ML23122A163
| ML23122A163 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 05/18/2023 |
| From: | Geoffrey Miller NRC/RGN-IV/DRSS |
| To: | Kapellas B Entergy Operations |
| Greene N | |
| References | |
| EA-23-019 IR 2023090 | |
| Download: ML23122A163 (15) | |
See also: IR 05000416/2023090
Text
May 18, 2023
Brad Kapellas, Site Vice President
Entergy Operations, Inc.
P.O. Box 756
Port Gibson, MS 39150
SUBJECT: GRAND GULF NUCLEAR STATION - NRC INSPECTION REPORT
05000416/2023090 AND PRELIMINARY WHITE FINDING
Dear Brad Kapellas:
This letter refers to the inspection conducted from November 14, 2022, to April 5, 2023, by the
U.S. Nuclear Regulatory Commission (NRC) at the Grand Gulf Nuclear Station. The purpose of
the inspection was to verify Entergy Operations, Inc. (licensee) is ensuring the accuracy and
operability of radiation monitoring instruments that are used to monitor areas, materials, and
workers to ensure a radiologically safe work environment and detect and quantify radioactive
process streams and effluent releases. On April 5, 2023, a final exit briefing was conducted with
you and other members of your staff. The results of the inspection are documented in the
enclosed report.
The enclosed report discusses a preliminary White finding (i.e., a finding with low-to-moderate
safety significance that may require additional NRC inspections), with three associated
apparent violations. As described in the enclosed report, during the week of November 14,
2022, NRC inspectors reviewed documents related to your radiation monitoring instrumentation
program and identified calibration failures for the drywell and containment high range area
radiation monitors. The finding was assessed based on the best available information, using the
applicable significance determination process (SDP). The final resolution of this finding will be
conveyed in separate correspondence.
The finding has three associated apparent violations which are being considered for escalated
enforcement action in accordance with the NRC Enforcement Policy, which can be found at
http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The apparent violations
involve the failure to: (1) calibrate primary drywell and containment high range area radiation
monitors in accordance with 10 CFR 20.1501(c); (2) follow and maintain the effectiveness of an
emergency plan that meets the requirements in 10 CFR Part 50, Appendix E, and the planning
standards of 10 CFR 50.47(b); and (3) maintain the drywell and containment high range area
radiation monitors operable or else initiate action to prepare and submit a Special Report to the
NRC immediately.
B. Kapellas 2
In accordance with NRC Inspection Manual Chapter 0609, we intend to complete our evaluation
using the best available information and issue our final significance determination and
enforcement decision, in writing, within 90 days from the date of this letter. The significance
determination process encourages an open dialogue between your staff and the NRC; however,
the dialogue should not impact the timeliness of our final determination.
Before we make a final decision on this matter, we are providing you with an opportunity to
either (1) attend a Regulatory Conference where you can present to the NRC your perspective
on the facts and assumptions the NRC used to arrive at the finding and assess its significance,
or (2) submit your position on the finding to the NRC in writing. If you request a Regulatory
Conference, it should be held within 40 days of the receipt of this letter, and we encourage you
to submit supporting documentation at least one week prior to the conference in an effort to
make the conference more efficient and effective. The focus of the Regulatory Conference is to
discuss the significance of the finding and not necessarily the root cause(s) or corrective
action(s) associated with the finding. If a Regulatory Conference is held, it will be open for public
observation. If you decide to submit only a written response, such submittal should be sent to
the NRC within 40 days of your receipt of this letter.
If you decline to request a Regulatory Conference or to submit a written response, you
relinquish your right to appeal the final SDP determination, in that by not doing either, you fail to
meet the appeal requirements stated in the Prerequisite and Limitation sections of Attachment 2
of NRC Inspection Manual Chapter 0609.
If you choose to send a written response, it should be clearly marked as a Response to
Apparent Violations in NRC Inspection Report 05000416/2023090; EA-23-019 and should
include for the apparent violations: (1) the reason for the apparent violations or, if contested, the
basis for disputing the apparent violations; (2) the corrective steps that have been taken and the
results achieved; (3) the corrective steps that will be taken; and (4) the date when full
compliance will be achieved. Your response may reference or include previously docketed
correspondence if the correspondence adequately addresses the required response.
Additionally, your written response should be sent to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Director,
Division of Radiological Safety and Security, U.S. Nuclear Regulatory Commission, Region IV,
1600 East Lamar Blvd., Arlington, Texas 76011-4511, and the NRC Resident Inspector at the
Grand Gulf Nuclear Station, and emailed to R4Enforcement@nrc.gov, within 40 days of the date
of this letter. If an adequate response is not received within the time specified or an extension of
time has not been granted by the NRC, the NRC will proceed with its enforcement decision or
schedule a Regulatory Conference.
Please contact Gregory Warnick at 817-200-1249 within 10 days from the issue date of this
letter to notify the NRC of your intentions. If we have not heard from you within 10 days, we will
continue with our significance determination and enforcement decision. The final resolution of
this matter will be conveyed in separate correspondence.
Because the NRC has not made a final determination in this matter, a Notice of Violation is not
being issued at this time. In addition, please be advised that the number and characterization of
the apparent violations described in the enclosed inspection report may change as a result of
further NRC review.
B. Kapellas 3
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a
copy of this letter, its enclosure, and your response, if you choose to provide one, will be made
available electronically for public inspection in the NRC Public Document Room and from the
NRCs Agencywide Documents Access and Management System (ADAMS), accessible from
the NRC website at http://www.nrc.gov/reading-rm/adams.html.
If you have any questions concerning this matter, please contact Gregory Warnick of my staff
at 817-200-1249.
Sincerely,
Rivera-Varona, Aida signing on behalf
of Miller, Geoffrey
on 05/18/23
Geoffrey B. Miller, Director (Acting)
Division of Radiological Safety & Security
Docket No. 05000416
License No. NPF-29
Enclosure:
NRC Inspection Report 05000416/2023090
cc w/ encl: Distribution via LISTSERV
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: ACR Yes No Publicly Available Sensitive NRC-002
OFFICE ES:ACES HP:DIOR SHP:DIOR C:DIOR C:PBA TL:ACES
NAME ARoberts DAntonangeli NGreene GWarnick JJosey RKumana
SIGNATURE /RA/ E /RA/ E /RA/ E /RA/ E /RA/ E /RA/ E
DATE 05/02/23 /05/02/23 05/02/23 05/02/23 05/02/23 05/04/23
OFFICE RC NRR NSIR OE D:DORS D:DRSS
NAME DCylkowski RFelts MMcCoppin JPeralta RLantz AXR1 for GMiller
SIGNATURE /RA/ E /RA/ E /RA/ E /RA/ E /RA/ E /RA/ E
DATE 05/05/23 05/09/23 05/15/23 05/11/23 05/16/23 05/18/23
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number: 05000416
License Number: NPF-29
Report Number: 05000416/2023090
Enterprise Identifier: I-2023-090-0003
Licensee: Entergy Operations, Inc.
Facility: Grand Gulf Nuclear Station
Location: Port Gibson, MS
Inspection Dates: November 14, 2022 to April 5, 2023
Inspectors: D. Antonangeli, Health Physicist
N. Greene, Senior Health Physicist
S. Hedger, Senior Emergency Preparedness Inspector
Approved By: Gregory G. Warnick, Chief
Decommissioning, ISFSI & Operating Reactors Branch
Division of Radiological Safety & Security
Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting a NRC inspection at Grand Gulf Nuclear Station, 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.
List of Findings and Violations
Failure to calibrate primary drywell and containment high range area radiation monitors in
accordance with 10 CFR 20.1501(c)
Cornerstone Significance Cross-Cutting Report
Aspect Section
Emergency Preliminary White [H.9] - Training 71124.05
Preparedness AV 05000416/2023090-01
Open
During the week of November 14, 2022, NRC inspectors reviewed documents related to the
licensees radiation monitoring instrumentation program and identified calibration failures for
their drywell and containment high range area radiation monitors (1D21K648A, 1D21K648B,
1D21K648C, and 1D21K648D). The calibration failures impacted all four radiation monitors.
The licensee failed to perform a calibration in accordance with NRC requirements of
10 CFR 20.1501(c). The licensee then failed to declare these radiation monitors inoperable in
accordance with their technical specification requirements (TS 3.3.3.1 and TS 3.0.1) and
perform the associated limiting condition for operation (LCO) action. Inoperable radiation
monitors would be unable to perform their intended function for Emergency Preparedness
actions in accordance with 10 CFR 50.54(q)(2).
Additional Tracking Items
None.
2
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 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.
RADIATION SAFETY
71124.05 - Radiation Monitoring Instrumentation
Calibration and Testing Program (IP Section 03.02) (4 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection
instruments per procedure 06-IC-1D21-R-1002:
(1) drywell high range area monitor, plant I.D: 1D21K648A
(2) drywell high range area monitor, plant I.D: 1D21K648D
(3) containment high range area monitor, plant I.D: 1D21K648B
(4) containment high range area monitor, plant I.D: 1D21K648C
INSPECTION RESULTS
Failure to calibrate primary drywell and containment high range area radiation monitors in
accordance with 10 CFR 20.1501(c)
Cornerstone Significance Cross-Cutting Report
Aspect Section
Emergency Preliminary White [H.9] - Training 71124.05
Preparedness AV 05000416/2023090-01
Open
During the week of November 14, 2022, NRC inspectors reviewed documents related to the
licensees radiation monitoring instrumentation program and identified calibration failures for
their drywell and containment high range area radiation monitors (1D21K648A, 1D21K648B,
1D21K648C, and 1D21K648D). The calibration failures impacted all four radiation monitors.
The licensee failed to perform a calibration in accordance with NRC requirements of
10 CFR 20.1501(c). The licensee then failed to declare these radiation monitors inoperable in
accordance with their technical specification requirements (TS 3.3.3.1 and TS 3.0.1) and
perform the associated limiting condition for operation (LCO) action. Inoperable radiation
monitors would be unable to perform their intended function for Emergency Preparedness
actions in accordance with 10 CFR 50.54(q)(2).
Description: The NRC inspectors reviewed documents related to the licensees radiation
monitoring instrumentation program. The inspectors identified documented failures of
selected radiation monitoring instruments associated with the sensitivity parameters. Upon
further review, inspectors determined that all four of the licensees accident high range
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radiation monitors (two drywell - detectors A and D, two containment - detectors B and C)
failed to be within the sensitivity tolerances during their last two calibrations cycles.
The sensitivity parameter represents the fundamental way the detector (in this case an ion
chamber) works. This parameter relates the output signal of the detector to the amount of
radiation present. The calibration process uses this parameter to demonstrate the
instruments ability to accurately detect radiation. For context, the sensitivity parameter was
determined in a controlled laboratory environment where the detector was exposed to a
known radiation field (in roentgens per hour (R/hr)) that resulted in a corresponding output
current (in amps) based on the collection efficiency of the detector. This was how the
sensitivity parameter value for the detector was determined, in the units of amps (A) per R/hr
(A/R/hr). The vendor established the sensitivity parameter value by testing three decades of
response and averaging them. This established the linear and consistent response on the
detector side of the calibration. In this case, the vendor provided an average value of
6.8 E-11 A/R/hr with a tolerance of +/- 10 percent (%), as a requirement, to maintain a
successful calibration check of the system. Moreover, for accident high range radiation
monitors, NUREG 0737, Clarification of TMI Action Plan requirements, describes a
calibration variance for not checking the entire detector range using radiation. This means
that the sensitivity parameter check plays a more important role in the detector calibration.
There is only one radiation level measurement made and this is the only indication of how the
detector will respond on the higher radiological ranges that are not being checked within the
licensees calibration process. The sensitivity parameter check verifies that the current output
on any range of the instrument between calibrations is displayed within a reasonable
tolerance of the actual radiological conditions. This allows the control room operators to make
an acceptable determination of actions during/post an accident.
This sensitivity parameter was introduced to the licensee's calibration program and process
by the corrective actions for a Notice of Violation (NOV) accompanying Inspection Report 05000416/2017012, which the licensee received from the NRC by letter dated August 22,
2017 (ADAMS Accession No. ML17235B265). The licensee added the sensitivity parameter
check to the calibration procedure as a corrective action of the 2017 violation since it was
required by the vendor manual for a successful calibration. Since implementation of this
sensitivity parameter to calibration procedure 06-IC-1D21-R-1002, Containment/Drywell High
Range Area Radiation Monitor Calibration, the licensee has not been able to successfully
determine the detector sensitivity parameter within the vendors stated tolerance. The
licensee has initiated condition reports (CRs), for tracking purposes, when the sensitivity
failed to be within required tolerance, but the CR evaluations consistently conclude that the
sensitivity parameter tolerance is not a technical specification acceptance criterion; therefore,
the calibrations were completed without meeting the tolerance or completion of Section 5.89
of calibration procedure 06-IC-1D21-R-1002. The calibration procedure states that completion
of the procedure is a successful performance of the calibration surveillance. However, the
NRC asserts that the calibration procedure is inadequate and/or incomplete because the
results conflict with the acceptance criterion.
In addition, the licensee conducted operability evaluations for these drywell and containment
high range radiation monitors and concluded that the calibration procedure was inadequate.
Specifically, the licensee determined these sensitivity values cannot be collected adequately
without factoring background radiation/current into the calculation. The licensee also
concluded that an additional step in the procedure related to collecting background data was
needed. The licensee stated to the NRC that they agree the calibration procedure was
inadequate relative to the way in which they handle the sensitivity parameter value. However,
4
the licensee maintained that the radiation monitors were properly calibrated based on
meeting the radiation source check tolerance of +/- 36%, as described in Section 5.87,
Radiation Calibration, of their calibration procedure 06-IC-1D21-R-1002.
The licensee is committed to perform calibration of the drywell and containment high range
radiation monitors in accordance with NUREG-0737, and in compliance with the vendor
manual. Per NUREG-0737, the licensee must complete a special calibration for at least one
decade below 10 R/hr. In this case, the licensees radiation source check, involves exposing
the detector to a known radiation source, at approximately 4.5 rem per hour (R/hr), that
verifies the radiation detector is within tolerance, and thus, adequately calibrated. The
inspectors identified that the radiation source check tolerance of +/- 36%, as established by
the licensee from the vendor manual, is inappropriate because the tolerance of +/- 36% is
applicable to the overall system accuracy of the detector (i.e., across a wide range of
radiation intensity and radiation energy) and is not applicable for a single point reading on the
lowest decade as performed with the radiation source check. Based on ANSI N320-1978, as
the licensee commits to, the radiation system calibration shall be within +/- 40%, and +/- 15%
precision for any single sample. The calibration data provided by the licensee, and reviewed
by the NRC, demonstrates a single point error as high as +/- 33% for three of the four (A, B,
and D) drywell/containment high range area radiation monitors, and would significantly
challenge meeting the overall system accuracy of +/- 36% when factoring in other system
losses and errors across the other seven decade readings required for a successful
calibration. In fact, during the NRCs communication with the licensee and vendor, the vendor
stated that based on the available data, the overall system accuracy was likely greater than
+/- 40% for these detectors. The NRC requested the licensee assess the system accuracy of
their containment and drywell radiation monitoring systems for confirmation.
It is noteworthy that following issuance of the 2017 NOV, the licensee used their corrective
action process, in part, to respond to this violation. In condition report CR-GGN-2017-06876,
the licensee documented a validation of the calibration of containment area radiation monitors
(B and C) and stated the following, Based on the calibration sheets, the installed monitors
were exposed to a field of 4.95 R/hr. In both cases, the associated control room monitors
indicated 4 R/hr. This is within 20% [19.2%] of the actual field, and therefore acceptable. The
total stated accuracy of the instrument loop (detector, monitor, and indicator) is +/-36% of the
input radiation per vendor manual 460000136. This verifies that the Containment Area
Radiation Monitors are capable of detecting and measuring the radiation level within the
reactor containment during and following an accident with sufficient accuracy to provide
usable information, as per NUREG-0737. This statement shows that the licensee understood
the acceptance criteria and acceptable tolerances for the radiation source check and system
loop accuracy for a successful calibration. This data was used to satisfy the NRCs concern in
2017 in its determination that the calibrations of these monitors were successful, within
tolerance, and operable. As of the date of this report, the inspectors were not able to
determine if the calibrations were successful based on the data provided to the NRC at the
time of our inspection.
Specifically, inspectors reviewed procedure 06-IC-1D21-R-1002, revision 113, in which
Step 5.87.5 instructs the licensee to record the As Found meter and recorder readings.
These are the readings used for the radiation calibration for the detectors. It further instructs
the licensee to immediately notify the supervisor if the As Found values are not within
tolerance, but unfortunately, the tolerance is inappropriately documented as +/- 36%, which
as stated above, does not comply with the vendor manual requirements or applicable ANSI
5
standards. Thus, the licensee consistently and inappropriately considered this calibration
verification as successful, due to meeting the documented tolerance.
In response to these errors, the inspectors requested that the licensee demonstrates to the
NRC that the overall system accuracy meets the tolerance of +/- 36% from the vendor or the
+/- 40% from the ANSI standard, which would comply with the vendor manual requirements.
As of the end of the inspection, NRC had not received this information for the drywell and
containment high range area radiation monitors.
A successful calibration is required to ensure the radiation detectors are operable, and thus,
able to both timely and accurately inform the licensee of in-situ radiological conditions during
and post an accident. These radiological readings are then used to make determinations for
various emergency response action levels (EALs), in accordance with the licensees EAL
Technical Bases Emergency Plan.
The licensee responded to questions provided by the inspectors focused on understanding
the effects of the errors on EAL classification and dose assessment capabilities. Based on
review of the evaluations and supplemental information provided by the licensee, including
the licensees Emergency Plan Table F-1, Fission Product Barrier Threshold Matrix, the
inspectors determined:
For detectors A/D: the two drywell detectors would be used to classify up to an
Unusual Event or Alert classification
For detectors B/C: the two primary containment area radiation monitors would be
used to classify up to a Site Area Emergency (SAE)
For detectors A/B/C/D: all four detectors are used to classify up to a General
Emergency (GE)
The primary concern on the EAL classification impacts is that the licensee has not
demonstrated that they would be able to timely and accurately classify a GE in cases where
they could have at least 20% fuel clad damage, but with reactor vessel levels remaining
greater than the reactor pressure vessel (RPV) levels that trigger other EAL fission product
barrier criteria. In the document Grand Gulf Nuclear Station EAL Technical Bases,
Table F-1 (revision 1), it states that there is a fuel clad barrier loss and a containment
barrier potential loss when site Severe Accident Procedures (SAPs) are entered.
Procedure 05-S-01-EP-2, RPV Control, revision 3, indicates that SAPs are entered when
RPV level cannot be maintained above -191 inches. In cases where the RPV level remains
above -191 inches and significant fuel clad damage exists, the licensee hasnt demonstrated
that there are other EAL criteria that could be credited to compensate for not having the
capability to classify the GE based on containment radiation monitor readings at the timing
expected for EAL FG1, i.e., earlier than would otherwise occur from other EALs in the
approved EAL scheme.
Based on NRC's review of Table 5.4-1 of the licensees EAL Technical Bases Emergency
Plan, although the licensee may enter their SAP due to factors such as the RPV water level
hitting its threshold for a SAE, the inability to use their radiation monitors to indicate actual
radiation levels in the release pathway provides a degraded aspect of their ability to timely
and accurately classify a GE. This has a direct impact on offsite response organizations being
able to effectively implement protective action strategies to protect the public. While entry into
6
the SAP due to the RPV water level is a mitigating factor, for the purpose of significance per
IMC 0609, Appendix B, the accuracy and timeliness of EAL classifications, and the required
protective action recommendation, are considered degraded and not lost.
Corrective Actions: The licensee performed an operability evaluation, as documented in
CR-GGN-2022-10690, supplemented by CR-GGN-2022-11351, which states that, The
conditions identified in CR-2022-2940 for detector 1D21N048D and CR-2022-3094 for
detector 1D21N048D did not meet detector sensitivity criteria provided in procedure. In both
cases, the instruments passed their loop calibrations checks providing reasonable assurance
of operability. The licensee informed the inspectors that they are conducting an uncertainty
analysis, which will be used in their response to this violation, and as available, will be
evaluated by the NRC.
Corrective Action References: CR-GGN-2022-10690
Performance Assessment:
Performance Deficiency: The licensee failed to perform a calibration in accordance with NRC
requirements of 10 CFR 20.1501(c). The licensee then failed to declare these radiation
monitors (1D21K648A, 1D21K648B, 1D21K648C, and 1D21K648D) inoperable in
accordance with their technical specification requirements (TS 3.3.3.1 and TS 3.0.1) and
perform the associated limiting condition for operation (LCO) action. Inoperable radiation
monitors would be unable to perform their intended function for Emergency Preparedness
actions in accordance with 10 CFR 50.54(q)(2).
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Facilities and Equipment attribute of the Emergency
Preparedness cornerstone and adversely 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 finding was more than
minor because it was associated with equipment needed (i.e., the drywell and containment
high range radiation monitors) for EAL determinations, which is considered a risk-significant
planning standard (RSPS) (i.e., 10 CFR 50.47(b)(4)) and adversely affected the Emergency
Preparedness cornerstone objective to ensure that the performance expectation of
reasonable assurance exists so that the licensee can effectively implement the approved
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix B, Emergency Preparedness SDP. Using Attachment 2 to IMC 0609, Appendix B,
the finding is a failure to comply with RSPSs. Based on Table 5.4-1 of the licensees
Emergency Plan, the inspectors determined that an EAL has been rendered ineffective such
that any GE would not be declared for a particular off-normal event, but because of other
EALs, an appropriate declaration could be made in a degraded manner (i.e., delayed). Since
the GE classification would most likely be made at some point by entering the licensees
SAP, the finding is not a loss of RSPS function but rather a degraded RSPS function when
the staff considers all relevant mitigating factors. Thus, entry into the SAP has not been
determined as both timely and accurate in all accident scenarios. Moreover, the actual
containment and drywell high range monitor calibration data reviewed by inspectors for the
radiation source check readout on the meter face and control room panels seem to
consistently under-respond to radiation.
7
Thus, inoperable drywell and primary containment high range area radiation monitors
affects the licensees ability to make both timely and accurate EAL classifications per the
licensees Emergency Plan. Therefore, the violation is preliminary determined as a finding of
WHITE significance.
Cross-Cutting Aspect: H.9 - Training: The organization provides training and ensures
knowledge transfer to maintain a knowledgeable, technically competent workforce and instill
nuclear safety values. Specifically, since at least 2017, the licensee has not demonstrated
that their staff performing the calibration verifications of these radiation monitors has the
technical knowledge to understand the full breadth of meeting acceptance criteria and
requirements established for a successful calibration. Furthermore, their surveillance
requirement 3.0.1 states, in part, that a failure to meet a surveillance is a failure to meet the
LCO. NRC staff has engaged with the licensee multiple times to discuss these calibration
aspects and establish a common understanding that the calibration data reviewed does not
support these radiation monitors as being calibrated, and thus, they are not operable.
Enforcement:
Violation:
Apparent Violation #1: 10 CFR 20.1501(c) - Failure to calibrate the drywell and containment
high range area radiation monitors
Title 10 CFR 20.1501(c) requires that the licensee shall ensure that instruments and
equipment used for quantitative radiation measurements (e.g., dose rate and effluent
monitoring) are calibrated periodically for the radiation measured.
Contrary to the above, from September 2019 to April 5, 2023, the licensee failed to ensure
that instruments and equipment used for quantitative radiation measurements (e.g., dose rate
and effluent monitoring) were calibrated periodically for the radiation measured. Specifically,
the licensee failed to adequately calibrate and maintain the drywell and containment high
range area radiation monitors in accordance with industry and vendor standards, as
committed to, for a successful calibration.
Apparent Violation #2: 10 CFR 50.54(q)(2) - Failure to follow and maintain the effectiveness
of an emergency plan and standards of 10 CFR 50.47(b)(4)
Title 10 CFR 50.54(q)(2) requires, in part, that a holder of a license under 10 CFR Part 50
shall follow and maintain the effectiveness of an emergency plan that meets the requirements
in 10 CFR Part 50, Appendix E, and the planning standards of 10 CFR 50.47(b).
Title 10 CFR 50.47(b)(4) requires, in part, that a standard emergency classification and action
level scheme is in use by the nuclear facility licensee, and State and local response plans call
for reliance on information provided by facility licensees for determinations of minimum initial
offsite response measures.
Contrary to the above, from September 2019 to April 5, 2023, the licensee failed to follow and
maintain the effectiveness of an emergency plan which met the requirements in
10 CFR Part 50 Appendix E and the planning standards of 10 CFR 50.47(b). Specifically, the
licensee failed to maintain a standard emergency classification scheme as required by
10 CFR 50.47(b)(4) as a result of calibration errors for drywell and containment area radiation
monitors used for making General Emergency (GE) classifications. These calibration errors
8
failed to provide reasonable assurance that the monitors will remain operable and provide
timely and accurate radiological information to the licensee during accident conditions.
Apparent Violation #3: TS 3.3.3.1 LCO Action - Failure to maintain the drywell and
containment high range area radiation monitors operable and initiate action to prepare and
submit a Special Report to the NRC immediately
Technical Specification (TS) 3.3.3.1 requires, in part, that the post-accident monitoring (PAM)
instrumentation for each function in Table 3.3.3.1-1 shall be operable. Condition C requires,
in part, that with one or more functions with two required channels inoperable, restore one
required channel to operable status with 7 days. Condition D requires, in part, that with the
required action and associated completion time of Condition C not met, enter the Condition
referenced in Table 3.3.3.1-1 for the channel immediately. Table 3.3.3.1-1 Function 12,
Primary Containment Area Radiation, and Function 13, Drywell Area Radiation, reference
Condition F. Condition F requires, in part, that as required by required action D.1 and
referenced in Table 3.3.3.1-1, initiate action to prepare and submit a Special Report
immediately.
Contrary to the above, on December 23, 2022, the licensee failed to initiate an action to
prepare and submit a Special Report after 7 days had elapsed with two required PAM
instrumentation channels inoperable. Specifically, on December 16, 2022, NRC inspectors
reviewed the radiation source check data and sensitivity parameter data for each of the
drywell and containment high range monitors (detectors) during the calibration surveillance in
accordance with procedure 06-IC-1D21-R-1002 and identified the value for all four detectors
was outside of acceptable tolerances per industry acceptance criteria and standards, but the
licensee still declared them operable. As a result, the licensee failed to initiate the LCO
action.
Enforcement Action: These violations are being treated as apparent violations pending a final
significance (enforcement) determination.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On April 5, 2023, the inspectors presented the preliminary White significance inspection
results to Brad Kapellas, Site Vice President, and other members of the licensee staff.
9
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71124.05 Corrective Action CR-GGN-YYYY- 2017-00612, 2017-06876, 2022-02940, 2022-03094, 2022-
Documents XXXXX 10690, 2022-11351
71124.05 Miscellaneous Assessment of Calibration Status for Grand Gulf High Range 02/28/2023
Area Monitors
71124.05 Miscellaneous Grand Gulf Emergency Preparedness (EP) Position Paper 12/20/2022
22-01: All Channels of Containment and Drywell Radiation
Monitoring declared INOPERABLE
71124.05 Miscellaneous NRC Questions and Responses from EP Position Paper 22- 01/17/2023
01
71124.05 Miscellaneous GG Responses to NRC Questions on Operability Evaluation 01/17/2023
71124.05 Miscellaneous Licensee Response to Questions from the 12/02/22 RP 12/15/2022
Inspection Status Update Call
71124.05 Miscellaneous 460000136 Victoreen Radiation Monitors Vendor Manual 08/08/1995
71124.05 Miscellaneous 877-1-1 Fluke Biomedical Victoreen 875 High Range Containment 05/2021
Monitor Operators Manual
71124.05 Miscellaneous GIN 2021-00062 Grand Gulf Nuclear Station EAL Technical Basis - 1
71124.05 Miscellaneous ML15127A549 GRAND GULF NUCLEAR STATION - NRC INTEGRATED 05/12/2015
INSPECTION REPORT 05000416/2015001
71124.05 Miscellaneous ML17235B265 GRAND GULF NUCLEAR STATION - NRC RADIATION 08/22/2017
PROTECTION INSPECTION REPORT 05000416/2017012
AND NOTICE OF VIOLATION
71124.05 Operability CR-GGN-2022- Operability Evaluation of Containment/Drywell High Range 11/22/2022
Evaluations 10690 Radiation Monitors - Sensitivity Check
71124.05 Operability CR-GGN-2022- Operability Evaluation of Containment/Drywell High Range 12/19/2022
Evaluations 11351 Radiation Monitors - Sensitivity Check
71124.05 Procedures 06-IC-1D21-R- Containment/Drywell High Range Area Radiation Monitor 113
1002 Calibration
71124.05 Procedures EN-OP-104 Operability Determination Process 17
05-S-01-EP-2 RPV Control 3
71124.05 Work Orders WO 00542468-01 1D21N048A: Replace In-Drywell Radiation Detector 03/17/2022
10
Inspection Type Designation Description or Title Revision or
Procedure Date
71124.05 Work Orders WO 00542472-01 1D21N048D: Replace In-Drywell Radiation Detector 03/18/2022
71124.05 Work Orders WO 52782236-01 06IC1D21-R-1002-03 Channel B (Containment) Calibration 09/05/2019
Record
71124.05 Work Orders WO 52782237-01 06IC1D21-R-1002-03 Channel C (Containment) Calibration 10/30/2019
Record
71124.05 Work Orders WO 52842051-01 06IC1D21-R-1002-03 Channel A (Drywell) Calibration 04/05/2020
Record
71124.05 Work Orders WO 52842512-01 06IC1D21-R-1002-03 Channel D (Drywell) Calibration 04/05/2020
Record
71124.05 Work Orders WO 52900509-01 06IC1D21-R-1002-03 Channel B (Containment) Calibration 09/02/2021
Record
71124.05 Work Orders WO 52906611-01 06IC1D21-R-1002-03 Channel C (Containment) Calibration 06/24/2021
Record
11