-2016-005-R01, EC 66685 Will Modify the Division III Diesel Generator Engine High Crankcase Pressure Trip to Bypass the Trip for Approximately 10 Seconds

(4) SE-2016-006, Standby Service Water Cooling Tower Fan Operation During Cold Weather

(5) SE-2017-001-R01, Change to Reactor Core Isolation Cooling Room Temperature Relay

(6) SE-2017-002-R00, EC 74136 Calculation MC-Q1P75-17001

(7) SE-2017-003-R00, Insert Blind Fitting Outboard of Penetration #73 to Eliminate Diving to Perform Local Leak Rate Testing for Containment Penetration #73

(8) SE-2017-004-R00, Calculation of Maximum Allowable Leakage Limits for Standby Liquid Control System with Restricting Orifice 1C41-RO-D001 Passing Flow During Anticipated Transient Without Scram

(9) SE-2018-004-R00, Compensatory Actions for Sand Bagging Control Building Diesel Generator and Standby Service Water Pumphouse Doors for CR-GGN-2018-4101 CA-1 10 CFR 50.59 Screening/Applicability Determinations

(1) Engineering Change (EC) 47972, Increasing the Orifice Size for the P41D013 to Increase SSW Flow to the HPCS Room Cooler and HPCS Diesel Generator Jacket Water Coolers CR-GGN-2013-7465/LO-GLO-2014-0048, CA 19

(2) EC 48893, EC Will Relocate 4 out of 5 RTDs Located in Each Plant Air Compressor

(3) EC 51721, Remove UFR Relay from RPS MG Set B, 1C71S001B

(4) EC 58557, TMod for Leak Repair (Line Crimp) on Drain Line from 1E51F219

(5) EC 60805, Installation of Two Vent Valves in the RCIC Room at Floor Level and Installs a Sight Glass

(6) EC 63217, Emergency Temp Mod to Maintain Acceptable Division 1 Battery Room Temperature

(7) EC 63736, Equivalency for Firmware Version Changes and Approval of New Qualification Report NUS-A076QA Rev 6 for NUS Temperature Monitor Model NUS-A076PA-1

(8) EC 66961, Leak Repair Evaluation on Affected Welds between the Sock-O-Let Attached to 28-DBD-16 and 1-DBD-123 Drain Line Upstream of Drain Valve 1N21F107B

(9) EC 67917, Operability Input for Division III HPCS Diesel Generator Accepts As-is Condition for Cracked Welds

(10) EC 74074, Temporary Modification for Commencing Plant Startup while Having Only the Inner 1/2 Plate Installed for the RHR A Room HELB Wall Barrier

(11) EC 75867, Revise MC-Q1P41-97020 and MC-Q1P41-99003 to Incorporate the Full IST Degradation Allowance of 7% and Incorporate the Use of SRSS Method in Calculations

(12) EC 76351, Analysis of the Heat Removal Capability of ADHRS in RF21

(13) EC 76977, Review of Patel Engineering Test Report PEI-TR-841209-04 for Patel Thread Sealants

(14) EC 77034, Evaluate Use of Oakite 32 for Flushing the Recirc Pump Seal Cooler

(15) EC 78125, LLRT from Reverse Side for 1E12F028A/B

(16) EC 75846, Calculation of Maximum Pressure Allow in the SSW Instrument Lines

(17) Field Change Request 74210, Remove the LCO 3.0.9 Requirement from EC No. 74074

71111.18Plant Modifications

The inspectors evaluated the following temporary or permanent modifications:

(1) CN5080, technical specification bases change to required standby service water flowrate to residual heat removal heat exchangers on November 20, 2018

(2) Change of thread sealant used in environmental qualification applications on November 26, 2018

71111.19Post Maintenance Testing

The inspectors evaluated the following post-maintenance tests:

(1) Reactor core isolation cooling room cooler post bearing, shaft, and belt maintenance on October 16, 2018

(2) Secondary containment door post configuration change on November 13, 2018

(3) Reactor core isolation cooling outage post maintenance test on November 26, 2018

(4) Division I emergency diesel generator fuel oil fitting replacement on November 27, 2018

(5) Reactor core isolation cooling injection valve 1E51F013 motor inspection, Work Order 52689971 on December 19, 2018

(6) Implement Engineering Change 60805, replace reactor core isolation cooling valves and sight glass on December 19, 2018

(7) Bypass valve A coil replacement on December 20, 2018

71111.22Surveillance Testing The inspectors evaluated the following surveillance tests: Routine

(1) Reactor core isolation cooling/residual heat removal steam line high flow functional test Channel A on October 30, 2018

71114.02Alert and Notification System Testing

The inspector evaluated the maintenance and testing of the alert and notification system between January 3, 2017, and November 2, 2018.

71114.03Emergency Response Organization Staffing and Augmentation System

The inspector evaluated the readiness of the Emergency Response Organization between January 3, 2017, and November 2, 2018. The inspector also evaluated the licensees ability to staff their emergency response facilities in accordance with emergency plan commitments.

71114.04Emergency Action Level and Emergency Plan Changes

The inspector evaluated Emergency Plan Revisions 76 and 77, submitted on October 3, 2017, and July 30, 2018, respectively. In addition, the inspector evaluated the 10 CFR 50.54(q) emergency plan change process and practices between January 3, 2017, and November 2, 2018. The evaluation reviewed screenings and evaluations documenting the implementation of this process. The reviews of the change process documentation and the Emergency Plan change do not constitute NRC approval.

71114.05Maintenance of Emergency Preparedness

The inspector evaluated the maintenance of the emergency preparedness program between January 3, 2017, and November 2, 2018. The evaluation reviewed activations of the emergency plan, the conduct of drills and exercises, licensee audits and assessments, and the maintenance of equipment important to emergency preparedness.

71114.06Drill Evaluation Emergency Planning Drill

The inspectors evaluated:

(1) A simulated loss-of-coolant accident with offsite release drill on October 2, 2018

(2) A simulated loss-of-coolant accident with offsite release drill on November 14,

RADIATION SAFETY

71124.05Radiation Monitoring Instrumentation Walk Downs and Observations

The inspectors evaluated radiation monitoring instrumentation during plant walkdowns.

Calibration and Testing Program (1 Sample)

The inspectors evaluated the licensees calibration and testing program.

The inspectors reviewed the licensees responses to Notice of Violation (NOV)05000416/2017012-01, dated September 21, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17269A031) and December 21, 2017 (ADAMS Accession No. ML17362A041), as documented in a letter to the licensee, dated February 7, 2018 (ADAMS Accession No. ML18038B584). At that time, it was determined that an onsite review of the implementation of the corrective actions would be conducted to determine whether full compliance had been achieved and would be maintained. The inspectors reviewed the aforementioned documents, relevant corrective action documents, the revised procedures, and completed surveillances. The inspectors determined that the causal analysis results, corrective actions taken and planned to address recurrence, and the date when full compliance will be/was achieved for this violation have been adequately addressed; as a result, the NOV is closed.

71124.06Radioactive Gaseous and Liquid Effluent Treatment Walk Downs and Observations

The inspectors evaluated the licensees radioactive gaseous and liquid effluent treatment systems during plant walkdowns.

Calibration and Testing Program (Process and Effluent Monitors) (1 Sample)

The inspectors evaluated the licensees gaseous and liquid effluent monitor instrument calibration and testing.

Sampling and Analyses (1 Sample)

The inspectors evaluated radioactive effluent sampling and analysis activities.

Instrumentation and Equipment (1 Sample)

The inspectors evaluated radioactive effluent instrumentation and equipment.

Dose Calculations (1 Sample)

The inspectors evaluated dose calculations.

71124.07Radiological Environmental Monitoring Program Site Inspection

The inspectors evaluated the licensees radiological environmental monitoring program.

Groundwater Protection Initiative Implementation (1 Sample)

The inspectors evaluated the licensees groundwater monitoring program.

71124.08Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Radioactive Material Storage

The inspectors evaluated the licensees radioactive material storage.

Radioactive Waste System Walk down (1 Sample)

The inspectors evaluated the licensees radioactive waste processing facility during plant walkdowns.

Waste Characterization and Classification (1 Sample)

The inspectors evaluated the licensees radioactive waste characterization and classification.

Shipment Preparations (1 Sample)

The inspectors evaluated the licensees radioactive material shipment preparation processes.

Shipment Records (1 Sample)

The inspectors evaluated the licensees non-excepted package shipment records.

OTHER ACTIVITIES - BASELINE

71151Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

(1) MS06: Emergency AC Power Systems (04/01/2017-09/30/2018)

(2) MS07: High Pressure Injection Systems (07/01/2017-09/30/2018)

(3) MS08: Heat Removal Systems (07/01/2017-09/30/2018)

(4) MS09: Residual Heat Removal Systems (07/01/2018-09/30/2018)

(5) MS10: Cooling Water Support Systems (04/01/2017-09/30/2018)

(6) BI01: Reactor Coolant System (RCS) Specific Activity Sample (10/01/2017-09/30/2018)

(7) EP01: Drill/Exercise Performance (DEP) Sample (10/01/2017-09/30/2018)

(8) EP02: Emergency Response Organization (ERO) Drill Participation Sample (10/01/2017-09/30/2018)

(9) EP03: Alert And Notification System (ANS) Reliability Sample (10/01/2017-09/30/2018)

71152Problem Identification and Resolution Semiannual Trend Review

The inspectors reviewed the licensees corrective action program for trends in the licensees lubrication and predictive monitoring (i.e. oil analysis) program that might be indicative of a more significant safety issue.

Annual Follow-up of Selected Issues (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Reactor core isolation cooling delayed injection after December 12, 2018, scram, Condition Report CR-GGN-2018-13050, on December 17, 2018

71153Follow-up of Events and Notices of Enforcement Discretion Events

The inspectors evaluated plant and operator response to a manual reactor scram due to open bypass valve and the licensees response on December 12, 2018.

Licensee Event Reports (2 Samples)

The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report 05000416/2016-002-01, Automatic Actuation of the Reactor Protection System Due to B Main Transformer Wiring, on December 11, 2018

(2) Licensee Event Report 05000416/2016-006-01, Multiple Valid Engineered Safety Feature Actuations, on December 11,

INSPECTION RESULTS

Failure to Update the Updated Final Safety Analysis Report Cornerstone Severity Cross-cutting Aspect Inspection Procedure Not Applicable Severity Level IV NCV 05000416/2018004-01 Closed Not Applicable

71111.04 - Equipment

Alignment The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.71(e) when the licensee failed to update the Updated Final Safety Analysis Report Table 9.2-16.

Description:

Updated Final Safety Analysis Report (UFSAR) Table 9.2-16 provided the standby service water (SSW) system cooling duty loads following a design basis accident.

Licensee Procedure 17-S-06-22, SSW A Performance, Revision 15, provided instructions to perform an SSW system flow balance to verify components served by the system received adequate cooling water flow rates under post loss of coolant accident conditions. When reviewing the UFSAR, the inspectors noted that some minimum allowable flow rates from the SSW A Performance procedure were lower than specified in Table 9.2-16. Specifically, residual heat removal heat exchanger A required flow was 7,900 gallons per minute per Table 9.2-16, versus 7,727 gallons per minute in Procedure 17-S-06-22.

The inspectors reviewed the three most recent SSW A and SSW B flow performance test results and noted that although all of the as-left flow rates were above established procedural requirements, some of the flow rates were below the values contained in Table 9.2-16. The licensee provided justification of system flow per completed Calculation MC-Q1P41-97020, Revision 13, that the SSW flow rates specified in the SSW A Performance procedure were appropriate for system loads. However, the inspectors noted that each time the SSW A Performance procedure allowable system flow rates were revised, UFSAR Table 9.6-12 was not updated. The licensee entered the UFSAR versus SSW flow performance testing into the corrective action program as Condition Report CR-GGN-2018-12692 for an operability determination. After reviewing the applicable SSW flow calculations and technical specifications, the inspectors concluded that the as-left SSW system flow balance loads did not challenge system operability.

Per Condition Report CR-GGN-2018-12705, UFSAR Table 9.6-12 was based on an original Bechtel design calculation, which had not been updated since Calculation MC-Q1P41-97020 was originally developed and approved on November 25, 1997. Furthermore, the inspectors noted that Calculation MC-Q1P41-97020 had been revised multiple times (currently on Revision 13) and Procedure 17-S-06-22, SSW A Performance, has been revised multiple times (currently on Revision 15); however, UFSAR Table 9.2-16 was still based on the original Bechtel design calculation. The inspectors compared the required flow rates contained in MC-Q1P41-97020 to Table 9.2-16 and noted that some of the newly calculated flow requirements were non-conservative with respect to the UFSAR.

Corrective Actions: The licensee entered this issue into their corrective action program and planned to perform a broke/fix evaluation to determine long-term corrective actions. This evaluation was still in progress at the conclusion of this inspection period.

Corrective Action Reference: The licensee entered the issue into their corrective action program as Condition Report CR-GGN-2018-13205.

Performance Assessment:

The inspectors determined this violation was associated with a minor performance deficiency.

Enforcement:

Severity: The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter noncompliance. This violation was determined to be Severity Level IV in accordance with the NRC Enforcement Policy Example 6.1.d.3. The inspectors determined that there is a material impact on safety or licensed activities because if utilized, lack of up-to-date information in the final safety analysis report, could be a nonconservative impact on design analysis.

Violation: 10 CFR 50.71(e), Maintenance of Records, Making of Reports, requires, in part, that, Each person licensed to operate a nuclear power reactor shall update periodically the final safety analysis report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed.

This submittal shall contain all the changes necessary to reflect information and analyses submitted to the Commission by the applicant or licensee, or prepared by the applicant or licensee pursuant to Commission requirement since the submittal of the original or the last update to the final safety analysis report.

Contrary to the above, from November 25, 1997, to December 31, 2018, the licensee did not update the final safety analysis report to assure that the information included in the report contained the latest information developed. Specifically, since Calculation MC-Q1P41-97020 was developed on November 25, 1997, to revise the SSW system load analysis and system acceptance criteria contained in Procedure 17-S-06-22, SSW A Performance, the UFSAR was impacted and was not revised for accuracy.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Implement Lubrication Oil Program for Quality Systems Cornerstone Significance Cross-cutting Aspect Inspection Procedure Mitigating Systems

Green NCV 05000416/2018004-02 Closed H.2 - Human Performance, Field Presence

71111.12 - Maintenance

Effectiveness The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to implement procedures for the lubrication program for safety-related and quality components. Specifically, licensee Procedure SEP-LUB-GGN-001, GGN Lubrication Program, Revision 1, requires appropriate storage, issuance, and recordkeeping for oils used in safety-related and quality systems. The licensee failed to implement the procedure, including unauthorized storage locations and 28 examples of inadequate records across four safety-related and quality systems.

Description:

On September 19, 2018, the inspectors toured the station and interviewed personnel regarding the process to add oil to safety-related and quality systems. The inspectors identified several concerns, captured in Condition Report CR-GGN-2018-10576, which included five different locations to obtain oil, oil stored in unapproved containers in the turbine building, and an inconsistent understanding of the approved process to add oil to quality systems.

The inspectors performed an independent review of the oil program and recent oil additions to quality systems. The inspectors noted that Section 6 of licensee Procedure SEP-LUB-GGN-001, GGN Lubrication Program, Revision 1, requires the following:

Lubricants shall be stored in a manner that prevents contamination or degradationlubricants shall be issued from storescontainers shall be cleaned or determined to be visually clean before usewaste lubricants shall be disposed of the type and quantity of oil added should be recorded on the Work Order for each addition or change out of oil

Stated differently, the approved process to add oil to a quality system requires obtaining it from the warehouse in a clean container, receiving an issue ticket for the amount provided, disposing of any remaining oil after the work is complete, and attaching the issue ticket to the completed work order as the record of the oil added.

The inspectors reviewed recent work orders and identified 28 examples of the licensee failing to keep adequate records of oil additions across four quality systems. In each case, there was missing issue tickets as a record of the source and quality of the oil added:

System Condition Report Work Orders Missing Issue Records Reactor Core Isolation Cooling (RCIC)

CR-GGN-2018-11192 CR-GGN-2018-10957 440942, 505488, 42791450, 52697367, 52756102 Residual Heat Removal (RHR)

CR-GGN-2018-11193 52583375, 52584318, 52580723, 52530869 Emergency Diesel Generator (EDG)

Governors CR-GGN-2018-11197 488101, 52731167, 52621307, 52530874, 446198, 428564, 418838, 52583021, 425352 Standby Service Water (SSW)

CR-GGN-2018-11231 52767435, 460072, 52626683, 52472664, 446478, 52620220, 378356, 52530869, 51208903, 360427

Further, the inspectors determined that the improper storage of oil, such as in the turbine building and in unapproved containers, did not conform to the licensees program requirements.

The inspectors reviewed the most recent chemistry results for oil samples from all quality systems that use lubrication, governor control, and/or fuel oil. The inspectors did not identify any issues of concern and noted the licensee was monitoring parameters such as particulates, viscosity, and trace elements that could indicate contaminants.

The inspectors concluded the licensee failed to implement procedures for the lubrication program for safety-related and quality components. The inspectors determined the issue was a recurring failure, was programmatic across several quality systems, and that the scope of the failures to follow the lubrication program was not isolated to a small set of technicians but instead represented a programmatic failure to provide oversight by supervisors.

In response to the NRCs conclusion, the licensee initiated Standing Order Maint-18-0003, which implemented additional controls for oil additions including supervisory oversight. The inspectors noted the licensee initiated condition reports for each of the issues as described previously.

Corrective Actions: The licensee locked the alternate oil issue facilities, issued a standing order to obtain oil for safety related applications only from the warehouse, and entered the issues into the corrective action program.

Corrective Action Reference: Condition Report CR-GGN-2018-10576

Performance Assessment:

Performance Deficiency: The failure to implement procedures for the lubrication program for safety-related and quality components was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor, and therefore a finding, because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, the inspectors conducted a limited scope sample of four safety systems over a recent time period, and determined that the licensee routinely failed to implement the procedure, including unauthorized storage locations and 28 examples of inadequate records. The inspectors determined this was indicative of a programmatic failure to implement procedures for appropriate storage, issuance, and recordkeeping for oils used in multiple safety-related and quality systems.

Significance: Using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because:

(1) the finding was not a deficiency affecting the design or qualification of a mitigating system;

(2) the finding did not represent a loss of system and/or function;

(3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and

(4) the finding does not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significant in accordance with the licensee's maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Cross-cutting Aspect: The finding had a cross-cutting aspect in the area of human performance associated with field presence because licensee leadership failed to promptly correct deviations from standards and expectations while ensuring supervisory and management oversight of work activities [H.2]. Specifically, the scope of the failures to follow the lubrication program was not isolated to a small set of technicians and instead represented a programmatic failure to provide oversight by supervisors.

Enforcement:

Violation: Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 9.a of Appendix A to Regulatory Guide 1.33, Revision 2, requires that procedures for maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The licensee established Procedure SEP-LUB-GGN-001, GGN Lubrication Program, in part, to meet this requirement. Procedure SEP-LUB-GGN-001, GGN Lubrication Program, Revision 1, step 6, required appropriate storage, issuance, and recordkeeping for oils used in safety-related and quality systems.

Contrary to the above, from November 13, 2017, to September 19, 2018, the licensee failed to ensure appropriate storage, issuance, and recordkeeping for oils used in safety-related and quality systems. Specifically, the inspectors identified unauthorized storage locations and 28 examples of inadequate records across four safety-related and quality systems.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Design Control for Reactor Core Isolation Cooling and Emergency Diesel Generators Cornerstone Significance Cross-cutting Aspect Inspection Procedure Mitigating Systems Green NCV 05000416/2018004-03 Closed H.12 - Human Performance, Avoid Complacency

71111.12 - Maintenance

Effectiveness The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to correctly translate the design basis of the reactor core isolation cooling system and the emergency diesel generators into specifications and procedures. Specifically, the reactor core isolation cooling system and the emergency diesel generators required governor oil to be filtered; however, the licensee performed this task outside of a quality process and did not specify filtration as a critical characteristic in the commercial grade dedication process for the oil.

Description:

On October 9, 2018, as part of a focused baseline sample on the oil program for quality systems, the inspectors reviewed vendor manuals and operating experience. The inspectors focused on systems with oil governors, such as reactor core isolation cooling (RCIC) and the emergency diesel generators (EDGs).

The Terry Steam Turbine vendor manual associated with RCIC states, Important: All oil should be filtered through a filter press or through a temporary 5 micron filter before adding it to the system. In a letter from Dresser-Rand to the Terry Turbine Users Group, dated March 27, 2000, the vendor expanded on this requirement stating, It is also important to filter new oil before refilling the oil system. The new oil should be filtered to a cleanliness better than the expected operating cleanliness of the new unit. This will remove any contaminants in the new oil and help ensure that the new oil will meet the cleanliness acceptance criteria in operation.

The licensee documented oil system filtration requirements for the emergency diesel generator governors in a letter dated April 29, 1999, and numbered GIN 1999-01132. In this letter, the licensee reviewed operating experience OMR 418, Recent Problems with Woodward Governor Control Systems for Auxiliary Turbines and Emergency Diesel Generators, as follows:

OMR 418 identified six areas, or causes, for governor malfunctions

(1) Governor hydraulic oil impurities Recommendation: New oil should be filtered Response: Currently, when the oil is changed in the governors, or oil is added the new oil is not filtered. New oil should be filtered before being added to the governors. This can be accomplished by filtering to 5 microns as is done with adding oil to the RCIC turbine governor.

The inspectors then reviewed the process that the licensee used to provide quality oil to the RCIC and EDG systems for governor use. At the time of inspection, the oil was procured commercially and then dedicated per Procedure EN-DC-306, Acceptance of Commercial-Grade Items/Services in Safety-Related Applications, Revision 6. The now-quality oil was then placed in the warehouse, labeled as quality, kept separate from the commercial-grade version, and issued as requested by work orders via issue tickets. The inspectors noted that filtration to specific particulate size was not a critical characteristic used in the commercial-grade dedication process.

Since the oil was not procured or dedicated to a particulate level of 5 microns or less, the licensee then filtered the oil via a commercially obtained filtration skid and the result is the oil used in RCIC and EDG governors. Licensee Procedure 07-S-15-6 SU, "Lubricating Oil Collection," Revision 24, implemented vendor requirements to filter RCIC turbine oil and EDG governor oil to 5 microns. The inspectors challenged the licensees process for filtering oil with the following two concerns.

First, the process of taking a quality item and putting it through a non-quality process calls into question the final quality of the item. The oil filtration skid used is a non-quality commercial grade setup with a commercially-procured Ultipor III filter. Since the licensee does not perform analysis of the oil after filtration, it is plausible that the commercial-grade filter could have added contaminants or otherwise altered the critical characteristics specified in the dedication process. The inspectors noted that there was not any explicit guidance on how to use the filtration skid, such as minimum purge volumes, periodic maintenance, or periodic cleaning.

Second, the vendor requirements and operating experience, as incorporated by the licensee, require filtration for oil used in governor systems, but filtration is not listed as a critical characteristic during commercial-grade dedication. Procedure EN-DC-306 defines critical characteristic as the important design, material, and performance characteristics of a commercial-grade item that - once verified - will provide reasonable assurance that the item will perform its intended safety function. Section 5.10 of Procedure EN-DC-306 requires identification of critical characteristics including via review of available technical data provided by the supplier including supplier information letters[and] review of operating experience. This section of the procedure continues, critical characteristics are selected from the design characteristics necessary to preclude failure of the item to perform its safety functionare based on credible failure modes and effectsinclude performance and dependability The inspectors determined that OMR 418 was incorporated, per the licensees own analysis of the operating experience, to prevent malfunctions of governors which could lead to failure of the system to perform its safety function. By not considering filtration as a critical characteristic, the licensee is vulnerable to failures caused by an unmonitored oil parameter when the oil is first placed in the system.

The inspectors reviewed the most recent chemistry results for oil samples. The inspectors did not identify any issues of concern and noted the licensee was monitoring parameters such as particulates, viscosity, and trace elements that could indicate contaminants. Note that these samples are performed after the system is run and would not detect an initial oil addition that was contaminated.

The inspectors concluded the licensee failed to correctly translate the design basis of the RCIC system and the EDGs into specifications and procedures. The RCIC system and the EDGs require governor oil to be filtered; however, the licensee performed this task outside of a quality process and did not specify filtration as a critical characteristic.

Corrective Action: The licensee entered issues into the corrective action program.

Corrective Action References: Condition Reports CR-GGN-2018-11203 and CR-GGN-2018-11216.

Performance Assessment:

Performance Deficiency: The failure to correctly translate the design basis of the RCIC system and the EDG system into specifications and procedures was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor, and therefore a finding, because it was associated with the design control attribute of the Mitigating Systems Cornerstone and adversely affected the objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, licensee Procedure 07-S-15-6 SU, "Lubricating Oil Collection," Revision 24, implements vendor requirements to filter RCIC turbine oil and EDG governor oil to 5 microns. This filtration, however, is performed with a nonquality and nondedicated commercial-grade filter. Further, this filtration was performed after the lubrication oil had been dedicated per Procedure EN-DC-306, Acceptance of Commercial-Grade Items/Services in Safety-Related Applications. The filtration of oil outside of a quality process can jeopardize the ability of the quality systems to perform their specified safety function.

Significance: Using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because:

(1) the finding was not a deficiency affecting the design or qualification of a mitigating system;

(2) the finding did not represent a loss of system and/or function;

(3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and

(4) the finding does not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significant in accordance with the licensee's maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Cross-cutting Aspect: The finding had a cross-cutting aspect in the area of human performance associated with avoiding complacency because the licensee failed to recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes [H.12]. Specifically, licensee staff performing the filtration, supervising the work, and reviewing the program data were complacent to the latent risk of working outside of a quality process.

Enforcement:

Violation: As required by 10 CFR Part 50, Appendix B, Criterion III, Design Control, applicable regulatory requirements and the design basis, as defined in Section 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, from April 29, 1999, to October 9, 2018, for the quality-related structure and components associated with the RCIC system and EDG governors, to which 10 CFR Part 50, Appendix B, applies, the licensee failed to correctly translate applicable regulatory requirements and the design basis, as defined in Section 50.2 and as specified in the license application, into specifications, drawings, procedures, and instructions.

Specifically, the design basis for the RCIC system and the EDGs included requirements for governor oil to be filtered; however, the licensee failed to appropriately translate these requirements into specifications and procedures, since the licensee performed this task outside of a quality process and did not specify filtration as a critical characteristic.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Adequately Lubricate Motor-Operated Valve Stem Nut Cornerstone Significance Cross-cutting Aspect Inspection Procedure Mitigating Systems

Green NCV 05000416/2018004-04 Closed None

71111.13 - Maintenance

Risk Assessments and Emergent Work Control A self-revealed, Green, non-cited violation of Technical Specification 5.4.1.a, Procedures, was identified when the licensee failed to have adequate instructions to perform preventive maintenance. Specifically, the licensee failed to properly lubricate the Division 1 residual heat removal heat exchanger bypass valve E12F048A and the valve failed to stroke during a surveillance test.

Description:

On August 23, 2018, during a quarterly surveillance test on residual heat removal subsystem (RHR) A heat exchanger bypass valve E12F048A failed to stroke open on demand. During the surveillance, operators observed indications that valve E12F048A went full open as expected; however, RHR A flow decreased and the RHR A pump minimum flow valve opened, which was an unexpected system response for this system configuration.

Upon investigating, operators noticed that with the valve actuator operating the valve stem did not move, which indicated that the valve did not actually reposition open when demanded.

Operators entered the issue into their corrective action program as CG-GGN-2018-09705 and declared RHR subsystem A inoperable. The licensee identified that the stem nut threads had significant wear, preventing positive contact with the valve stem threads. As a consequence, the actuator was not able to move the valve. Further investigation identified degraded/hardened grease in the stem nut.

The licensee performed an equipment failure evaluation to determine why the valve failed to reposition. The licensee determined that although the stem grease was inspected, cleaned, and re-lubricated every 2 years, the stem was not being properly lubricated. In accordance with Procedure 07-S-14-4, Valve Actuator Gearbox Lubricant Sampling and Stem Lubrication Manual/Power Actuated Valves, Revision 24, the licensee lubricated the exposed portion of the stem. Because an anti-rotation device restricted routine access to the full length of the stem, the exposed portion was over 9 inches below the stem nut. However, with a valve stroke length of 9 inches, the fresh lubrication added to the stem did not lubricate the stem nut when the valve was fully stroked open and closed.

The inspectors visually inspected other risk significant RHR motor-operated valves to determine if the valves had similar metallic particles in the stem grease. Based on their observations, the inspectors did not identify any additional concerns. The inspectors also reviewed work order history and determined that:

• Valve E12F048A was last lubricated on August 29, 2017, under Work Order 52628141;

• the first documented instance where the E12F048A valve stem was lubricated was April 13, 1999, under Work Order 50895906, using Revision 15 of Procedure 07-S-14-4, dated March 17, 1998; and

• no documented work was performed on valve E12F048A after April 13, 1999, which would have properly lubricated the stem nut (such as an actuator refurbishment).

The inspectors reviewed Revision 15 of Procedure 07-S-14-4 and determined that the instructions to lubricate valve E12F048A remained unchanged through Revision 24. The inspectors reviewed Work Order 52628141 and concluded that, based on the procedure used at the time and the valve design, the valve was not properly lubricated. Based on interviews with engineering personnel, the inspectors determined the last time the stem nut was adequately lubricated was likely in the late 1990s, but prior to the April 13, 1999, stem lubrication.

Corrective Actions: Licensee corrective actions included replacing the stem nut, performing motor-operated valve (MOV) diagnostic testing, and re-performing the surveillance test satisfactorily. The licensee revised procedures, including the applicable lubrication procedure, MOV periodic test procedures, and maintenance procedures to include specific instructions on lubricating this style of valve to ensure the stem nut was properly lubricated.

Corrective Action Reference: The licensee entered the issue into their corrective action program as Condition Report CR-GGN-2018-09705.

Performance Assessment:

Performance Deficiency: The failure to establish adequate instructions to properly lubricate the E12F048A valve was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the performance deficiency contributed to the failure of the E12F048A valve to reposition open on demand, which affected the operability of RHR subsystem A.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Section A. Since the finding does not affect the design or qualification and does not represent a loss of system function, the finding screens to a Green significance. Specifically, the heat exchanger inlet and outlet valves remained available and would have allowed for RHR system flow to the reactor through the heat exchanger with sufficient flow to maintain the low pressure coolant injection function.

Cross-Cutting Aspect: No cross-cutting aspect was assigned to this finding because the lubrication instructions for this valve were developed in 1998. Therefore, the inspectors determined the cause of the finding is not indicative of current licensee performance.

Enforcement:

Violation: Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained for activities that are recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Appendix A, Section 9.a of Regulatory Guide 1.33 requires that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Contrary to the above, between April 13, 1999, and August 29, 2017, the licensee failed to ensure that maintenance that can affect the performance of safety-related equipment was properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Specifically, the licensee failed to develop preventive maintenance instructions to adequately lubricate the valve stem and stem nut on the Division 1 RHR bypass valve E12F048A.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Perform Complete Evaluations of the Licensee Interface with Offsite Organizations Cornerstone Significance Cross-cutting Aspect Report Section Emergency Preparedness Green NCV 05000416/2018004-05 Closed H.8 - Human Performance, Procedure Adherence

71114.05 - Maintenance

of Emergency Preparedness The inspector identified a Green, non-cited violation of 10 CFR 50.54(t)(2) for the licensees failure to include an evaluation of the adequacy of the interfaces with State and local governments in a review of emergency preparedness program elements in Audit Reports QA-07-2017-GGNS-1 and QA-07-2018-GGNS-1. Specifically, audit personnel did not provide offsite officials with an opportunity to provide their view of the adequacy of the interface to the audit team, resulting in a failure to evaluate this interface.

Description:

The inspector reviewed Quality Assurance Audit Reports QA-07-2017-GGNS-1 and QA-07-2018-GGNS-1, dated May 30, 2017, and May 14, 2018, respectively. These reports documented adequacy evaluations of the licensees emergency preparedness program performed by persons who had no direct responsibility for the implementation of the program, as required by 10 CFR 50.54(t). Since the licensee staff performing the evaluation were independent from the program, they needed to take action to develop first-hand understanding of the program in addition to documentation reviews. This would allow them to gage whether there were unidentified issues that the emergency preparedness staff had not recognized and whether action had been taken on previously identified issues. In order to evaluate the adequacy of interfaces between the staff and State and local agencies (one of the evaluation areas), an outreach to State and local agencies is needed to allow these agencies communication opportunities to help the evaluator recognize such issues.

It was determined that the report sections addressing Program Element 1: Responsibility and Organization, and Audit Contacts/Meeting Attendees - List, described the audit teams evaluation of the interface between the Grand Gulf Nuclear Station emergency preparedness staff and offsite response organizations for each report. Based on the reports, the evaluations consisted of the following:

• In 2017, the evaluation was based on a document review of other audit reports dealing with drill observations, review of documentation associated with monthly teleconferences between State and local agencies and the emergency preparedness department, and review of records related to the annual review of Emergency Action Levels (EALs) with the agencies.

• In 2018, the evaluation was based on review of records related to the annual review of EALs with the agencies and records of annual training provided to the agencies.

The inspector discussed the content of the 2017 and 2018 audit reports with several audit staff members involved in the efforts and reviewed informal notes kept by auditor staff. The inspector confirmed the following:

• In 2017, an opportunity was provided to Louisiana Department of Environmental Quality (LDEQ) to provide information about the quality of the interface with the licensee. No evidence was identified of an opportunity being provided to the State of Mississippi or to local officials in Tensas Parish or Claiborne County.

• In 2018, an opportunity was provided to Mississippi Emergency Management Agency (MEMA) to provide similar information. No such opportunity was provided to officials in the State of Louisiana or with local officials in Tensas Parish or Claiborne County.

From 2012 to 2017, the procedure for audit performance had been used by auditors to establish contact with both State and local government agencies. Previously, interviews or surveys were provided to fire and police departments in Claiborne County and Port Gibson; MEMA, Mississippi Department of Health/Division of Radiological Health; LDEQ, Governors Office of Homeland Security and Emergency Preparedness (GOSHEP); Port Gibson/Claiborne County Civil Defense; and Tensas Parish Office of Homeland Security and Emergency Preparedness. Based on the reports, auditor notes, and interviews, this was not implemented correctly during the 2017-2018 time period.

The inspector concluded that Grand Gulf Nuclear Station did not conduct an adequate evaluation of the interface between the stations emergency preparedness organization and offsite officials because the evaluation did not provide offsite officials the opportunity to provide their view of the adequacy of the interface to the audit team.

Corrective Actions: The licensee entered these issues into the corrective action program. In addition, the licensee is taking action to contact each of the State and local agencies to identify any issues between their organizations.

Corrective Action Reference: Condition Report CR-GGN-2018-12103

Performance Assessment:

Performance Deficiency: The failure to perform an evaluation for adequacy of the interface with State and local governments in accordance with 10 CFR 50.54(t)(2) was a performance deficiency.

Screening: The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the offsite emergency preparedness attribute of the Emergency Preparedness Cornerstone, and affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the ability to implement adequate measures to protect the health and safety of the public could be affected if communication and coordination problems between the licensee and offsite agencies are not detected and corrected.

Significance: Using Inspection Manual Chapter 0609, Significance Determination Process, 4, Tables 1, 2, and 3, worksheets (effective date October 7, 2016); and the corresponding Appendix B, Emergency Preparedness Significance Determination Process, 2 (issue date September 22, 2015); the performance deficiency was determined to have very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded risk significant planning standard function.

Cross-Cutting Aspect: The finding had a cross-cutting aspect in the area of procedural adherence associated with human performance because the licensee failed to follow processes, procedures, and work instructions [H.8]. Specifically, Entergy Nuclear Emergency Plan Standard Audit Template, Audit Number 7, Revisions 11 and 12, Performance Element 1, Attribute 2, Auditor Instruction

(e) contained instructions to solicit comments from State and local agencies, but the audit teams failed to implement this portion of the audit instruction with the applicable governmental population.

Enforcement:

Violation: Title 10 CFR 50.54(t)(2) requires, in part, that the review of emergency preparedness program elements must include an evaluation for adequacy of the interfaces with State and local governments.

Contrary to the above, from May 30, 2017, to December 17, 2018, the licensees review of emergency preparedness program elements failed to include an evaluation for adequacy of the interfaces with State and local governments. Specifically, the reviews conducted under Audit Reports QA-07-2017-GGNS-1 and QA-07-2018-GGNS-1 did not provide offsite response organizations the opportunity to provide information about the adequacy of their interface with the licensee as specified in the Entergy Standard Audit Template.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy, because it was very low safety significance (Green)and was entered into the licensees corrective action program as Condition Report CR-GGN-2018-12103.

Failure to Conduct Drills in Accordance with the Site Emergency Plan Cornerstone Significance Cross-cutting Aspect Report Section Emergency Preparedness Green NCV 05000416/2018004-06 Closed H.9 - Human Performance, Training

71114.05 - Maintenance

of Emergency Preparedness The inspector identified a Green, non-cited violation of 10 CFR 50.54(q)(2) associated with the licensees failure to follow their emergency plan. Specifically, the licensee failed to follow Grand Gulf Nuclear Station Emergency Plan, Revisions 66 to 77, Section 8.3.2.c, which requires an annual drill to determine the effectiveness of the local fire department working in conjunction with the licensee fire brigade. The licensee failed to conduct correctly scoped annual fire brigade drills from 2012 to 2017.

Description:

The inspector reviewed drills and exercises conducted by the licensee between January 2017 and November 2018, and compared the drill and exercise evaluation reports to the requirements of the licensee emergency plan.

The inspector determined that Grand Gulf Nuclear Station Emergency Plan, Revisions 66 to 77, Section 8.3.2.c, required that a fire brigade drill be conducted on an annual basis to determine the effectiveness of the local fire department working in conjunction with the fire brigade.

The inspector evaluated the drill reports for the 2017 annual fire brigade drill. The report indicated that Claiborne County Fire responded and provided support as requested. However, it indicated in the event timeline that the offsite fire department came on site after the drill was terminated. Interviews with licensee fire protection staff revealed that Claiborne County Fire came onsite and stopped with their equipment at the protected area access point. No interaction took place with any fire brigade staff during the drill. Therefore, there was no opportunity to evaluate the effectiveness of the fire brigade and Claiborne County Fire working together. Further interview responses, validated by review of other annual fire brigade drill reports, showed that there were no evaluated interactions between the fire brigade and offsite fire departments from 2012 to 2015. In addition, no fire brigade drill was conducted in 2016 to meet this annual requirement. Interviews indicated that the off-site fire department did receive training at the plant every year.

The inspector reviewed site implementation procedures and conducted licensee staff interviews to gage whether there was an understanding of the specific fire brigade drill requirements. Site staff had various understandings of what the fire brigade drill requirements were as documented in the emergency plan. Procedure EN-EP-306, Drills and Exercises, Revisions 2 through 9, Attachment 9.1, stated for drill/exercise, Type 7, that the fire drills are conducted in accordance with Tech Specs and/or Fire Protection Program/Procedures. The procedure, which contained a site-specific emergency plan commitment list (Section 8.0), had commitments related to the content of Attachment 9.1, but did not document the specific details of the annual fire brigade drill. Therefore, there has not been recognition by licensee staff that the procedures fire drill description was different than what is contained in the emergency plan.

The inspector determined that the licensee did not conduct annual fire brigade drills in which the fire brigade and off-site fire departments were evaluated working in conjunction with each other. Therefore, the inspector concluded that the licensee did not follow the requirements of the site emergency plan.

Corrective Actions: The licensee entered these issues into the corrective action program.

Corrective Action Reference: Condition Report CR-GGN-2018-12101

Performance Assessment:

Performance Deficiency: The inspector determined that the failure to conduct drills required by the emergency plan is a performance deficiency within the licensees ability to foresee and correct.

Screening: The performance deficiency was more than minor because it was associated with the emergency response organization performance (drills and exercises) cornerstone attribute and adversely affected the Emergency Preparedness Cornerstone objective of being capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The licensees ability to take adequate measures to protect the health and safety of the public is degraded when the licensee does not perform drills and exercises to ensure emergency response organization proficiency.

Significance: Using Inspection Manual Chapter 0609, Significance Determination Process, 4, Tables 1, 2, and 3 worksheets (effective date October 7, 2016); and the corresponding Appendix B, Emergency Preparedness Significance Determination Process, 2 (issue date September 22, 2015); the performance deficiency was determined have very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded risk significant planning standard function. The planning standard function was not lost because the licensee did conduct drills and off-site organization training that addressed portions of the related emergency plan commitments.

Cross-Cutting Aspect: The finding had a cross-cutting aspect in the area of human performance associated with training because the licensee did not maintain a workforce knowledgeable about the requirements of the emergency plan [H.9]. Specifically, the review of drill reports text and licensee interviews, compared against the implementing procedures, showed examples of insufficient knowledge of content of the site emergency plan. This contributed to the misconception by the licensee that their actions were in compliance with the plan.

Enforcement:

Violation: Title 10 CFR 50.54(q)(2) requires, in part, that a power reactor licensee follow an emergency plan which meets the requirements of Appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b). Planning standard 10 CFR 50.47(b)(14) requires, in part, that the licensee conduct periodic drills to maintain key skills. Grand Gulf Nuclear Station Emergency Plan, Revisions 66 to 77, Section 8.3.2.c, states, in part, that a drill is conducted on an annual basis to determine the effectiveness of the local fire department working in conjunction with the fire brigade.

Contrary to the above, between April 11, 2012, and December 20, 2017, Grand Gulf Nuclear Station failed to follow an emergency plan which met the requirements of Appendix E and the standards of 10 CFR 50.47(b). Specifically, the licensee failed to conduct annual fire brigade drills with the scope of evaluation required by the emergency plan to maintain key emergency response organization skills.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy, because it was very low safety significance (Green) and was entered into the licensees corrective action program as Condition Report CR-GGN-2018-12101.

Observation

71152 - Problem

Identification and Resolution The inspectors reviewed the licensees corrective action program, system health reports, and other documentation to identify trends that might be indicative of a more significant safety issue for lubrication and hydraulic control oil for the reactor core isolation cooling (RCIC)system.

The inspectors reviewed adverse issues that had been identified for these RCIC oil subsystems in the past 3 years. During this period, 19 condition reports were generated. The majority of these condition reports were for low-level issues such as housekeeping, requesting oil additions, and enhancements to processes such as job briefs.

The inspectors focused on three condition reports that documented adverse chemistry data and questions on the oil program:

• CR-GGN-2018-10179 documented elevated phosphorus and particulates from oil samples drawn from the RCIC turbine lubrication oil subsystem

• CR-GGN-2018-10576 documented NRC concerns about the traceability of oil used in safety-related systems

• CR-GGN-2018-10445 documented NRC concerns about an unauthorized oil storage area where containers were found labeled RCIC Oil The inspectors noted that the licensee performed a prompt operability determination for the elevated oil contaminants in the RCIC turbine lubrication oil subsystem. Corrective actions included flushing of the system, post-flush oil sampling, and a standing corrective action to perform more frequent oil analysis during system operation. The inspectors independently reviewed surveillance test data for the RCIC system including vibrations and temperatures to validate that the system was not adversely impacted.

Regarding traceability of oil used in safety-related systems and unauthorized oil storage, the inspectors documented two non-cited violations in this inspection report.

The inspectors also identified several issues that did not rise to a more-than-minor safety significance:

• The 2015 problem identification and resolution inspection shared a comment with the licensee, captured in Condition Report CR-GGN-2015-05831, that the tracking of oil additions to systems could use improvement. This represented a missed opportunity to enhance the program prior to the focused baseline inspection of 2018.

• Previous revisions of Procedure 07-S-15-6 SU, "Lubricating Oil Collection," specified that oil filtration was to be performed at the component stating, If sampling RCIC turbine or diesel governor, then ensure 5 micron or better filter connected to fill line.

The licensee, prior to Revision 24, had been performing the filtering in a different location and transporting the filtered oil to the component. This was contrary to the written instructions. This observation was captured in Condition Report CR-GGN-2018-11203.

• Procedure SEP-LUB-GGN-02, GGN Oil Analysis Program, Revision 0, states, elevated particle count is a correctable condition, either with filtration or lubricant change, and does not constitute an operability issue. This guidance is contrary to NRC Information Notice 2001-06, Centrifugal Charging Pump Thrust Bearing Damage Not Detected Due to Inadequate Assessment of Oil Analysis Results and Selection of Pump Surveillance Points. This generic communication discusses an undetected emergency core cooling system (ECCS) pump failure with elevated particulates in the oil. Although the ECCS pump in the Information Notice passed in-service and other surveillance tests, the Information Notice concludes that, the failure of both

[surveillance] tests to indicate bearing degradation appears to have biased the decision to not investigate the elevated particle count and If trends of condition monitoring data are not actively investigated when they deviate from an established baseline, a licensee may overlook significant pump degradation that is not detected by performance testing. This observation was captured in Condition Report CR-GGN-2018-11215.

• The inspectors noted that the licensee did not have any additional oil samples saved from the elevated phosphates issue in RCIC. This represented a lost opportunity for additional chemistry analysis to determine the precise source of the oil contaminants.

• The inspectors noted the station was inconsistent in the practice of applying foreign material exclusion controls to the filtration skids used for RCIC and emergency diesel generator oils. This observation was captured in Condition Report CR-GGN-2018-11149.

The inspectors verified that all issues were addressed within the scope of the corrective action program and that the completed and planned actions were appropriate to correct the identified causes. The inspectors did not identify any new trends or concerns that might be indicative of a more significant safety issue for the lubrication and hydraulic control oil for the RCIC system.

EXIT MEETINGS AND DEBRIEFS

On October 11, 2018, the inspector presented the Focused Baseline Inspection results to Mr. E. Larson, Site Vice President, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

On November 9, 2018, the inspector provided a debrief for the Emergency Preparedness Program Inspection to Mr. E. Larson, Site Vice President, and other members of the licensee staff. On December 17, 2018, the inspector communicated the emergency preparedness program inspection results telephonically to Mr. E. Larson, Site Vice President, and other members of the licensee staff. The inspector verified no proprietary information was retained or documented in this report.

On November 30, 2018, the inspector presented the Baseline Radiation Safety Inspection results to Mr. E. Larson, Site Vice President, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

On December 14, 2018, the inspectors presented the preliminary evaluations of Changes, Tests, and Experiments Inspection results to Mr. R. Franssen, General Manager Plant Operations, and other members of the licensee staff. On December 20, 2018, the inspectors presented the final evaluations of Changes, Tests, and Experiments Inspection results to Mr. E. Larson, Site Vice President, and other members of the licensee staff. The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

On January 10, 2019, the inspectors presented the Quarterly Resident Inspector Inspection results to Mr. E. Larson, Site Vice President, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

DOCUMENTS REVIEWED

71111.12 - Maintenance Effectiveness

Condition Reports (CR-GGN-)

2018-10957

2018-11192

2018-11193

2018-11197

2018-11203

2018-11215

2018-11216

2018-11231

Work Orders

368342

2585

2472664

Procedures

Number

Title

Revision

04-01-02-1H13-

P601-21A-E5

Alarm Response Instruction E51-PDAH-L614

100

07-S-15-6

Lubricating Oil Sample Collection

EN-DC-310

Predictive Maintenance Program

Miscellaneous

Documents

Number

Title

Oil Analysis Reports

Terry Steam Turbine Manual

Woodward Governor Manual

EC 40251

Evaluate Replacing DTE 797 Oil with DTE 732 Oil

Maint-18-0003

Standing Order: Interim Actions for Lube Oil Additions, Oil Changes

71111.15 - Operability Determinations and Functionality Assessments

Condition Reports (CR-GGN-)

2018-10179

Work Orders

2697367

2791450

71111.17T - Evaluations of Changes, Tests, and Experiments

Condition Reports (CR-GGN-)

2016-00299

2016-01499

2016-08294

2016-08297

2016-08298

2016-08327

2016-08328

2016-08329

2016-08912

2017-04143

2018-13028

2018-13090

Condition Reports Generated During Inspection (CR-GGN-)

2018-12983

2018-12990

2018-13006

2018-13015

2018-13029

2018-13054

2018-13062

2018-13074

2018-13090

Work Orders

336989

431520

434226

439316

461847

483308

Procedures

Number

Title

Revision

01-S-06-49

Control of Engineering Documents

01-S-17-17

Periodic System Pressure Testing for the ISI Ten Year

Plan

108

03-1-01-1

Cold Shutdown to Generator Carrying Minimum Load

178

04-1-01-E12-1

System Operating Instruction Residual Heat Removal

System

151

04-1-01-E12-2

System Operating Instruction Shutdown Cooling And

Alternate Decay Heat Removal Operation

28

05-1-02-VI-2

Hurricanes Tornadoes and Severe Weather

137

06-OP-1C41-Q-

001

Standby Liquid Control Functional Test

130

17-S-05-C41

Performance and System Engineering Instruction

System Pressure Test Standby Liquid Control System

CEP-PT-001

ASME Section XI Pressure Testing Program

308

EN-FAP-LI-001

Performance Improvement Review Group (PRG)

Process

EN-FAP-OM-021

Critical Decision Procedure

EN-FAP-OP-023

Operations Performance Indicators

EN-LI-100

Process Applicability Determination

EN-LI-101

CFR 50.59 Evaluations

EN-OM-119

On-Site Safety Review Committee

EN-OP-104

Operability Determination Process

EN-OP-111

Operation Decision-Making Issue (ODMI) Process

M-195.0

Technical Specification for Protection against Dynamic

Effects Associated with the Postulated Rupture of Piping

Drawings

Number

Title

Revision

795E802

Standby Liquid Control System

E1267-005

Z77 Safeguard Switchgear and Battery Room

Ventilation System Heating Coil

E1267-019

Z77 Safeguard Switchgear and Battery Room Air

Handling Unit and Supply Fan

J1359-002

Z77 Safeguard Switchgear and Battery Rooms Outside

Air Temperature

P-1083A

ISI Boundary Diagram Reactor Core Isolation Cooling

System

Miscellaneous

Documents

Number

Title

Revision

or Date

460000498

Installation Operation and Maintenance Instructions for

Air Handling Units

EGS-TR-23004-01 Instructions for using Patel Thread Sealant P-1

EQDP-

EQ34.1_003

Environmental Qualification Documentation Package for

Patel Electrical Connectors and Conduit Seals

ES-10

Design Standard for Environmental Sealing

ES-19

Design Standard for Environmental Equipment

Qualification Maintenance

LO-GLO-2017-

00054

Self-Assessment for 2018 NRC Inspection for

Evaluation of Changes Tests and Experiments

November 15

2018

QA-4-2018-

GGNS-01

Engineering (Design Control) Audit Notification/Audit

Plan Memorandum

February 26

2018

Calculations

Number

Title

Revision

CC-Q1111-16001 Maximum Leakage Past Sand Bag Wall during PMP

Flood

M5.8.23

Equipment Environmental Qualification Calculation

M5.8.23-2

Supplement 2 to Equipment Environmental Qualification

Calculation

XC-Q1N11-94004 Dose Consequences of a Main Steam Line Break

Outside Containment

71114.02 - Alert and Notification System Testing

Procedures

Number

Title

Revision

01-S-10-3

Emergency Planning Department Responsibilities

Miscellaneous Documents

Title

Date

REP-10 Design Review Report, Entergy Grand Gulf Nuclear Station, Port

Gibson, Mississippi

May 2013

Grand Gulf Public Notification System Preventative Maintenance Record,

Site: LAA

May 3, 2017

Grand Gulf Public Notification System Preventative Maintenance Record,

Site: LAA

October 27,

2017

Grand Gulf Public Notification System Preventative Maintenance Record,

Site: LAA

March 27, 2018

71114.03 - Emergency Response Organization Staffing and Augmentation System

Procedures

Number

Title

Revision

10-S-01-6

Notification of Offsite Agencies and Plant On-Call

Emergency Personnel

Miscellaneous

Documents

Number

Title

Date

GIN 2017-00055

Quarterly Off-Hours Unannounced Everbridge Test -

5748251086942785

March 23, 2017

GIN 2017-00100

Quarterly Off-Hours Unannounced Everbridge Test - 2nd

Quarter 2017

June 2, 2017

GIN 2017-0196

Quarterly Off-Hours Unannounced Everbridge Test -

7973662619809853

September 27,

2017

GIN 2017-0269

Quarterly Off-Hours Unannounced Everbridge Test -

Broadcast ID Ending in 1360 Attached

December 20,

2017

GIN 2018-00045

Quarterly Off-Hours Unannounced Everbridge Test -

7982458713958410

March 26, 2018

GIN 2018-00109

Quarterly Off-Hours Unannounced Everbridge Test -

7973662621076652

June 22, 2018

GIN 2018-00165

Quarterly Off-Hours Unannounced Everbridge Test -

7969264575072408

October 4, 2018

71114.04 - Emergency Action Level and Emergency Plan Changes

Procedures

Number

Title

Revision

EN-EP-305

Emergency Planning 10CFR50.54(q) Review Program

Miscellaneous

Documents

Number

Title

Date

9.1,

CFR 50.54(q)(2)

Review

01-S-10-5, Revision 16

October 17, 2017

9.1,

CFR 50.54(q)(2)

Review

01-S-10-33, Revision 24

May 13, 2018

9.1,

CFR 50.54(q)(2)

Review

10-S-01-12, Revision 46

November 7, 2017

9.1,

CFR 50.54(q)(2)

Review

EN-EP-306, Revision 9

November 15,

2017

Miscellaneous

Documents

Number

Title

Date

9.1,

CFR 50.54(q)(2)

Review

EN-EP-801, Revision 15

January 11, 2018

9.2,

CFR 50.54(q)(3)

Screening

10-S-01-38, Revision 5

May 2, 2017

9.2,

CFR 50.54(q)(3)

Screening

10-S-01-39, Revision 5

May 2, 2017

9.2,

CFR 50.54(q)(3)

Screening

Emergency Plan, Revision: 76

June 21, 2017

9.2,

CFR 50.54(q)(3)

Screening

Emergency Plan, Revision: 77

June 25, 2018

9.3,

CFR 50.54(q)(3)

Evaluation

10-S-01-38, Revision 5

May 2, 2017

9.3,

CFR 50.54(q)(3)

Evaluation

10-S-01-39, Revision 5

May 2, 2017

9.3,

CFR 50.54(q)(3)

Evaluation

Emergency Plan, Revision: 76

June 21, 2017

9.3,

CFR 50.54(q)(3)

Evaluation

EN-EP 801, Revision 16

October 2, 2018

9.3,

CFR 50.54(q)(3)

Evaluation

LBDCR 2017-044, Revision 0

August 29, 2018

GNRO-2017-00062 Emergency Plan Revision 76, Grand Gulf Nuclear

Station, Unit 1; Docket No. 50-416,

License No. NPF-29

October 3, 2017

GNRO-2018-00035 Emergency Plan Revision 77, Gran

License No. NPF-29

July 30, 2018

71114.05 - Maintenance of Emergency Preparedness

Condition Reports (CR-GGN-)

2017-00311

2017-01874

2017-04068

2017-10467

2017-11842

2018-00027

2018-02697

2018-02806

2018-02857

2018-03243

2018-03743

2018-04694

2018-06606

2018-08241

2018-09809

2018-09810

2018-09813

2018-10335

2018-12022

2018-12057

2018-12101

2018-12103

2018-12104

Work Orders

364738

488789

490278

504491

Procedures

Number

Title

Revision

01-S-10-3

Emergency Planning Department Responsibilities

10-S-01-37

Communications Drills

10-S-01-38

Emergency Plan Procedure: EAL Contingency Planning

10-S-01-39

Grand Gulf Equipment Important to Emergency

Response

10-S-02-1

ERF Inspection, Inventories, Operability Checks and

Maintenance

EN-EP-202

Equipment Important to Emergency Response

EN-EP-306

Drills and Exercises

2, 3, 4, 5,6, 7, 9

EN-FAP-EP-013

Emergency Preparedness Program Maintenance

EN-LI-102

Corrective Action Program

EN-LI-104

Self-Assessment and Benchmark Process

EN-TQ-125

Fire Brigade Drills

Miscellaneous

Documents

Number

Title

Revision

or Date

Fire Drill Scenario, Unit 1, Date: 12-20-17, Time: 10:45,

Shift/Team: D

December 20,

2017

Grand Gulf Nuclear Station After Action

Report/Improvement Plan, Exercise Date - September

18-19, 2018, Radiological Emergency Preparedness

(REP) Program

November 6,

2018

Grand Gulf Nuclear Station Emergency Drill Scenario,

August 2017 Red Team (Yellow Controlling Team)

July 21, 2017

Grand Gulf Nuclear Station February 22, 2017 Blue

Team Drill Report

Project Title: 3853 - MO2580 - Upgrade Gai-Tronics

(FTP)

November 15,

2017

9.3,

CFR 50.54(q)(3)

Evaluation

Emergency Plan, Revision: 75

March 2, 2017

GDRL-FP-FBD

Fire Brigade Drill

April 11, 2012

GDRL-FP-FBD

Fire Brigade Drill

December 16,

2013

GDRL-FP-FBD

Fire Brigade Drill

December 7,

2014

GDRL-FP-FBD

Fire Brigade Drill

December 13,

Miscellaneous

Documents

Number

Title

Revision

or Date

2015

GDRL-FP-FBD

Fire Brigade Drill

December 20,

2017

GIN 2017-00064

2017 MS-1 Drill for Merit, River Region Medical Center

April 10, 2017

GIN 2017-00071

GGN 2017 March 29 Blue Team Wertz Biennial

Exercise Report

April 18, 2017

GIN 2017-00149

GGN 2017 July 12 Red Team Collins Training Drill

Report

August 8, 2017

GIN 2017-00176

Review of Census Growth Rates and Methodology for

the Grand Gulf Nuclear Station 2017 ETE Update

September 12,

2016

GIN 2017-00177

GGN 2017 August 16 Red Team Collins Training Drill

Report

September 12,

2017

GIN 2017-00203

Quarterly Emergency Response Facilities Inventory

Report - 3rd Qtr. 2017

October 3, 2017

GIN 2017-00231

Emergency Preparedness Letter of Agreement (LOA)

Annual Review - 2017

November 13,

2017

GIN 2017-00244

Rev. 001

GGN 2017 October 25 Green Team Sumrall ERO

Training Drill Report

January 11,

2018

GIN 2017-00262

2017 Annual Media Training

December 18,

2017

GIN 2017-00263

GGN 2017 November 15-16 Onsite Medical Drill Report November 25,

2017

GIN 2017-00278

Quarterly Emergency Response Facilities Inventory

Report - 4th Q 2017

January 8, 2018

GIN 2018-00047

GGN 2018 February 28 Red Team - Collins Alternate

Facility ERO Training Drill Report Scenario # GDRL-

EP-FD01

March 29, 2018

GIN 2018-00047

GGN 2018 February 28 Blue Team - Sumrall Alternate

Facility ERO Training Drill Report Scenario # GDRL-

EP-FD01

March 29, 2018

GIN 2018-00047

GGN 2018 February 28 Green Team - Wertz Alternate

Facility ERO Training Drill Report Scenario # GDRL-

EP-FD01

March 29, 2018

GIN 2018-00047

GGN 2018 February 28 Yellow Team - Wertz/Roach

Alternate Facility ERO Training Drill Report Scenario #

GDRL-EP-FD01

March 29, 2018

GIN 2018-00054

Quarterly Emergency Response Facilities Inventory

Report - 1st Q 2018

April 4, 2018

GIN 2018-00060

GGN 2017 October 2 Semi Annual Health Physics Drill

Report

April 12, 2018

GIN 2018-00106

Quarterly Emergency Response Facilities Inventory

Report - 2nd Q 2018

June 19, 2018

Miscellaneous

Documents

Number

Title

Revision

or Date

GIN 2018-00143

Onsite Health Physics Drill, GGNS-EP-2018HPDRILL-

A, Drill Scenario and Report, Drill 06/22/2018

July 20, 2018

GIN 2018-00158

Quarterly Emergency Response Facilities Inventory

Report - 3rd Q 2018

September 11,

2018

GIN 2018-00209

Onsite Health Physics Drill, GGNS-EP-2018HPDRILL-

B, Drill Scenario and Report, Drill 09/18/2018

October 18,

2018

GIN 2018-00210

GGN 2018 October 3 Red Team Wertz ERO Training

Drill Report

November 5,

2018

KLD TR-941

Grand Gulf Nuclear Station 2017 Population Update

Analysis

O2C-GGN-2017-

0055

Oversight Observation Checklist, Activity: Emergency

Response Organization Drill, Associated Briefs, and

Critiques for Drill Conducted on 02/22/2017 (Blue

Team)

February 22,

2017

O2C-GGN-2017-

0100

Oversight Observation Checklist, Activity: Emergency

Response Organization Exercise, Associated Briefs,

and Critiques for Exercise Conducted on 03/29/2017

(Blue Team)

March 29, 2017

O2C-GGN-2017-

201

Oversight Observation Checklist, Activity: Emergency

Response Organization Drill and Associated Critiques

for Drill Conducted on 07/12/2017 (Red Team)

July 12, 2017

O2C-GGN-2017-

299

Oversight Observation Checklist, Activity: Emergency

Response Organization Drill and Associated Critiques

for Drill Conducted on 10/25/2017 (Green Team)

October 25,

2017

O2C-GGN-2018-

0039

Oversight Observation Checklist, Activity: Backup

Facility Emergency Response Organization Drills and

Associated Critiques for Drills Conducted on

2/22/2017 (Red, Blue, Green, & Yellow Teams)

February 28,

2018

QA-7-2013-GGNS-

Quality Assurance Audit Report

July 18, 2013

QA-7-2014-GGNS-

Quality Assurance Audit Report

May 29, 2014

QA-7-2015-GGNS-

Quality Assurance Audit Report

May 12, 2015

QA-7-2016-GGNS-

Quality Assurance Audit Report

May 2, 2016

QA-7-2017-GGNS-

Quality Assurance Audit Report, Audit Area:

Emergency Plan

May 30, 2017

QA-7-2018-GGNS-

Quality Assurance Audit Report, Audit Area:

Emergency Preparedness

May 14, 2018

QS-2012-GGNS-

016

GGNS Quality Assurance Surveillance Report

May 10, 2012

Miscellaneous

Documents

Number

Title

Revision

or Date

QS-2018-GGNS-

018

Grand Gulf Nuclear Station Quality Assurance

Surveillance Report

December 11,

2018

71124.05 - Radiation Monitoring Instrumentation

Condition Reports (CR-GGN-)

2015-01775

2017-00612

2017-06876

2017-08404

2017-08486

2017-09537

2017-10692

2017-10767

2017-11076

2018-01415

2018-01534

2018-07518

2018-11802

2018-11808

2018-11860

2018-11935

2018-12061

2018-12235

2018-12252

2018-12253

2018-12365

2018-12619

Condition Reports (CR-HQN-)

2018-02416

Work Orders

(WO-GGN-)

Number

Title

Date

471192

1D21K603 - Repair Alarm Issues

November 8,

2017

2256

TS/CORR FHA Monitor of AXM Channel Test

November 5,

2018

2584284

1D21K601 Calibrate Residual Heat Removal Room A

Radiation Monitor per Attached

November 8,

2017

2632817

06-IC-1D21-R-1002 - Channel B (Containment) -

Containment/Drywell High Range Area Radiation

Monitor Calibration (1D21K648B)

Sept 9, 2017

2633366

06-IC-1D21-R-1002 - Channel C (Containment) -

Containment/Drywell High Range Area Radiation

Monitor Calibration (1D21K648C)

Sept 9, 2017

2634227

06-IC-1D21-R-1002 - Channel C (Containment) -

Containment/Drywell High Range Area Radiation

Monitor Calibration (1D21K648C)

March 1, 2018

2671679

06-IC-1D17-R-1002 - Channel B - Main Steam Line

High Radiation Monitor (PCIS) Calibration (1D17K610B)

Sept 16, 2017

2671888

06-IC-1D17-R-1002 - Channel C - Main Steam Line

High Radiation Monitor (PCIS) Calibration (1D17K610C)

Sept 17, 2017

2677687

06IC121-R-1001-06 - New Fuel Handling Area, Div N

(1D21K625)

November 10,

2017

2707405

06-IC-1D21-R-1002 - Channel A (Drywell) -

Containment/Drywell High Range Area Radiation

Monitor Calibration (1D21K648A)

August 31, 2017

2708600

06-IC-1D21-R-1002 - Channel D (Drywell) -

August 31, 2017

Work Orders

(WO-GGN-)

Number

Title

Date

Containment/Drywell High Range Area Radiation

Monitor Calibration (1D21K648D)

2729513

06IC1D17-A-1003-02 - Channel B, Schedule with

Channel C - Fuel Handling Area Pool Sweep Rad

Monitor Cal (1D17K618B)

February 15,

2018

2729514

06IC1D17-A-1003-03 - Channel C, Schedule with

Channel B - Fuel Pool Sweep Exhaust Radiation

Monitor Cal (1D17K618C)

February 15,

2018

2733749

06IC1D17-A-1003-01 - Channel A, Channel D to be

Schedule with this - Fuel Pool Sweep Exhaust Radiation

Monitor (1D17K618A)

January 25,

2018

2733750

06IC1D17-A-1003-04 - Channel D, Channel A to be

Schedule with this - Fuel Pool Sweep Exhaust

Radiation Monitor (1D17K618D)

January 25,

2018

2734775

06-IC-1D17-R-1002 - Channel D - Main Steam Line

High Radiation Monitor (PCIS) Calibration (1D17K610D)

Sept 16, 2017

2736717

06IC1D17-A-0008-01 - Channel A -

Containment/Drywell Vent Exhaust (PCIS) Radiation

Monitor (1D17K609A)

October 18,

2017

2745761

06-IC-1D17-R-1002 - Channel A - Main Steam Line

High Radiation Monitor (PCIS) Calibration (1D17K610A)

Sept 16, 2017

2756945

06IC1D17-A-0008-03 Channel C - Containment/Drywell

Vent Exhaust (PCIS) Radiation Monitor (1D17K609C)

July 28, 2018

2758320

06IC1D17-A-0008-02 Channel B - Containment/Drywell

Vent Exhaust (PCIS) Radiation Monitor (1D17K609B)

July 28, 2018

2770600

06IC1D17-A-1001-01 Channel A - Fuel Handling Area

Ventilation Exhaust Radiation Monitor Calibration

Channel A (1D17K617A)

September 28,

2018

2779921

06ICSD17-A-1004-04 Channel D, Schedule to work with

Channel A - Control Room Vent Radiation Monitor

(SD17K621D)

October 18,

2018

2787228

06IC1D17-A-0008-04 Channel D - Containment/Drywell

Vent Exhaust (PCIS) Radiation Monitor (1D17K609D)

October 25,

2018

2789277

06IC1D17-A-1007 Radiation Calibration - Off-Gas Pre

Treat Radiation Recorder (1D17R604)

October 31,

2018

2802197

06-IC-1D21-R-1002 - Channel A (Drywell) -

Containment/Drywell High Range Area Radiation

Monitor Calibration (1D21K648A)

May 2, 2018

2847974-01

04103-D21-1-01 Monthly Area Rad Monitors Functional

Test

November 14,

2018

Procedures

Number

Title

Revision

04-1-03-D21-1

Monthly Area Radiation Monitors Functional Test

06-IC-1D17-A-

26

Accident Range Monitor AXM Calibration

100

06-IC-1D17-A-

27

Eberline (SPING) Radiation Monitor Calibration

100

06-IC-1D17-R-

1002

Main Steam Line High Radiation Monitor (PCIS)

Calibration

110, 111

06-IC-1D21-R-

1002

Containment/Drywell High Range Area Radiation

Monitor Calibration

110, 111, 112

08-S-07-83

Operation and Calibration of the ND-9000 Whole Body

Counter

EN-FAP-RP-007

Operation of the RP Central Calibration Facility

EN-MA-105

Control of Measuring and Test Equipment (M&TE)

EN-RP-301

Radiation Protection Instrument Control

EN-RP-303

Source Checking of Radiation Protection

Instrumentation

EN-RP-305

Source Maintenance

EN-RP-306

Calibration and Operation of the Eberline PM-7

EN-RP-308

Operation and Calibration of Gamma Scintillation Tool

Monitors

EN-RP-312

Operation and Calibration of the Canberra GEM-5

EN-RP-315

Operation and Calibration of the CRONOS

Contamination Monitor

EN-RP-317

Central Calibration Facility

EN-RP-317-02

Calibration of Portable Air Samplers

EN-RP-317-04

Calibration of Portable Area Radiation Monitors

EN-RP-317-05

Calibration of Extendable Dose Rate Instruments

EN-RP-317-07

Calibration of Portable Count Rate Instruments

EN-RP-317-08

Calibration of Portable Scalers

EN-RP-317-09

Calibration of Dosimeters

EN-RP-317-10

Calibration of Portable Dose Rate Instruments

Miscellaneous

Documents

Number

Title

Date

Certificate of Calibration for Sr-90/Y-90 S/N B6-321

March 15, 2004

Certificate of Radioactivity Calibration for Kr-85 S/N

65089-9

October 1, 1981

Instruction Manual for High-Range Containment

Monitor 875

March 24, 1986

Miscellaneous

Documents

Number

Title

Date

Operation and Maintenance Instructions: NUMAC

Logarithmic Radiation Monitor

November 1987

Source Certificate and Certificate of Calibration for CS-

137 Unit S/N M-008, Source S/N Y-155 (94-001)

December 30,

1993

2017-B2-28-

LABSTN-0003

Laboratory Standard Calibration/Verification Data - V-

570 Meter (3587M)

June 29, 2017

2017-B2-28-

SRCVER-0005

Laboratory Standard Verification Data - Model 81-6

(7010)

September 14,

2017

2017-B2-28-

SRCVER-0008

Laboratory Standard Source Verification Data - Model

(JLS-8254)

October 12,

2017

2017-B2-28-

SRCVER-0009

Laboratory Standard Source Verification Data - Model

(2414)

December 27,

2017

GIN 2006-00023

Streamlining Work Request Reviews for Preventative

Maintenance Optimization (PMO) Preventative

Maintenance (PM) Changes

January 13,

2006

MAI 275342

Task 18953, Transverse In-core Probe (TIP)

Mechanism Area Radiation Monitor (1D21K605)

April 10, 2000

Audits and Self-

Assessments

Number

Title

Date

LO-GLO-2017-21

Pre NRC Inspection Self-Assessment of RP

Instrumentation Program using 71124 Attachment 5

May 24, 2017

LO-GLO-2017-62

Self-Assessment for Pre NRC Inspection: Radiation

Monitoring Instrumentation Assessment (IP 71124.05)

August 21, 2018

LO-GLO-2018-73

Chemistry Laboratory QA/QC Program

September 5,

2018

QA-14/15-2017-

GGNS-01

Combined Radiation Protection and Radwaste Audit

Notification/Audit Plan Memorandum

October 23,

2017

Portable Instrumentation Calibration Data Sheet

Number

Title

Date

2017-B2.28-CALDAT-06663 CHP-CR-193, LM-177

December 5, 2017

2017-B2-28-CALDAT-06664 2192, LM-177

December 5, 2017

2018-B2-28-CALDAT-00003 11047, SAC-4

January 1, 2018

2018-B2-28-CALDAT-00369 CHEM-002, LV-1D

January 15, 2018

2018-B2.28-CALDAT-01492 CHP-DR-279, Model 9-3

February 19, 2018

2018-B2-28-CALDAT-01718 CHP-ASA011, H-810

February 21, 2018

2018-B2-28-CALDAT-02038 CHP-ASL049, RMA-25

February 28, 2018

2018-B2-28-CALDAT-02043 CHP-ASL024, RMA-25

February 28, 2018

2018-B2-28-CALDAT-02271 HP-DS-048, SAC-4

February 5, 2018

Portable Instrumentation Calibration Data Sheet

Number

Title

Date

2018-B2.28-CALDAT-02411

11649, AMP-100

March 7, 2018

2018-B2-28-CALDAT-02430 CHP-DR-151, RO-20

March 7, 2018

2018-B2-28-CALDAT-03310 CHPAMSD025, AMS-4 PART DET

March 23, 2018

2018-B2-28-CALDAT-04077 CHP-DR-579, RDS-31 (iTx)

May 21, 2018

2018-B2-28-CALDAT-04315 CHP-TEL085, Telepole II

June 18, 2018

2018-B2.28-CALDAT-05552 HP-DR-347, WR Telepole

August 28, 2018

2018-B2-28-CALDAT-05572 CHP-DR-418, RDS-31(iTx)

May 31, 2018

2018-B2-28-CALDAT-05581 CHP-TEL074, WR Telepole

August 30, 2018

2018-B2-28-CALDAT-05749 2991.3, RO-7H

September 4, 2018

2018-B2-28-CALDAT-05750 RHP-CR-158, LM-177

September 6, 2018

2018-B2-28-CALDAT-06176 CHP-CR-214, LM-177

September 19, 2018

Stationary Radiation Instrument Calibration Records

Number

Title

Date

Calibration of the Canberra/Nuclear Data People

Mover WBC System at the Entergy Grand Gulf

Nuclear Station

August 17, 2017

17-GEM-004

GEM-004, Canberra GEM-5

March 17, 2017

17-GEM-005

GEM-005, Canberra GEM-5

March 14, 2017

18-GEM-004

GEM-004, Canberra GEM-5

March 20, 2018

18-GEM-005

GEM-005, Canberra GEM-5

March 20, 2018

CCF1701

CRONOS CALIBRATION DATA SHEET (1701-013-

CR0400G)

April 4, 2018

CRONOS-001

CRONOS CALIBRATION DATA SHEET (1106-123)

January 16, 2017

CRONOS-001

CRONOS CALIBRATION DATA SHEET (1106-123)

January 11, 2018

CRONOS-002

CRONOS CALIBRATION DATA SHEET (1107-092)

September 27, 2017

CRONOS-003

CRONOS CALIBRATION DATA SHEET (1106-124)

January 16, 2017

CRONOS-003

CRONOS CALIBRATION DATA SHEET (1106-124)

July 2, 2018

CRONOS-004

CRONOS CALIBRATION DATA SHEET (1107-096)

January 11, 2018

CRONOS-004

CRONOS CALIBRATION DATA SHEET (1107-096)

July 2, 2018

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

Condition Reports (CR-GGN-)

2014-02598

2017-00336

2017-06224

2017-08668

2017-08747

2017-11406

2017-12122

2017-12501

2018-03230

2018-06199

2018-06533

2018-06689

2018-06921

2018-08668

2018-09300

Procedures

Number

Title

Revision

01-S-08-11

Radioactive Discharge Control

116

06-CH-SD17-A-

27

Radwaste Effluent Liquid Process Monitor Calibration

103

06-CH-SG17-M-

0042

Radwaste Release Dissolved Gases

2

06-CH-SG17-M-

0043

Radwaste Release Monthly Composite

108

06-CH-SG17-M-

0045

Radwaste Release Post-Release Calculations

105

06-CH-SG17-O-

0045

Liquid Radwaste Post Release

105

06-IC-SD17-A-

24

Liquid Radwaste Effluents Radiation Monitor Calibration 105

06-IC-SD17-R-

25

Effluent System Flow Rate Monitor Calibration

106

06-IC-SD17-R-

28

Effluent System Redundant Flow Rate Monitor

Calibration

104

06-IC-SG17-R-

1001

Liquid Radwaste Effluent Flow Calibration

101

07-S-14-314

In-Place Testing of Containment Cooling System

Charcoal Filter Trains

07-S-53-T48-4

SBGT Differential Pressure System Operation

08-S-04-220

Ventilation Exhaust Gaseous Radwaste Operations

111

EN-CY-102

Laboratory Analytical Quality Control

EN-OP-102

Protective and Caution Tagging

Miscellaneous

Documents

Number

Title

Date

2016 Grand Gulf Nuclear Station Land Use Census

December 16,

2016

2018-00175

Quantification of Unmonitored Gaseous Effluent

Release Due to Evaporation of Tritiated Water in the

CST/RWST Basin

October 8, 2018

GNRO-

2017/00055

Revised Grand Gulf Nuclear Station Annual Radioactive

Effluent Release Report

September 7,

2017

GNRO-

2017/00058

Special Report - Gaseous Radwaste Treatment System

Out of Service

September 14,

2017

GNRO-

2018/00021

Grand Gulf Nuclear Station Annual Radioactive Effluent

Release Report

April 25, 2018

W.O. 52851098

Containment Building Vent Gaseous Isotopic

November 29,

2018

Audits and Self-Assessments

Number

Title

Date

LO-GLO-2017-0063 Radioactive Gaseous and Liquid Effluent Treatment

August 16, 2018

Effluent Monitor Calibration Records

Number

Title

Date

06-IC-SD17-A-1022 SSW System Radiation Monitor Calibration

January 28, 2017

06-IC-SD17-A-1024 Liquid Radwaste Effluents Radiation Monitor

Calibration

August 1, 2016

06-IC-SD17-A-1024 Liquid Radwaste Effluents Radiation Monitor

Calibration

October 19, 2017

06-IC-SD17-A-1026

Offgas & Radwaste Ventilation Radiation Monitor

Calibration

March 14, 2018

06-IC-SD17-A-1026

Fuel Handling Area Ventilation Radiation Monitor

Calibration

April 11, 2018

06-IC-SD17-A-1026

Containment Ventilation Radiation Monitor Calibration

July 25, 2018

In-Place Filter Testing and Carbon Testing Records

Standby Gas Treatment System Filter Leak Tests

Air Cleaning System Surveillance Test Records

Number

Title

Date

WO 465517-18

Train-B SBGT

June 3, 2017

WO 52619171

Train-A SBGT

June 23, 2017

WO 52726107

Train-A Control Room Ventilation

August 23, 2018

WO 52733218

Train-B Control Room Ventilation

October 10, 2017

Liquid Radwaste Release Permits

Number

Title

Date

18-11-10-01

Batch Liquid Radwaste Discharge Permit

November 10, 2018

2017-069

Liquid Radwaste Post Release

November 9, 2017

2018-023

Liquid Radwaste Post Release

March 5, 2018

2018-024

Liquid Radwaste Post Release

March 5, 2018

2018-060

Liquid Radwaste Post Release

May 31, 2018

2018-148

Liquid Radwaste Post Release

September 29, 2018

2018-149

Liquid Radwaste Post Release

September 30, 2018

71124.07 - Radiological Environmental Monitoring Program

Condition Reports (CR-GGN-)

2017-08045

2017-08571

2017-10702

2017-10887

2018-00319

2018-03506

2018-08320

2018-11076

Procedures

Number

Title

Revision

04-S-02-SH13-

P862-1A-F6

Met System Trouble

06-EN-S000-A-

0002

Biannual Land Use Census

101

06-EN-S000-V-

0001

Radiological Environmental Sampling

2

06-IC-SC84-SA-

1003

Primary Tower Wind Speed/Direction, Air Temperature

(T/dT) and RH Calibration

107

06-OP-1000-D-

0001

Surveillance Procedure Data Package

156

07-S-53-C84-7

Backup Tower Wind Speed/Direction & Air Temperature

Calibration

08-S-04-964

Chemistry Instruction: Met Data Processing

EN-CY-102

Laboratory Analytical Quality Control

EN-CY-111

Radiological Groundwater Protection Program

EN-CY-127

Land Use Census

EN-RP-113

Response to Contaminated Spills/Leaks

Miscellaneous

Documents

Number

Title

Date

2016 Grand Gulf Nuclear Station Land Use Census

December 16, 2016

Data Review of 2017 GG Meteorological Data-Final

March 29, 2018

EN-LI-104-Att. 9.2 REMP Benchmarks Reports

June 28, 2018

GNRO-

2017/00029

Grand Gulf Nuclear Station Annual Radiological

Environmental Report

April 27, 2017

GNRO-

2017/00055

Revised Grand Gulf Nuclear Station Annual

Radioactive Effluent Release Report

September 7, 2017

GNRO-

2018/00021

Grand Gulf Nuclear Station Annual Radioactive

Effluent Release Report

April 25, 2018

GNRO-

2018/00022

Grand Gulf Nuclear Station Annual Radiological

Environmental Report

April 28, 2018

GPF-CRMP-AIR

Collect and Prepare Air Samples Training

November 26, 2013

LPN GLP-ICCT-

MET 2018

Meteorological Monitoring Training

June 20, 2018

Audits and Self-Assessments

Number

Title

Date

Entergy Audit # WT-WTHQN-2015-00728-Audit

Closure-TB

October 26, 2016

Audits and Self-Assessments

Number

Title

Date

Teledyne Brown Engineering 2nd Quarter 2018 Quality

Assurance Report

August 6, 2018

LO-GLO-2017-

00064

Pre-NRC REMP 71124.07 Self-Assessment

August 2, 2018

Groundwater

Protection

Documents

Number

Title

Revision

or Date

GGNS Groundwater Monitoring Program Improvements

Report

April 10, 2017

Groundwater Monitoring Plan for Grand Gulf Nuclear

Station

6045-0032-002

Tritium in Groundwater GGNS Upland Complex - 2nd

Quarter 2018

July 24, 2018

Meteorological Calibration Records

Number

Title

Date

2785928

Primary Tower Wind Speed/Direction, Air Temperature

(T/dT) and Relative Humidity Calibration

March 9, 2018

2811406

Primary Tower Wind Speed/Direction, Air Temperature

(T/dT) and Relative Humidity Calibration

October 8, 2018

CHEM-001

Air Sampler Calibration Data Sheet

February 20, 2018

CHEM-003

Air Sampler Calibration Data Sheet

January 11, 2018

CHEM-005

Air Sampler Calibration Data Sheet

January 11, 2018

CHEM-008

Air Sampler Calibration Data Sheet

January 11, 2018

71124.08 - Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage,

and Transportation

Condition Reports (CR-GGN-)

2017-10774

2018-07380

2018-08573

Condition Reports (CR-HQN-)

2017-01543

2017-01544

2018-01427

Procedures

Number

Title

Revision

2-S-01-11

Radwaste Operations

08-S-06-50

Loading Radioactive Material

EN-RP-121

Radioactive Material Control

EN-RP-121-01

Receipt of Radioactive Material

Procedures

Number

Title

Revision

EN-RW-101

Radioactive Waste Management

EN-RW-102

Radioactive Shipping Procedure

EN-RW-103

Radioactive Waste Tracking Procedure

EN-RW-104

Scaling Factors

EN-RW-105

Process Control Program

EN-RW-106

Integrated Transportation Security Plan

Miscellaneous

Documents

Number

Title

Revision

or Date

2017

Annual Radiological Effluent Release Report

April 25, 2018

ASP-077

Calibration Data Sheet: ASP-1 (SPA-3)

February 20, 2018

BR-D-NA SRT

Bead Resin

CFR Part 61 Waste Stream Sample Screening and

Evaluation

August 9, 2018

DAW-U-NA

CFR Part 61 Waste Stream Sample Screening and

Evaluation

March 9, 2017

EC-18365

Process Applicability Determination

HP-644

Type A Cask Loading and Shipping Check-Off Sheet

Audits and Self-Assessments

Number

Title

Date

LO-GLO-2017-

00065 CA-00002

Self-Assessment: Pre-NRC Inspection Module

71124-08

August 16, 2018

QA-14/15-2017-

GGNS-01

Combined Radwaste and Radiation Protection Audit

September 12, 2017

Radioactive Material and Waste Shipments

Number

Title

Package

GGN-2017-0708

>A LSA-II RQ Cat 2 (RWCU-A Partial Liner)

Type A

GGN-2017-1101

Type A Package (RWCU-B Sample - 5-gallon drum)

Type A

GGN-2017-1202

LSA-II, RQ-Radionuclides (RWCU-B/CPS-B)

Type A

GGN-2018-0906

UN 2916, Radioactive Material - Type B)(U) Package, 7

Fissile Excepted, RQ Radionuclide

(Irradiated Hardware)

Type B(U)

GGN-2018-1010

UN 2916, Radioactive Material - Type B)(U) Package, 7

Fissile Excepted, RQ Radionuclide

(Irradiated Hardware)

Type B(U)

Radiation Surveys (GG-)

1710-0418

1806-1153

1806-1179

1806-1198

1806-1220

1806-1244

1806-1286

1806-1339

1807-0028

71151 - Performance Indicator Verification

Condition Reports (CR-GGN-)

2017-09975

2017-10167

Miscellaneous

Documents

Number

Title

Date

GIN 2017-210

Alert Notification System Test

October 9, 2017

GIN 2017-253

Alert Notification System Test

December 6,

2017

GIN 2017-264

Alert Notification System Test

November 15,

2017

GIN 2018-00001

Alert Notification System Test

January 6, 2017

GIN 2018-00028

Alert Notification System Test

February 7,

2018

GIN 2018-00037

Alert Notification System Test

March 13, 2018

GIN 2018-00055

GGNS Emergency Response Organization Duty Roster

April 5, 2018

GIN 2018-00076

GGNS Emergency Response Organization Duty Roster

April 30, 2018

GIN 2018-00078

Alert Notification System Test April 2018

May 1, 2018

GIN 2018-00079

Alert Notification System Test

May 3, 2018

GIN 2018-00123

June 2018 Alert Notification System Test

July 18, 2018

GIN 2018-00124

July 2018 Alert Notification System Test

July 31, 2018

GIN 2018-00138

Alert Notification System Test

August 6, 2018

GIN 2018-00166

Alert Notification System Test

September 25,

2018

71152 - Problem Identification and Resolution

Condition Reports (CR-GGN-)

2016-02442

2018-08059

2018-11148

2018-11149

2018-11172

2018-11179

2018-11230

Work Orders

440940

505473

Request for Information

Focused Baseline Inspection

Grand Gulf

Inspection Report: 05000416/2018004

Inspection Dates: October 1 - December 31, 2018

Inspection Procedure: IP 71111 series, IP 71151, IP 71152

Lead Inspector: Dan Bradley, Senior Resident Inspector

Information Requested For 4th Quarter 2018

The following information should be sent in electronic format (Certrec IMS preferred) to the

attention of Dan Bradley by October 8, 2018. Please provide requested documentation

electronically in pdf files, Excel, or other searchable formats, if possible. The information

should contain descriptive names and be indexed or hyperlinked to facilitate ease of use. If

requested documents are large and/or only hard copy formats are available, please inform the

inspector for clarification.

Please provide information for the following topic:

Lubrication oil, fuel oil, and hydraulic control oil used in the following systems:

a. Reactor Core Isolation Cooling (RCIC)

b. Low Pressure Core Spray (LPCS)

c. Low Pressure Cooling Injection (LPCI/RHR)

d. High Pressure Core Spray (HPCS)

e. Standby Liquid Control (SLC)

f.

Standby Service Water (SSW)

g. High Pressure Core Spray Service Water (HPCS SWS)

h. Emergency Diesel Generators

1.

Condition reports associated with the selected topic for the last 3 years including the

associated operability determination.

2.

Vendor manuals and industry standards used for the selected topic.

3.

Preventative maintenance schedules and basis for the selected topic, including oil

changes and samples.

4.

A table with oil used for the selected topic that lists type/manufacturer of the oil, how it is

procured (commercial or safety-related), if any additional processes are applied to it prior

to use (such as filtration), and critical specifications (temperature range, maximum

particulate size, etc.).

5.

Oil analysis results for the selected topic for the last 3 years.

6.

A list of work orders associated with the selected topic for the last 3 years, including

open work orders.

7.

Complete work orders for associated with the selected topic for the last 3 years that

involved adding oil. Please include quality assurance records for the oil.

8.

Site procedures for the selected topic including normal operations, maintenance,

offnormal, chemistry, and surveillance testing. Please include filtration procedures,

storage of the filtration skid components, preventative maintenance performed on the

filtration skid, and procedures that involve use of the oil issue facility in the Turbine

Building for the selected topic.

9.

Administrative and/or program procedures for the selected topic including operability

determinations, Corrective Action Program (including trending requirements and

definitions of prompt/promptly resolving adverse conditions), storage of quality parts,

foreign material exclusion, system performance monitoring programs, dedicating

commercial-grade components for safety-related use, oil programs, post-maintenance

testing program, and operating experience.

10. A list of allowed storage areas for the selected topic.

11. A list of any engineering evaluations or calculations with low design margins for the

selected topic.

2. A list of maintenance rule components and functions; based on engineering or expert

panel judgment, for the selected topic.

13. A list of maintenance rule functional failure evaluations for the last 3 years for the

selected topic.

14. A list of operating experience evaluations for the last 3 years for the selected topic.

15. A list of root cause and apparent cause evaluations associated initiated/completed in the

last 3 years for the selected topic.

16. A list of Corrective Actions to Prevent Recurrence (CAPRs) for the selected topic.

17. A list of any common-cause failures of components in the last 3 years for the selected

topic.

18. A mechanical drawing of the RCIC system and piping that includes the safety-related

boundaries of the system.

19. An electronic copy of the design bases documents for the selected topic.

20. An electronic copy of the system health notebooks for the selected topic.

Inspector Contact Information:

Dan Bradley

Senior Resident Inspector

573-676-3181

Dan.Bradley@nrc.gov

The following items are requested for the

Public Radiation Safety Inspection

at Grand Gulf

Dates of Inspection: 11/26/2018 to 11/30/2018

Integrated Report 2018004

Inspection areas are listed in the attachments below.

Please provide the requested information on or before Monday, October 29, 2018.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.05 should be in a file/folder titled

5-A, applicable organization charts in file/folder 5-B, etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Natasha Greene at 817-200-1154 or via

e-mail at Natasha.Greene@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.

5.

Radiation Monitoring Instrumentation (71124.05)

Date of Last Inspection:

July 10, 2017

A.

List of contacts and telephone numbers for the following areas below. Please include

area code and prefix. If work cell numbers are appropriate, then please include them as

well.

1. Process monitor calibration (Include Chemistry, Systems Engineering and I&C, as

applicable)

2. Radiation protection instrument calibration (Portable and Stationary)

3. Installed instrument calibrations (Include Systems Engineering and I&C)

4. Count room and Laboratory instrument calibrations (Include RP and Chemistry, as

applicable)

5. EP contacts for Equipment Important to Emergency Response/Preparedness

(EITER)

6. Licensing/Regulatory Affairs

7.

B.

Applicable organization charts, including position or job titles. Please include as

appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),

Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C.

Copies of audits, self-assessments, vendor or NUPIC audits for contractor support,

LARs, and LERs, performed since the date of the last inspection, related to:

1. Portable Radiation instruments: Area radiation monitors, portable continuous air

monitors (AMS3/4), portable survey instruments (count rate, dose rate, occupational

air sampling), electronic dosimeters, teledosimetry

2. Stationary Radiation Instruments: Portal monitors, small article monitors, personnel

contamination monitors, or whole body counters

3. Installed Radiation Instruments: Area radiation monitors (RMS), process monitors

(non-effluent), criticality monitors, accident monitors

4. Count Room instrumentation (Chemistry and RP, if separate RP Ops and Effluents):

Gamma Spec, LSC, Gross Alpha, Gross Beta, including bench-top counters

5.

D.

Procedure indexes for radiation protection procedures and other related disciplines.

1. Calibration, use, and operation of continuous air monitors, portable survey

instruments, temporary area radiation monitors, electronic dosimeters, teledosimetry

2. Calibration use and operation of portal monitors, small article monitors, personnel

contamination monitors, and whole body counters

3. Calibration of installed area radiation monitors, process monitors, criticality monitors,

and accident monitors

4. Calibration use and operation of Count Room instrumentation (GS, LSC, GA, GB)

(include bench top counters here)

NOTE: Please ensure that RP, Chemistry, and I&C procedures are included, as

appropriate.

E.

Please provide specific procedures related to the following areas noted below.

Additional procedures may be requested by number after the inspector reviews the

procedure index.

1. Calibration of portable ion chambers

2. Calibration of Friskers

3. Calibration of telescoping high range instruments

4. Calibration of portable neutron instruments

5. Calibration of SAMs

6. Whole body counter calibration

7. Laboratory instrumentation quality control

8. Calibration of Containment/Drywell high range radiation monitor

F.

Please provide a list of NRC Regulatory Guides and NUREGs that you are currently

committed to relative to this program. Please include the revision and/or date for the

commitment and where this may be located in your current licensing basis documents.

G.

Please provide a summary list of corrective action documents (including corporate and

sub-tiered systems) written since the date of the last inspection, related to the following

programs:

1. Area radiation monitors, continuous air monitors, portable survey instruments,

electronic dosimeters, and teledosimetry

2. Portal monitors, small article monitors, personnel contamination monitors, and whole

body counters

3. Installed radiation monitors, criticality monitors, accident range monitors

4. Count room radiation instruments

NOTE: These lists should include a description of the condition that provides

sufficient detail that the inspectors can ascertain the regulatory impact, the

significance level assigned to the condition, the status of the action (e.g., open,

working, closed, etc.) and the search criteria used. Please provide in document

formats which are sortable and searchable so that inspectors can quickly and

efficiently determine appropriate sampling and perform word searches, as

needed. (Excel spreadsheets are the preferred format.) If codes are used,

please provide a legend for each column where a code is used.

H.

State the required calibration frequency and provide the most recent calibration data for

the whole body counters, at least one portable survey instrument, one area radiation

monitor, one air sampler, one continuous air monitor, and one drywell/containment high-

range monitor.

I.

Provide a list of any scheduled calibrations, while we are onsite, for the instrumentation

noted in request above, in 5-I.

J.

Provide the alarm set point values for the portal and personnel contamination monitors in

operation.

K.

Radiation Monitoring System health report for the previous 12 months

L.

Provide the following lists of instruments to include make, model, identifier (S/N or plant

ID), and location:

1. Portable radiation instruments currently in use (for EADs just make, model, and

quantity).

2. Stationary radiation instruments currently in use.

3. Installed Radiation monitors

a. Area radiation monitors and

b. Process radiation monitors.

(Include their instrumentation designator, function and calibration procedure

number and title.) Please indicate which, if any, detectors have been

replaced within the past 2 years (since the last inspection).

c. Radiation instrumentation abandoned in place.

d. Radiation instrumentation covered by the maintenance rule.

M.

Provide a list of sources used routinely for source check of portable, stationary, and

installed radiation monitoring instruments.

N.

Provide the NIST traceability and calibration or verification of the primary sources for

instrument calibration and the procedures used to achieve this.

6.

Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

Date of Last Inspection:

July 10, 2017

A.

List of contacts and telephone numbers for the following areas. Please include area

code and prefix. If work cell numbers are appropriate, then please include them as well.

1. Radiological effluent control (liquid & gaseous) and reporting

(RP, Chemistry, RW, Ops, etc.)

2. Effluent Monitor calibration (liquid and gaseous) and maintenance

(RP, Chemistry, I&C, Maintenance, Systems Engineering, EP, etc.)

3. Engineered safety feature air cleaning systems for effluent release

(Systems Engineering, I&C, Maintenance, etc.)

4. Licensing/Regulatory Affairs

B.

Applicable organization charts including position or job titles for the above individuals

and also for their supportive Management. Please include as appropriate for your site,

Site Management, RP, Chemistry, Maintenance (I&C), Engineering, and Emergency

Protection. (Recent pictures are appreciated.)

C.

Copies of audits, self-assessments, vendor, or NUPIC audits of contractor support, and

LERs written since the date of the last inspection, related to:

1. Radioactive effluents and effluent radiation monitors

2. Engineered Safety Feature Air cleaning systems

D.

Procedure indexes for the following areas and related disciplines.

1. Radioactive effluents and effluent radiation monitors (to include the flow monitors)

2. Engineered Safety Feature Air cleaning systems (both TS and non-TS systems for

effluents)

E.

Please provide specific procedures related to the following areas noted below.

Additional procedures may be requested by number after the inspector reviews the

procedure indexes.

1. Sampling and analysis of radioactive effluents

2. Effluent monitor setpoint determination

3. Generating radioactive effluent release permits

4. Effluent Monitor Calibrations (Include associated flow monitors)

5. Laboratory instrumentation quality control

6. In-place testing of HEPA filters and charcoal adsorbers for TS effluent exhaust

systems and other effluent air-cleaning systems, but not breathing air systems

F.

Please provide a list of NRC Regulatory Guides and NUREGs that you are currently

committed to relative to this program. Please include the revision and/or date for the

commitment and where this may be located in your current licensing basis documents.

G.

Please provide a summary list of corrective action documents (including corporate and

sub-tiered systems) written since the date of the last inspection, associated with:

1. Radioactive effluents

2. Effluent radiation monitors (include associated effluent flow monitors)

3. Engineered Safety Feature Air cleaning systems (effluents, not breathing air)

NOTE: These lists should include a description of the condition that provides

sufficient detail that the inspectors can ascertain the regulatory impact, the

significance level assigned to the condition, the status of the action (e.g., open,

working, closed, etc.) and the search criteria used. Please provide in document

formats which are sortable and searchable so that inspectors can quickly and

efficiently determine appropriate sampling and perform word searches, as

needed. (Excel spreadsheets are the preferred format.) If codes are used,

please provide a legend for each column where a code is used.

H.

Annual Radioactive Effluent Release Reports for the latest two calendar years

I.

Current revision of the Offsite Dose Calculation Manual (or other name, but include all

parts for effluents) and any changes made since the last inspection.

J.

The inter-laboratory comparison results for laboratory quality control performance of

effluent sample analysis for the latest two calendar years

K.

Effluent sampling schedule for the week of the inspection

L.

Provide the last three annual trends of vent/stack effluent flow rates, by chart or table.

M.

Operations department (or other responsible dept.) log records for effluent monitors

removed from service or out of service or a list of the same and compensatory actions

taken during the out of service condition.

N.

Listing or log of liquid and gaseous release permits since the date of the last inspection

O.

A list of the technical specification-required air cleaning systems with the two most

recent surveillance test dates of in-place filter testing (of HEPA filters and charcoal

adsorbers) and laboratory testing (of charcoal efficiency) and the work order numbers

associated with the surveillances (and their system number/name).

P.

System Health Report for radiation monitoring instrumentation. Also, please provide a

specific list of all effluent radiation monitors that were considered inoperable for 7 days

or more since the date of the last inspection. If applicable, please provide the relative

Special Report and condition report(s). If not covered by maintenance rule, please

provide rationale.

Q.

A list of significant changes made to the gaseous and liquid effluent process monitoring

system since the date of the last inspection. If applicable, please provide the

corresponding UFSAR section in which this change was documented.

R.

A list of any occurrence in which a non-radioactive system was contaminated by a

radioactive system since the date of the last inspection. Please include any relevant

condition report(s).

S.

Current Part 61 analyses for hard to detect radionuclides

T.

Latest Land Use Census (coordinate with 71124.07)

U.

Effluent based procedures for EALs or EOPs.

7.

Radiological Environmental Monitoring Program (71124.07)

Date of Last Inspection:

July 10, 2017

A.

List of contacts and telephone numbers for the following areas. Please include area

code and prefix. If work cell numbers are appropriate, then please include them as well.

1. Radiological environmental monitoring (RP, Chemistry, I&C, etc.)

2. Meteorological monitoring (RP, Chemistry, EP, I&C, System Engineering, etc.)

3. Maintenance and calibration of the above equipment

4. Licensing/Regulatory Affairs

B.

Applicable organization charts including position or job titles. Please include as

appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),

Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C.

Copies of audits, self-assessments, vendor or NUPIC audits of contractor support, and

LERs written since the date of the last inspection, related to:

1. Radiological environmental monitoring program (including contractor environmental

laboratory audits, if used to perform environmental program functions)

2. Environmental TLD processing facility

3. Meteorological monitoring program

D.

Procedure index for the following areas and other related disciplines.

1. Radiological environmental monitoring program

2. Meteorological monitoring program

3. Maintenance and calibration of related instrumentation, including the meteorological

tower

E.

Please provide specific procedures related to the following areas noted below.

Additional procedures may be requested by number after the inspector reviews the

procedure indexes.

1. Sampling, collection and preparation of environmental samples

2. Sample analysis (if performed onsite)

3. Laboratory instrumentation quality control

4. Meteorological Tower sensor calibrations

F.

Please provide a list of NRC Regulatory Guides and NUREGs that you are currently

committed to relative to this program. Please include the revision and/or date for the

commitment and where this may be located in your current licensing basis documents.

G.

Please provide a summary list of corrective action documents (including corporate and

sub-tiered systems) written since the date of the last inspection, related to the following

programs:

1. Radiological environmental monitoring (include TLDs and air sample pumps or their

infrastructure)

2. Meteorological monitoring (include Met Tower sensors and support equipment)

These lists should include a description of the condition that provides sufficient

detail that the inspectors can ascertain the regulatory impact, the significance

level assigned to the condition, the status of the action (e.g., open, working,

closed, etc.) and the search criteria used. Please provide in document formats

which are sortable and searchable so that inspectors can quickly and

efficiently determine appropriate sampling and perform word searches, as

needed. (Excel spreadsheets are the preferred format.) If codes are used,

please provide a legend for each column where a code is used.

H.

Copies of the two most recent calibration packages for the meteorological tower

instruments

I.

Copies of the Annual Radiological Environmental Operating Reports and Land Use

Census for the latest two calendar years, and current revision of the Offsite Dose

Calculation Manual. Please include any supportive documentation for the changes

made to the ODCM since the last inspection.

J.

Copy of the environmental laboratorys inter-laboratory comparison program results for

the latest two calendar years, if not included in the Annual Radiological Environmental

Operating Report

K.

Data from the environmental laboratory documenting the analytical detection sensitivities

for the various environmental sample media (i.e., air, water, soil, vegetation, and milk)

L.

Quality Assurance audits (e.g., NUPIC) for contracted services

M.

Current NEI Groundwater Protection Initiative (GPI) Plan and status. Provide the most

recent monitoring results for each monitoring well per the GPI. Provide a separate list of

any missed samples, as applicable.

N.

Technical requirements manual or licensee controlled specifications which list the

meteorological instruments calibration requirements

O.

If applicable, per NEI 07-07, provide any reports that document any spills/leaks to

groundwater since the date of the last inspection. Please indicate what external

communications were made regarding each spill/leak.

P.

Provide any new entries into 10 CFR 50.75(g) files since the date of the last inspection.

Q.

Please identify your three highest X/Q (chi/Q) and/or D/Q sectors, as currently used in

the selection of your required REMP sampling locations. If these are different values

from your most recent meteorological assessment, please provide that assessment and

indicate the three highest X/Q and/or D/Q sectors per your latest assessment. Also

indicate your noted predominant and least prevalent wind direction/sector, as used in

your REMP analysis.

R.

Provide the height of the highest effluent release point. Please indicate if the height

accounts for plant grade elevation.

8.

Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage,

and Transportation (71124.08)

Date of Last Inspection:

July 10, 2017

A.

List of contacts and telephone numbers for the following areas. Please include area

code and prefix. If work cell numbers are appropriate, then please include them as well.

1. Solid Radioactive waste processing (RP, Chemistry, Ops, Maintenance, I&C,

Engineering, etc.)

2. Transportation of radioactive material/waste (RP, Maintenance, Ops, Security,

Chemistry, etc.)

3. personnel involved in solid radwaste processing, transferring, and transportation of

radioactive waste/materials)

4. Licensing/Regulatory Affairs

B.

Applicable organization charts including position or job titles. Please include as

appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),

Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C.

Copies of audits, department self-assessments, and LERs written since the date of the

last inspection, related to:

1. Solid radioactive waste management

2. Radioactive material/waste transportation program

D.

Procedure index for the following areas and other related disciplines.

1. Solid radioactive waste management

2. Radioactive material/waste transportation

E.

Please provide specific procedures related to the following areas noted below.

Additional procedures may be requested by number after the inspector reviews the

procedure indexes.

1. Process control program and any changes made since the last inspection

2. Solid and liquid radioactive waste processing

3. Waste stream sampling and analysis

4. Waste characterization and classification

5. Radioactive material/waste packaging & shipping

F.

Please provide a list of NRC Regulatory Guides and NUREGs that you are currently

committed to relative to this program. Please include the revision and/or date for the

commitment and where this may be located in your current licensing basis documents.

G.

Please provide a summary list of corrective action documents (including corporate and

sub-tiered systems) written since the date of the last inspection, related to:

1. Solid radioactive waste

2. Transportation of radioactive material/waste

NOTE: These lists should include a description of the condition that provides

sufficient detail that the inspectors can ascertain the regulatory impact, the

significance level assigned to the condition, the status of the action (e.g., open,

working, closed, etc.) and the search criteria used. Please provide in document

formats which are sortable and searchable so that inspectors can quickly and

efficiently determine appropriate sampling and perform word searches, as

needed. (Excel spreadsheets are the preferred format.) If codes are used,

please provide a legend for each column where a code is used.

H.

Copies of training lesson plans for 49 CFR 172, Subpart H, for radwaste processing,

packaging, and shipping

I.

Provide a summary list or log of radioactive material and radioactive waste shipments for

the two most recent calendar years, in addition to the current calendar year.

J.

Please provide at least two different radioactive waste stream sample analysis results

and resulting scaling factors for the latest two calendar years.

K.

A listing of all onsite radwaste storage facilities. Please include a summary or list of the

items stored in each facility with the most recent dose rates/surveys.

L.

A list of any significant (e.g., DAW, resins, Type B or greater) radioactive shipments that

will be completed during our onsite inspection period. If available, please provide the

applicable shipping manifests/waste characterizations and most recent surveys for each

shipment.

M.

A list of significant changes made to the liquid or solid radwaste processing systems

since the date of the last inspection. If applicable, please provide the corresponding

UFSAR section in which this change was documented. Provide any supportive

documentation for the changes made or have it readily available for review.

N.

List of radioactive waste processing systems or equipment abandoned in place since the

last inspection.

O.

Please provide a schedule of radioactive material or waste processing or shipment

activities during the inspection week. Please indicate the current storage location of the

stored RAM or waste prepared for shipment, as well as any supportive surveys of its

measured dose rates. If available, please indicate its current stated waste class.

ML19038A437

SUNSI Review

ADAMS:

Non-Publicly Available

Non-Sensitive

Keyword:

By: JKozal

Yes No

Publicly Available

Sensitive

NRC-002

OFFICE

SRI:DRP/C

RI:DRP/C

SRI:DRP/B

RI:DRP/C

BC:DRS/EB1

ABC:DRS/EB2

NAME

TSteadham

NDay

DBradley

BParks

VGaddy

JDrake

SIGNATURE

TCS

NHD

DB via email

BP

VGG

JD

DATE

01/24/2019

01/23/2019

1/24/2019

1/22/2019

1/22/19

1/18/2019

OFFICE

BC:DRS/OB

BC:DRS/PSB2

ATL:DRS/IPAT

SPE:DRP/C

BC:DRP/C

NAME

GWerner

HGepford

RKellar

CYoung

JKozal

SIGNATURE

GEW

HJG

RLK

CHY

JWK

DATE

01/20/2019

01/22/2019

01/22/2019

1/18/2019

2/7/2016