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| number = ML17235B265
| number = ML17235B265
| issue date = 08/22/2017
| issue date = 08/22/2017
| title = Grand Gulf - NRC Radiation Protection Inspection Report 05000416/2017012 and Notice of Violation
| title = NRC Radiation Protection Inspection Report 05000416/2017012 and Notice of Violation
| author name = Gepford H J
| author name = Gepford H
| author affiliation = NRC/RGN-IV/DRS/PSB-1
| author affiliation = NRC/RGN-IV/DRS/PSB-1
| addressee name = Larson E
| addressee name = Larson E
Line 14: Line 14:
| page count = 36
| page count = 36
}}
}}
See also: [[followed by::IR 05000416/2017012]]
See also: [[see also::IR 05000416/2017012]]


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:August 22, 2017
[[Issue date::August 22, 2017]]
Mr. Eric Larson, Site Vice President
Entergy Operations, Inc.
Grand Gulf Nuclear Station
P.O. Box 756
Port Gibson, MS 39150
SUBJECT: GRAND GULF NUCLEAR STATION - NRC RADIATION PROTECTION
INSPECTION REPORT 05000416/2017012 AND NOTICE OF VIOLATION
Dear Mr. Larson:  
On July 14, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
the Grand Gulf Nuclear Station and discussed the results of this inspection with you and other
members of your staff.  The results of this inspection are documented in the enclosed report.
Based on the results of this inspection, the NRC has identified two issues that were evaluated
under the risk significance determination process as having very low safety significance
(Green).  The NRC also determined that one violation is associated with these issues. 
This violation was evaluated in accordance with the NRC Enforcement Policy.  The
current Enforcement Policy is included in the NRCs Web site at http://www.nrc.gov/about-
nrc/regulatory/enforcement/enforce-pol.html.  The violation is cited in the enclosed Notice of
Violation (Notice) and the circumstances surround it are described in detail in the subject
inspection report.  The violation is being cited because this violation did not meet the criteria to
be treated as a non-cited violation because the licensee failed to restore compliance within a
reasonable period of time after it was identified.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response.  If you have additional information that you
believe the NRC should consider, you may provide it in your response to the Notice.  The NRC
review of your response will also determine whether further enforcement action is necessary to
ensure your compliance with regulatory requirements.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a
regulatory requirement 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.
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 E. LAMAR BLVD
ARLINGTON, TX 76011-4511


Mr. Eric Larson, Site Vice President Entergy Operations, Inc.
E. Larson  
2
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter will be
made available for public inspection in the NRC Public Document Room from the NRCs Agency
wide Documents Access and Management System (ADAMS), accessible from the NRC Web
site at http://www.nrc.gov/reading-rm/adams.html.  To the extent possible, your response should
not include any personal, privacy, or proprietary information so that it can be made available to
the public without redaction.
Sincerely,
/RA/
Heather J. Gepford, Ph.D., CHP, Branch Chief
Plant Support Branch 1 
Division of Reactor Safety 
Docket No. 50-416
License No. NPF-29
Enclosure:
Inspection Report 05000416/2017012 
w/Attachments: 
1. Supplemental Information
2. Request for Information 


Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150


SUBJECT: GRAND GULF NUCLEAR STATION - NRC RADIATION PROTECTION INSPECTION REPORT 05000416/2017012 AND NOTICE OF VIOLATION
ML17235B265 
SUNSI Review 
ADAMS:  
Non-Publicly Available
Non-Sensitive
Keyword: 
By:  HGepford
Yes    No
Publicly Available
Sensitive 
NRC-002
OFFICE
SHP:PSB2
HP:PSB2
HP:PSB2
SHP:RIII
C:PSB2
C:PSB2
NAME
LCarson
NGreene
JODonnell
TGo
HGepford
JKozal
SIGNATURE
/RA/
/RA/
/RA/
/RA/
/RA/
/RA/
DATE
8/17/17
8/17/17
8/17/17
8/17/17
8/17/17
8/22/17
OFFICE
ACES
C:PSB2
NAME
MHay
HGepford
SIGNATURE
/RA/
/RA/
DATE
8/22/17
8/22/17


==Dear Mr. Larson:==
On July 14, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Grand Gulf Nuclear Station and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket:
05000416
Report:
05000416/2017012
Facility:
Grand Gulf Nuclear Station
Dates:  
July 10 through July 14, 2017  
Inspectors:
L. Carson II, Sr. Health Physicist
N. Greene, PhD, Health Physicist
J. ODonnell, CHP, Health Physicist
T. Go, Health Physicist (RIII)  
Accompanied by S. Money, Health Physicist
Approved By:
Heather Gepford, PhD, CHP
Chief, Plant Support Branch 2
Division of Reactor Safety


Based on the results of this inspection, the NRC has identified two issues that were evaluated under the risk significance determination process as having very low safety significance (Green). The NRC also determined that one violation is associated with these issues.
2
NOTICE OF VIOLATION
Entergy Operations, Inc.
Docket No. 05000416 
Grand Gulf Nuclear Station 
License No. NPF-29
During an NRC inspection conducted from July 10-14, 2017, a violation of NRC requirements
was identified.  In accordance with the NRC Enforcement Policy, the violation is listed below: 
10 CFR 20.1501(c) requires, in part, that the licensee shall ensure that instruments and
equipment used for quantitative radiation measurements are calibrated periodically for
the radiation measured. 
Contrary to the above, since January 1, 2012, the licensee failed to ensure that  
instruments and equipment used for quantitative radiation measurements were  
calibrated periodically for the radiation measured.  Specifically, the licensee failed to
properly calibrate the containment/drywell high range radiation monitors and the main
steam line radiation monitors using industry accepted calibration methods and
tolerances. 
This violation is associated with a Green SDP finding.
Pursuant to the provisions of 10 CFR 2.201, Entergy Operations, Inc., is hereby required to
submit a written statement or explanation to the U.S. Nuclear Regulatory Commission,
ATTN:  Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional
Administrator, Region IV, 1600 E. Lamar Blvd., Arlington, TX 76011, and a copy to the NRC
Resident Inspector at the Grand Gulf Nuclear Station, within 30 days of the date of the letter
transmitting this Notice of Violation (Notice).  This reply should be clearly marked as a "Reply to
a Notice of Violation" and should include for the violation:  (1) the reason for the violation or, if
contested, the basis for disputing the violation or severity level, (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
previous docketed correspondence if the correspondence adequately addresses the required
response.  If an adequate reply is not received within the time specified in this Notice, an order
or a Demand for Information may be issued as to why the license should not be modified,
suspended, or revoked, or why such other action as may be proper should not be taken.  Where
good cause is shown, consideration will be given to extending the response time. 
If you contest this enforcement action, you should also provide a copy of your response with the
basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory
Commission, Washington, DC 20555-0001. 
Because your response will be made available electronically for public inspection in the
NRC Public Document Room or from the NRCs document system (ADAMS), accessible from
the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should
not include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction.  If personal privacy or proprietary information is  
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of your
response that deletes such information. If you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in


This violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included in the NRC's Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surround it are described in detail in the subject inspection report. The violation is being cited because this violation did not meet the criteria to be treated as a non-cited violation because the licensee failed to restore compliance within a reasonable period of time after it was identified.
3
detail the bases for your claim of withholding (e.g., explain why the disclosure of information will
create an unwarranted invasion of personal privacy or provide the information required by
10 CFR 2.390(b) to support a request for withholding confidential commercial or financial
information). If Safeguards Information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21. 
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days of receipt.
Dated this 22nd day of August 2017


You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response will also determine whether further enforcement action is necessary to ensure your compliance with regulatory requirements.
4
SUMMARY
IR 05000416/2017012; 07/10/2017 - 07/14/2017; Grand Gulf Nuclear Station; Radiation
Monitoring Instrumentation (71124.05), Radioactive Gaseous and Liquid Effluent Treatment
(71124.06)
Cornerstone:  Public Radiation Safety
*
Green.  The inspectors identified a violation of 10 CFR 20.1501(c) for the failure
to properly calibrate installed radiation monitors using industry accepted calibration
methods and tolerances.  Specifically, since January 2012, the licensee failed to  
properly calibrate the following radiation monitors:  main steam line, containment
high range, and the drywell high range.  This violation was originally entered into
the licensees corrective action program in March 2015 as Condition 
Report CR-GGNS-2015-01832.  However, in 2017, inspectors determined that
subsequent to 2015, the licensee failed to implement corrective actions to properly
calibrate the instruments. The licensee entered this repetitive issue into their corrective
action process as Condition Report CR-GGN-2017-06826.
The failure to properly calibrate radiation monitors is a performance deficiency.  The
performance deficiency is more than minor because it is associated with the cornerstone
attribute of plant instrumentation and adversely affects the cornerstone objective to
ensure adequate protection of employee health and safety during routine civilian nuclear
reactor operation and is therefore a finding.  Specifically, the failure to properly calibrate
radiation monitors impacts the licensees ability to assess dose rates.  Using Inspection
Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance
Determination Process, dated August 19, 2008, the inspectors determined the finding to
be of very low safety significance because it was not an as low as reasonably achievable
(ALARA) issue, there was no overexposure or substantial potential for overexposure,
and the licensees ability to assess dose was not compromised.  This finding has a
cross-cutting aspect in the resources component of the Problem Identification and
Resolution area because the licensee did not ensure that effective corrective actions
were implemented to address issues in a timely manner commensurate with the safety
significance [P.3].  (Section 2RS5)
*
Green.  The inspectors identified a finding associated with the licensees failure to
operate the gaseous radwaste system within design specifications.  These deficiencies
in design specifications were associated with the off gas charcoal adsorber and vault
refrigeration components of the gaseous radwaste system, which has impacted the
systems reliability and efficiency since at least 2007.  The design parameters for
offgas flow rate into the charcoal adsorbers and vault refrigeration temperature were
30 scfm and 0 degrees Fahrenheit, respectively.  In contrast, the gaseous radwaste
system is being operated with an approximate flow rate is 80 scfm and vault refrigeration
temperature is 15 degrees Fahrenheit.  The licensee has developed a system
improvement plan to address resolution of these issues during the next scheduled
outages.  This performance deficiency was entered into the licensees corrective action
program as  Condition Report CR-GGN-2017-06875.  


If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be made available for public inspection in the NRC Public Document Room from the NRC's Agency wide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal, privacy, or proprietary information so that it can be made available to the public without redaction.
5
The failure to operate the offgas gaseous radwaste system within design specifications,
resulting in elevated radiological effluent releases, is a performance deficiency.  The
finding is more than minor because it is associated with the plant equipment attribute of  
the Public Radiation Safety cornerstone and adversely affected the cornerstone
objective to ensure adequate protection of public health and safety from exposure of
radioactive materials released into the public domain as a result of routine civilian
nuclear plant operation. Using Inspection Manual Chapter 0609, Appendix D, Public
Radiation Safety Significance Determination Process, the finding was determined to be
of very low safety significance (Green) because it involved the Effluent Release
Program, it did not impair the ability to assess dose, and did not exceed the
10 CFR Part 50, Appendix I, or 10 CFR 20.1301(d) limits. The finding has a
cross-cutting aspect in the area of problem identification and resolution, associated with
the resolution component, because the licensee failed to take effective corrective actions
in a timely manner to minimize the unreliability and inefficiency of the gaseous radwaste
system [P.3]. (Section 2RS6) 


Sincerely,/RA/
Heather J. Gepford, Ph.D., CHP, Branch Chief Plant Support Branch 1 Division of Reactor Safety Docket No. 50-416 License No. NPF-29
6
REPORT DETAILS
2.
RADIATION SAFETY
Cornerstones:  Public Radiation Safety and Occupational Radiation Safety
2RS5 Radiation Monitoring Instrumentation (71124.05)
a.
Inspection Scope
The inspectors evaluated the accuracy and operability of the radiation monitoring
equipment used by the licensee to monitor areas, materials, and workers to ensure a
radiologically safe work environment. This evaluation included equipment used to
monitor radiological conditions related to normal plant operations, anticipated operational
occurrences, and conditions resulting from postulated accidents. The inspectors
interviewed licensee personnel, walked down various portions of the plant, and reviewed
licensee performance associated with radiation monitoring instrumentation, as described
below: 
*
The inspectors performed walk downs and observations of selected plant
radiation monitoring equipment and instrumentation, including portable survey
instruments, area radiation monitors, continuous air monitors, personnel
contamination monitors, portal monitors, and small article monitors. The
inspectors assessed material condition and operability, evaluated positioning of
instruments relative to the radiation sources or areas they were intended to
monitor, and verified performance of source checks and calibrations.
*
The inspectors evaluated the calibration and testing program, including
laboratory instrumentation, whole body counters, post-accident monitoring
instrumentation, portal monitors, personnel contamination monitors, small article
monitors, portable survey instruments, area radiation monitors, electronic
dosimetry, air samplers, and continuous air monitors.
*
The inspectors assessed problem identification and resolution for radiation
monitoring instrumentation. The inspectors reviewed audits, self-assessments,
and corrective action program documents to verify problems were being
identified and properly addressed for resolution.
These activities constitute completion of the three required samples of radiation
monitoring instrumentation, as defined in Inspection Procedure 71124.05.
b.
Findings
Introduction.  The inspectors identified a violation of 10 CFR 20.1501(c) for the failure to
properly calibrate installed radiation monitors using industry accepted calibration
methods and tolerances.  Specifically, the main steam line, containment high range, and
drywell high range radiation monitors have not been properly calibrated since at least
January 2012. This violation was originally entered into the licensees corrective action
program in March 2015 as Condition Report CR-GGNS-2015-01832.  However, in 2017,
inspectors determined that the licensee failed to implement appropriate corrective


===Enclosure:===
Inspection Report 05000416/2017012
7
actions to properly calibrate the instruments.  The licensee entered this repetitive issue
into their corrective action process as Condition Report CR-GGN-2017-06826.
Description.  The failure to properly calibrate the main steam line and
containment/drywell high range area radiation monitors was previously identified
and documented as a non-cited violation during an inspection in March of 2015:
NCV 05000416/2015001-04, Failure to Properly Calibrate Main Steam Line Radiation
Monitors and Containment/Drywall High Range Radiation Monitors. 
During this inspection, the inspectors reviewed the revised calibration procedures and
calibration data for main steam line, containment high range, and drywell high range
radiation monitors.  The main steam line radiation monitors provide reactor operators
with early indication of gross release of fission products from the fuel.  This monitor has
an automatic response function that isolates the reactor water sample line to limit the
release of radioactive materials.  The containment high range and drywell high radiation
monitors provide reactor operators and emergency response organization members
information about the radiological conditions inside the containment building and the
drywell.  This information is used to make informed decisions about what actions to take
during an accident as well as make emergency declarations.  As such, it is important
that these radiation monitors be properly calibrated.  However, it was determined that
the improper calibrations did not adversely affect the licensees ability to implement the
Emergency Plan.
Based on their review of the current revisions of the applicable procedures, corrective
action documents, and calibration data, the inspectors determined that the licensee had
not corrected the calibration method from the previous non-cited violation.  The licensee
procedures did not address the required reproducible source-to-detector geometry or the
characterization of the calibration sources used.  Additionally, because the main steam
line monitor calibration requires two different sources in the procedure, each source
should have been characterized in a reproducible geometry. 
The licensee revised Procedure 06-IC-1D17-R-1002, Main Steam Line High Radiation
Monitor (PCIS) Calibration, Revision 109, on April 3, 2017.  The previous revision (108)
was dated December 13, 2011.  Section 5.37 of this procedure describes the radiation
calibration method.  The calibration method, as described in this section, fails to employ
a reproducible geometry or calibrated radiation sources.  Further, the calibration method,
as described in this section, only addresses calibration of two of the six decades of the
logarithmic monitor. 
The licensee also revised Procedure 06-IC-1D21-R-1002, Containment/Drywell High
Range Area Radiation Monitor Calibration, Revision 108, on April 3, 2017.  The
previous revision (107) was dated September 12, 2011.  Section 5.87 describes the
radiation functional test portion of this procedure.  The calibration method described in
this section fails to employ a reproducible geometry or a calibrated radiation source. 
Further, the acceptance criteria in this section are twice that allowed in American
National Standards Institute (ANSI) N323D-2002, American National Standard for
Installed Radiation Protection Instrumentation, approved on September 3, 2002.  In
addition, the electronic calibration method in this procedure as allowed by NUREG 0737,
Clarification of TMI Action Plan Requirements, dated November 1980, only addresses
calibration of three of the seven decades of the logarithmic monitor.


===w/Attachments:===
1. Supplemental Information 2. Request for Information
8
The inspectors concluded that the licensee had continued to improperly calibrate
these process radiation monitors since the previous inspection in March 2015. 
Procedure 06-IC-1D17-R-1002 rocedure is used for all four channels of the main
steam line monitors and Procedure 06-IC-1D21-R-1002 is used for both channels of
the drywell and containment high range radiation monitors.  Because both procedures
failed to use appropriate calibration methodologies, the inspectors determined that
none of the containment/drywell high range and main steam line radiation monitors
had been properly calibrated since at least the date of the procedure revisions,
September 12, 2011, and December 13, 2011, respectively. 
In evaluating the underlying cause of the licensees failure to correct the calibration
issue, the inspectors noted the following.  On January 20, 2017, a corrective action
document (CR-GGN-2017-00612) was initiated identifying a non-conforming condition of
a Condition Adverse to Quality that the calibration procedure for the containment high
range and drywell high radiation monitors does not control the source geometry to the
monitor.  The CR further described the required calibration traceability not being
maintained. In the self-assessment report of the radiation protection instrument program 
(OL-GLO-2017-21) completed on May 23, 2017, the assessment team rated Objective 2,
the review of the prior inspection report, as unsatisfactory.  This rating was given
because actions related to this issue were not complete after a considerable amount of
time, which included at least five due date extensions and an extended outage that
should have allowed completion of the corrective action. 
Analysis.  The failure to properly calibrate radiation monitors is a performance
deficiency.  The performance deficiency is more than minor because it is associated with
the cornerstone attribute of plant instrumentation and adversely affects the cornerstone
objective to ensure adequate protection of employee health and safety during routine
civilian nuclear reactor operation and is therefore a finding.  Specifically, the failure to
properly calibrate radiation monitors impacts the licensees ability to assess dose rates. 
Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety
Significance Determination Process, dated August 19, 2008, the inspectors determined
the finding to be of very low safety significance because it was not an as low as
reasonably achievable (ALARA) issue, there was no overexposure or substantial
potential for overexposure, and the licensees ability to assess dose was not
compromised.  This finding has a cross-cutting aspect in the area of problem
identification and resolution, associated with the resolution component, because the
licensee did not ensure that effective corrective actions were implemented to address
issues in a timely manner commensurate with the safety significance [P.3].
Enforcement.  Title 10 CFR 20.1501(c) requires, in part, that the licensee shall
ensure that instruments and equipment used for quantitative radiation measurements
are calibrated periodically for the radiation measured. Contrary to the above, since at
least January 1, 2012, the licensee failed to ensure that instruments and equipment
used for quantitative radiation measurements were calibrated periodically for the
radiation measured.  Specifically, the licensee failed to properly calibrate the
containment/drywell high range radiation monitors and the main steam line
radiation monitors using industry accepted calibration methods and tolerances. 
This issue was entered into the licensees corrective action program as Condition
Report CR-GGN-2017-06826.


=SUMMARY=
IR 05000416/2017012; 07/10/2017 - 07/14/2017; Grand Gulf Nuclear Station; Radiation Monitoring Instrumentation (71124.05), Radioactive Gaseous and Liquid Effluent Treatment (71124.06)  
9
This issue was previously identified during an inspection in March of 2015, as
NCV 05000416/2015001-04 and was treated as a non-cited violation, consistent with
Section 2.3.2.a of the Enforcement Policy.  Since the licensee did not restore
compliance in a reasonable period of time, this violation is being cited, consistent with
the NRC Enforcement Policy, Section 2.3.2, which states, in part, that the licensee must
restore compliance within a reasonable period of time (i.e., in a timeframe
commensurate with the significance of the violation) after a violation is identified.  A
Notice of Violation is attached.  VIO 05000416/2017012-01, Failure to Properly
Calibrate Installed Radiation Monitors Using Industry Accepted Calibration Methods and
Tolerances.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)  
a.
Inspection Scope
The inspectors evaluated whether the licensee maintained gaseous and liquid effluent
processing systems and properly mitigated, monitored, and evaluated radiological
discharges with respect to public exposure.  The inspectors verified that abnormal
radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors
are out-of-service, were controlled in accordance with the applicable regulatory
requirements and licensee procedures.  The inspectors verified that the licensees
quality control program ensured radioactive effluent sampling and analysis adequately
quantified and evaluated discharges of radioactive materials.  The inspectors verified the
adequacy of public dose projections resulting from radioactive effluent discharges.  The
inspectors interviewed licensee personnel and reviewed licensee performance in the
following areas:
 
*
During walk downs and observations of selected portions of the radioactive
gaseous and liquid effluent equipment, the inspectors evaluated routine
processing and discharge of effluents, including sample collection and analysis. 
The inspectors observed equipment configuration and flow paths of selected
gaseous and liquid discharge system components, effluent monitoring systems,
filtered ventilation system material condition, and significant changes to effluent
release points.
*
Calibration and testing program for process and effluent monitors, including
National Institute of Standards and Technology traceability of sources, primary
and secondary calibration data, channel calibrations, set-point determination
bases, and surveillance test results. 
*
Sampling and analysis controls used to ensure representative sampling and
appropriate compensatory sampling.  Reviews included results of the inter-
laboratory comparison program, 
*
Instrumentation and equipment, including effluent flow measuring instruments, air
cleaning systems, and post-accident effluent monitoring instruments.
*
Dose calculations for effluent releases.  The inspectors reviewed a selection of
radioactive liquid and gaseous waste discharge permits and abnormal gaseous
or liquid tank discharges, and verified the projected doses were accurate.  The


===Cornerstone: Public Radiation Safety===
: '''Green.'''
The inspectors identified a violation of 10 CFR 20.1501(c) for the failure to properly calibrate installed radiation monitors using industry accepted calibration methods and tolerances. Specifically, since January 2012, the licensee failed to properly calibrate the following radiation monitors: main steam line, containment high range, and the drywell high range. This violation was originally entered into the licensee's corrective action program in March 2015 as Condition Report CR-GGNS-2015-01832. However, in 2017, inspectors determined that subsequent to 2015, the licensee failed to implement corrective actions to properly calibrate the instruments. The licensee entered this repetitive issue into their corrective action process as Condition Report CR-GGN-2017-06826.
10
inspectors also reviewed 10 CFR Part 61 analyses and methods used to
determine which isotopes were included in the source term.  The inspectors
reviewed land use census results, offsite dose calculation manual changes, and
significant changes in reported dose values from previous years.  
*
Problem identification and resolution for radioactive gaseous and liquid effluent
treatment.  The inspectors reviewed audits, self-assessments, and corrective
action program documents to verify problems were being identified and properly
addressed for resolution.
These activities constitute completion of the six required samples of radioactive gaseous
and liquid effluent treatment program, as defined in Inspection Procedure 71124.06. 
b.
Findings
Introduction. The inspectors identified a Green finding for the licensees failure to  
operate their gaseous radwaste system within design specifications, resulting in elevated
radiological effluent releases that were not as low as reasonably achievable.  These
deficiencies in meeting the design specifications/parameters are associated with the
offgas charcoal adsorber and vault refrigeration components of the offgas system, which
have impacted the systems reliability and efficiency since at least 2007.  
Description.  When reviewing the licensees annual effluent release reports, the
inspectors identified that in calendar year 2013, the licensee had total airborne releases
of fission and activation gases of 1920 curies (Ci), including a peak release of 1540 Ci
during the third quarter.  The inspectors noted that this annual gaseous release was
significantly higher than the previous annual releases of approximately 450 Ci in
calendar years 2010 thru 2012.  The licensee stated the primary reason for the elevated
activity of gaseous releases was associated with refrigeration equipment issues affecting
charcoal adsorption efficiency.  Upon further evaluation, NRC inspectors determined that
such issues with the charcoal adsorbers and vault refrigeration systems were long-term,  
ongoing, unresolved deficiencies in the gaseous radwaste system primarily due to  
numerous condenser in-leakages that remain unrepaired.   
   
The Grand Gulf Nuclear Station System Description, Revision 2, for the gaseous
radwaste system notes that there are two sets of four charcoal adsorber vessels
arranged in series, totaling eight charcoal adsorber beds. As the offgas flows from the
condenser system via the steam jet air ejectors into the charcoal adsorption system, the
charcoal acts as a medium to delay the flow of krypton and xenon gases to allow them to
decay to radiation levels acceptable for atmospheric release.  In addition, the activated
charcoal adsorbs the radioactive isotopes of iodine removing them for decay.  
The adsorption of xenon, krypton, and iodine offgas on charcoal depends on gas
flowrate, holdup time, mass of charcoal, and the dynamic adsorption coefficient.  The
inspectors determined the nominal flowrate for the licensees charcoal system to operate
efficiently is specified as 30 scfm, to achieve proper holdup times of offgases.  However,  
the licensee has been consistently running the system at 80 scfm.  
The Grand Gulf Nuclear Station System Description also states the charcoal adsorbers
must be operated under controlled temperature and humidity conditions, maintaining a
steady state temperature of about 0 degrees Fahrenheit (°F). However, for optimal


The failure to properly calibrate radiation monitors is a performance deficiency. The performance deficiency is more than minor because it is associated with the cornerstone attribute of plant instrumentation and adversely affects the cornerstone objective to ensure adequate protection of employee health and safety during routine civilian nuclear reactor operation and is therefore a finding. Specifically, the failure to properly calibrate radiation monitors impacts the licensee's ability to assess dose rates. Using Inspection Manual Chapter 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process," dated August 19, 2008, the inspectors determined the finding to be of very low safety significance because it was not an as low as reasonably achievable (ALARA) issue, there was no overexposure or substantial potential for overexposure, and the licensee's ability to assess dose was not compromised. This finding has a cross-cutting aspect in the resources component of the Problem Identification and Resolution area because the licensee did not ensure that effective corrective actions were implemented to address issues in a timely manner commensurate with the safety significance [P.3].  (Section 2RS5)
: '''Green.'''
The inspectors identified a finding associated with the licensee's failure to operate the gaseous radwaste system within design specifications. These deficiencies in design specifications were associated with the off gas charcoal adsorber and vault refrigeration components of the gaseous radwaste system, which has impacted the system's reliability and efficiency since at least 2007. The design parameters for offgas flow rate into the charcoal adsorbers and vault refrigeration temperature were 30 scfm and 0 degrees Fahrenheit, respectively. In contrast, the gaseous radwaste system is being operated with an approximate flow rate is 80 scfm and vault refrigeration temperature is 15 degrees Fahrenheit. The licensee has developed a system improvement plan to address resolution of these issues during the next scheduled outages. This performance deficiency was entered into the licensee's corrective action program as  Condition Report CR-GGN-2017-06875.
11
performance, a refrigeration temperature of 0 to -40°F is specified.  The inspectors
reviewed Figure 10 of Section 4.1.7 of Grand Gulf Nuclear Station System Description,
entitled Comparative Curie Decontamination Factors for 8, 12, and 16 Bed Systems,
which illustrated that the charcoal low temperature, eight bed system is designed to
operate at a decontamination factor of 1000 with the specified design parameters
(i.e., 30 scfm, 0ºF).  However, the inspectors determined licensees current offgas
flowrate of approximately 80 scfm and refrigeration temperature of approximately +15°F
will achieve a decontamination factor of less than 50.
The licensee performed evaluations, as documented in Apparent Cause
Evaluation CR-GGN-2013-0450, and determined that corrective actions were needed to
decrease the current elevated offgas flowrate into the charcoal adsorbers from
approximately 80 scfm, and to reduce the vault refrigeration temperature to within
design specifications.  The licensee implemented some corrective actions to reduce
condenser in-leakage, resulting in some improvement in the offgas flowrate (reduction
from ~160 scfm to ~80 scfm).  However, the offgas flowrates, charcoal adsorber
flowpath, and refrigeration vault operations still remain inconsistent with the design
specifications. 
Although these deficiencies were ongoing issues, the licensee provided no documented
evaluation to demonstrate that the degraded performance of the offgas system was
maintaining gaseous releases as low as reasonably achievable, which the Updated Final
Safety Analysis Report states is the primary design objective of the gaseous radwaste
management system.  The NRC inspectors discussed with the licensee that, although
the airborne releases may meet the 10 CFR Part 20, Appendix I, limitations, the failure  
to operate the system consistent with design parameters is significantly impacting the
systems ability to maintain gaseous releases as low as reasonably achievable, as
evidenced by the annual effluent reports.   
The licensee has developed a system improvement plan entitled, Offgas Long Range
Plan and Concluding Actions, to address how the plant may resolve the issues within
the next few scheduled outages.  This performance deficiency was entered into the
licensees CAP as Condition Report CR-GGN-2017-06875.  
Analysis.  The failure to operate the offgas gaseous radwaste system within design
specifications, resulting in elevated radiological effluent releases, is a performance  
deficiency.  The finding is more than minor because it is associated with the plant
equipment attribute of the Public Radiation Safety cornerstone and adversely affected
the cornerstone objective to ensure adequate protection of public health and safety from
exposure of radioactive materials released into the public domain as a result of routine  
civilian nuclear plant operation. Using Inspection Manual Chapter 0609, Appendix D,  
Public Radiation Safety Significance Determination Process, the finding was
determined to be of very low safety significance (Green) because it involved the
Effluent Release Program, it did not impair the ability to assess dose, and did not  
exceed the 10 CFR Part 50, Appendix I, or 10 CFR 20.1301(d) limits.  The finding has a  
cross-cutting aspect in the area of problem identification and resolution, associated with
the resolution component, because the licensee did not ensure that effective corrective  
actions were implemented to address issues in a timely manner commensurate with the  
safety significance [P.3].   


5 The failure to operate the offgas gaseous radwaste system within design specifications, resulting in elevated radiological effluent releases, is a performance deficiency. The finding is more than minor because it is associated with the plant equipment attribute of the Public Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure of radioactive materials released into the public domain as a result of routine civilian nuclear plant operation. Using Inspection Manual Chapter 0609, Appendix D, "Public Radiation Safety Significance Determination Process," the finding was determined to be of very low safety significance (Green) because it involved the Effluent Release Program, it did not impair the ability to assess dose, and did not exceed the  10 CFR Part 50, Appendix I, or 10 CFR 20.1301(d) limits. The finding has a cross-cutting aspect in the area of problem identification and resolution, associated with the resolution component, because the licensee failed to take effective corrective actions in a timely manner to minimize the unreliability and inefficiency of the gaseous radwaste system [P.3].  (Section 2RS6)   
12
Enforcement.  The inspectors did not identify a violation of regulatory requirements. 
Although the licensee failed to operate the system within the design specifications, as
described in the Grand Gulf Nuclear Station System Description, the inspectors
determined this was a self-imposed standard and did not constitute a regulatory
requirement. The issue was entered into the licensees corrective action program as
CR-GGN-2017-06875.  Finding (FIN) 05000416-2017012-02, Failure to Operate the
Gaseous Radwaste System Within Design Specifications.
2RS7 Radiological Environmental Monitoring Program (71124.07)
a.
Inspection Scope
The inspectors evaluated whether the licensees radiological environmental monitoring
program quantified the impact of radioactive effluent releases to the environment and
sufficiently validated the integrity of the radioactive gaseous and liquid effluent release
program.  The inspectors also verified that the licensee continued to implement the
voluntary NEI/Industry Ground Water Protection Initiative.  The inspectors reviewed or
observed the following items:
*
The inspectors observed selected air sampling and dosimeter monitoring
stations, sampler station modifications, and the collection and preparation of  
environmental samples. The inspectors reviewed calibration and maintenance
records for selected air samplers, composite water samplers, and environmental
sample radiation measurement instrumentation, and inter-laboratory comparison
program results.  The inspectors reviewed selected events documented in the
annual environmental monitoring report and significant changes made by the  
licensee to the offsite dose calculation manual as the result of changes to the
land census.  The inspectors evaluated the operability, calibration, and
maintenance of meteorological instruments and assessed the meteorological
dispersion and deposition factors.  The inspectors verified the licensee had
implemented sampling and monitoring program sufficient to detect leakage from
structures, systems, or components with credible mechanism for licensed
material to reach ground water and reviewed changes to the licensees written
program for identifying and controlling contaminated spills/leaks to groundwater.  
*
Groundwater protection initiative (GPI) implementation, including assessment of
groundwater monitoring results, identified leakage or spill events and entries
made into 10 CFR 50.75 (g) records, licensee evaluations of the extent of the
contamination and the radiological source term, and reports of events associated  
with spills, leaks, and groundwater monitoring results.
*
Problem identification and resolution for the radiological environmental
monitoring program.  The inspectors reviewed audits, self-assessments, and
corrective action program documents to verify problems were being identified
and properly addressed for resolution.
These activities constitute completion of the three required samples of radiological
environmental monitoring program, as defined in Inspection Procedure 71124.07.  
   


6
13
b.
Findings
No findings were identified.
2RS8
Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
and Transportation (71124.08)
a.
Inspection Scope
The inspectors evaluated the effectiveness of the licensees programs for processing,
handling, storage, and transportation of radioactive material.  The inspectors interviewed
licensee personnel and reviewed the following items:
*
Radioactive material storage, including waste storage areas including container
labeling/marking and monitoring containers for deformation or signs of waste
decomposition.
*
Radioactive waste system, including walk-downs of the accessible portions of the
radioactive waste processing systems and handling equipment.  The inspectors
also reviewed or observed changes made to the radioactive waste processing
systems, methods for dewatering and waste stabilization, waste stream mixing
methodology, and waste processing equipment that was not operational or
abandoned in place. 
*
Waste characterization and classification, including radio-chemical sample
analysis results for radioactive waste streams and use of scaling factors and
calculations to account for difficult-to-measure radionuclides, and processes for
waste classification including use of scaling factors and 10 CFR Part 61
analyses.
*
Shipment preparation, including packaging, surveying, labeling, marking,
placarding, vehicle checking, driver instructing, and preparation of the disposal
manifests.
*
Shipping records for LSA I, II, III, SCOI, II, Type A, or Type B radioactive material
or radioactive waste shipments. 
*
Problem identification and resolution for radioactive solid waste processing and
radioactive material handling, storage, and transportation.  The inspectors
reviewed audits, self-assessments, and corrective action program documents to
verify problems were being identified and properly addressed for resolution.
These activities constitute completion of the six required samples of radioactive solid
waste processing, and radioactive material handling, storage, and transportation
program, as defined in Inspection Procedure 71124.08.
b.
Findings
No findings were identified. 


=REPORT DETAILS=
14
4.
OTHER ACTIVITIES
4OA6 Meetings, Including Exit 
Exit Meeting Summary
On July 14, 2017, the inspectors presented the radiation safety inspection results to
Mr. E. Larson, Site Vice President, and other members of the licensee staff.  The licensee
acknowledged the issues presented.  The licensee confirmed that any proprietary information
reviewed by the inspectors had been returned or destroyed.


==RADIATION SAFETY==
Cornerstones: Public Radiation Safety and Occupational Radiation Safety
{{a|2RS5}}
   
==2RS5 Radiation Monitoring Instrumentation==
Attachment 1
{{IP sample|IP=IP 71124.05}}
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT 
Licensee Personnel   
J. Ashley, Environmental Specialist, Chemistry
R. Benson, Acting Manager, Radiation Protection
D. Byers, Manager, System Engineering
R. Gaston, Director, Corporate Licensing
M. Giacini, General Manager, Plant Operations
A. Hasanat, Licensing Engineer, Regulatory Assurance
J. Hallanbeck, Design Manager, Engineering
E. Larson, Site Vice President
M. Larson, Supervisor, Radiation Protection
K. Long, Shipper, Radwaste
J. Reese, Specialist, Chemistry
T. Reeves, Supervisor, Chemistry
F. Rosser, Specialist, Radiation Protection
P. Stokes, Support Supervisor, Radiation Protection
S. Sweet, Licensing Engineer, Regulatory Assurance
E. Wright, Supervisor, Radiation Protection
J. Underwood, Manager, Chemistry
NRC Personnel
N. Day, Resident Inspector
R. Smith, Acting Senior Resident Inspector
M. Young, Senior Resident Inspector
S. Hedger, Emergency Preparedness Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED 
Opened
05000416-2017012-01
VIO
Failure to Correct Instrument Calibration Process in a Timely
Manner (Section 2RS5)
Opened and Closed
05000416-2017012-02
FIN
Failure to Operate the Gaseous Radwaste System Within Design
Specifications (Section 2RS6)
Closed
None
Discussed
None


====a. Inspection Scope====
The inspectors evaluated the accuracy and operability of the radiation monitoring equipment used by the licensee to monitor areas, materials, and workers to ensure a radiologically safe work environment. This evaluation included equipment used to monitor radiological conditions related to normal plant operations, anticipated operational occurrences, and conditions resulting from postulated accidents. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance associated with radiation monitoring instrumentation, as described below:
* The inspectors performed walk downs and observations of selected plant radiation monitoring equipment and instrumentation, including portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors. The inspectors assessed material condition and operability, evaluated positioning of instruments relative to the radiation sources or areas they were intended to monitor, and verified performance of source checks and calibrations.
* The inspectors evaluated the calibration and testing program, including laboratory instrumentation, whole body counters, post-accident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, and continuous air monitors.
A1-2
* The inspectors assessed problem identification and resolution for radiation monitoring instrumentation. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.
LIST OF DOCUMENTS REVIEWED
 
These activities constitute completion of the three required samples of radiation monitoring instrumentation, as defined in Inspection Procedure 71124.05.
Section 2RS5: Radiation Monitoring Instrumentation
 
====b. Findings====
Procedures
 
Number
=====Introduction.=====
Title
The inspectors identified a violation of 10 CFR 20.1501(c) for the failure to properly calibrate installed radiation monitors using industry accepted calibration methods and tolerances. Specifically, the main steam line, containment high range, and drywell high range radiation monitors have not been properly calibrated since at least January 2012. This violation was originally entered into the licensee's corrective action program in March 2015 as Condition Report CR-GGNS-2015-01832. However, in 2017, inspectors determined that the licensee failed to implement appropriate corrective 7 actions to properly calibrate the instruments. The licensee entered this repetitive issue into their corrective action process as Condition Report CR-GGN-2017-06826.
Revision
 
06-IC-1D17-R-1002  
=====Description.=====
Main Steam Line High Radiation Monitor  
The failure to properly calibrate the main steam line and containment/drywell high range area radiation monitors was previously identified and documented as a non-cited violation during an inspection in March of 2015:
(PCIS) Calibration  
NCV 05000416/2015001-04, Failure to Properly Calibrate Main Steam Line Radiation Monitors and Containment/Drywall High Range Radiation Monitors.
108, 109  
 
06-IC-1D21-R-1002  
During this inspection, the inspectors reviewed the revised calibration procedures and calibration data for main steam line, containment high range, and drywell high range radiation monitors. The main steam line radiation monitors provide reactor operators with early indication of gross release of fission products from the fuel. This monitor has an automatic response function that isolates the reactor water sample line to limit the release of radioactive materials. The containment high range and drywell high radiation monitors provide reactor operators and emergency response organization members information about the radiological conditions inside the containment building and the drywell. This information is used to make informed decisions about what actions to take during an accident as well as make emergency declarations. As such, it is important that these radiation monitors be properly calibrated. However, it was determined that the improper calibrations did not adversely affect the licensee's ability to implement the Emergency Plan.
Containment/Drywell High Range Area  
 
Radiation Monitor Calibration  
Based on their review of the current revisions of the applicable procedures, corrective action documents, and calibration data, the inspectors determined that the licensee had not corrected the calibration method from the previous non-cited violation. The licensee procedures did not address the required reproducible source-to-detector geometry or the characterization of the calibration sources used. Additionally, because the main steam line monitor calibration requires two different sources in the procedure, each source should have been characterized in a reproducible geometry.
107, 108,109
 
08-S-07-83
The licensee revised Procedure 06-IC-1D17-R-1002, "Main Steam Line High Radiation Monitor (PCIS) Calibration," Revision 109, on April 3, 2017. The previous revision (108)was dated December 13, 2011. Section 5.37 of this procedure describes the radiation calibration method. The calibration method, as described in this section, fails to employ a reproducible geometry or calibrated radiation sources. Further, the calibration method, as described in this section, only addresses calibration of two of the six decades of the logarithmic monitor.
Radiation Protection Instruction Operation
 
and Calibration of the ND-9000 Whole Body
The licensee also revised Procedure 06-IC-1D21-R-1002, "Containment/Drywell High Range Area Radiation Monitor Calibration," Revision 108, on April 3, 2017. The previous revision (107) was dated September 12, 2011. Section 5.87 describes the radiation functional test portion of this procedure. The calibration method described in this section fails to employ a reproducible geometry or a calibrated radiation source. Further, the acceptance criteria in this section are twice that allowed in American National Standards Institute (ANSI) N323D-2002, "American National Standard for Installed Radiation Protection Instrumentation," approved on September 3, 2002. In addition, the electronic calibration method in this procedure as allowed by NUREG 0737, "Clarification of TMI Action Plan Requirements," dated November 1980, only addresses calibration of three of the seven decades of the logarithmic monitor.
Counter 
 
10
8 The inspectors concluded that the licensee had continued to improperly calibrate these process radiation monitors since the previous inspection in March 2015.
EN-CY-102
 
Laboratory Analytical Quality Control
Procedure 06-IC-1D17-R-1002 rocedure is used for all four channels of the main steam line monitors and Procedure 06-IC-1D21-R-1002 is used for both channels of the drywell and containment high range radiation monitors. Because both procedures failed to use appropriate calibration methodologies, the inspectors determined that none of the containment/drywell high range and main steam line radiation monitors had been properly calibrated since at least the date of the procedure revisions, September 12, 2011, and December 13, 2011, respectively.
9
 
EN-FAP-RP-007
In evaluating the underlying cause of the licensee's failure to correct the calibration issue, the inspectors noted the following. On January 20, 2017, a corrective action document (CR-GGN-2017-00612) was initiated identifying a non-conforming condition of a 'Condition Adverse to Quality' that the calibration procedure for the containment high range and drywell high radiation monitors does not control the source geometry to the monitor. The CR further described the required calibration traceability not being maintained. In the self-assessment report of the radiation protection instrument program (OL-GLO-2017-21) completed on May 23, 2017, the assessment team rated Objective 2, the review of the prior inspection report, as unsatisfactory. This rating was given because actions related to this issue were not complete after a considerable amount of time, which included at least five due date extensions and an extended outage that should have allowed completion of the corrective action.
Operation of the RP Central Calibration
 
Facility
=====Analysis.=====
2
The failure to properly calibrate radiation monitors is a performance deficiency. The performance deficiency is more than minor because it is associated with the cornerstone attribute of plant instrumentation and adversely affects the cornerstone objective to ensure adequate protection of employee health and safety during routine civilian nuclear reactor operation and is therefore a finding. Specifically, the failure to properly calibrate radiation monitors impacts the licensee's ability to assess dose rates.
EN-MA-105
 
Control of Measuring and Test Equipment
Using Inspection Manual Chapter 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process," dated August 19, 2008, the inspectors determined the finding to be of very low safety significance because it was not an as low as reasonably achievable (ALARA) issue, there was no overexposure or substantial potential for overexposure, and the licensee's ability to assess dose was not compromised. This finding has a cross-cutting aspect in the area of problem identification and resolution, associated with the resolution component, because the licensee did not ensure that effective corrective actions were implemented to address issues in a timely manner commensurate with the safety significance [P.3].
(M&TE)  
 
13
=====Enforcement.=====
EN-RP-122
Title 10 CFR 20.1501(c) requires, in part, that the licensee shall ensure that instruments and equipment used for quantitative radiation measurements are calibrated periodically for the radiation measured. Contrary to the above, since at least January 1, 2012, the licensee failed to ensure that instruments and equipment used for quantitative radiation measurements were calibrated periodically for the radiation measured. Specifically, the licensee failed to properly calibrate the containment/drywell high range radiation monitors and the main steam line radiation monitors using industry accepted calibration methods and tolerances. This issue was entered into the licensee's corrective action program as Condition Report CR-GGN-2017-06826.
Alpha Monitoring
 
9  
9 This issue was previously identified during an inspection in March of 2015, as NCV 05000416/2015001-04 and was treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy. Since the licensee did not restore compliance in a reasonable period of time, this violation is being cited, consistent with the NRC Enforcement Policy, Section 2.3.2, which states, in part, that the licensee must restore compliance within a reasonable period of time (i.e., in a timeframe commensurate with the significance of the violation) after a violation is identified. A Notice of Violation is attached. VIO 05000416/2017012-01, "Failure to Properly Calibrate Installed Radiation Monitors Using Industry Accepted Calibration Methods and Tolerances."
EN-RP-301
{{a|2RS6}}
Radiation Protection Instrument Control
==2RS6 Radioactive Gaseous and Liquid Effluent Treatment==
10
{{IP sample|IP=IP 71124.06}}
EN-RP-305
 
Source Maintenance 
====a. Inspection Scope====
0
The inspectors evaluated whether the licensee maintained gaseous and liquid effluent processing systems and properly mitigated, monitored, and evaluated radiological discharges with respect to public exposure. The inspectors verified that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out-of-service, were controlled in accordance with the applicable regulatory requirements and licensee procedures. The inspectors verified that the licensee's quality control program ensured radioactive effluent sampling and analysis adequately quantified and evaluated discharges of radioactive materials. The inspectors verified the adequacy of public dose projections resulting from radioactive effluent discharges. The inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:
EN-RP-317
* During walk downs and observations of selected portions of the radioactive gaseous and liquid effluent equipment, the inspectors evaluated routine processing and discharge of effluents, including sample collection and analysis.
Central Calibration Facility
 
0
The inspectors observed equipment configuration and flow paths of selected gaseous and liquid discharge system components, effluent monitoring systems, filtered ventilation system material condition, and significant changes to effluent release points.
EN-RP-317-08
* Calibration and testing program for process and effluent monitors, including National Institute of Standards and Technology traceability of sources, primary and secondary calibration data, channel calibrations, set-point determination bases, and surveillance test results.
Calibration of Portable Scalers 
* Sampling and analysis controls used to ensure representative sampling and appropriate compensatory sampling. Reviews included results of the inter-laboratory comparison program,
1
* Instrumentation and equipment, including effluent flow measuring instruments, air cleaning systems, and post-accident effluent monitoring instruments.
EN-RP-317-09
* Dose calculations for effluent releases. The inspectors reviewed a selection of radioactive liquid and gaseous waste discharge permits and abnormal gaseous or liquid tank discharges, and verified the projected doses were accurate. The 10 inspectors also reviewed 10 CFR Part 61 analyses and methods used to determine which isotopes were included in the source term. The inspectors reviewed land use census results, offsite dose calculation manual changes, and significant changes in reported dose values from previous years.
Calibration of Dosimeters
* Problem identification and resolution for radioactive gaseous and liquid effluent treatment. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.
2
 
EN-RP-317-10
These activities constitute completion of the six required samples of radioactive gaseous and liquid effluent treatment program, as defined in Inspection Procedure 71124.06.
Calibration of Portable Dose Rate Instrument 0
 
ODCM
====b. Findings====
Offsite Dose Calculation Manual
 
39
=====Introduction.=====
The inspectors identified a Green finding for the licensee's failure to operate their gaseous radwaste system within design specifications, resulting in elevated radiological effluent releases that were not as low as reasonably achievable. These deficiencies in meeting the design specifications/parameters are associated with the offgas charcoal adsorber and vault refrigeration components of the offgas system, which have impacted the system's reliability and efficiency since at least 2007.
Audits and Self-Assessments
 
Number
=====Description.=====
Title
When reviewing the licensee's annual effluent release reports, the inspectors identified that in calendar year 2013, the licensee had total airborne releases of fission and activation gases of 1920 curies (Ci), including a peak release of 1540 Ci during the third quarter. The inspectors noted that this annual gaseous release was significantly higher than the previous annual releases of approximately 450 Ci in calendar years 2010 thru 2012. The licensee stated the primary reason for the elevated activity of gaseous releases was associated with refrigeration equipment issues affecting charcoal adsorption efficiency. Upon further evaluation, NRC inspectors determined that such issues with the charcoal adsorbers and vault refrigeration systems were long-term, ongoing, unresolved deficiencies in the gaseous radwaste system primarily due to numerous condenser in-leakages that remain unrepaired.
Date
 
OL-GLO-2017-21
The Grand Gulf Nuclear Station System Description, Revision 2, for the gaseous radwaste system notes that there are two sets of four charcoal adsorber vessels arranged in series, totaling eight charcoal adsorber beds. As the offgas flows from the condenser system via the steam jet air ejectors into the charcoal adsorption system, the charcoal acts as a medium to delay the flow of krypton and xenon gases to allow them to decay to radiation levels acceptable for atmospheric release. In addition, the activated charcoal adsorbs the radioactive isotopes of iodine removing them for decay.
Self-Assessment of RP Instrumentation
 
Program
The adsorption of xenon, krypton, and iodine offgas on charcoal depends on gas flowrate, holdup time, mass of charcoal, and the dynamic adsorption coefficient. The inspectors determined the nominal flowrate for the licensee's charcoal system to operate efficiently is specified as 30 scfm, to achieve proper holdup times of offgases. However, the licensee has been consistently running the system at 80 scfm. The Grand Gulf Nuclear Station System Description also states the charcoal adsorbers must be operated under controlled temperature and humidity conditions, maintaining a steady state temperature of about 0 degrees Fahrenheit (°F). However, for optimal 11 performance, a refrigeration temperature of 0 to -40°F is specified. The inspectors reviewed Figure 10 of Section 4.1.7 of Grand Gulf Nuclear Station System Description, entitled "Comparative Curie Decontamination Factors for 8, 12, and 16 Bed Systems," which illustrated that the charcoal low temperature, eight bed system is designed to operate at a decontamination factor of 1000 with the specified design parameters (i.e., 30 scfm, 0ºF). However, the inspectors determined licensee's current offgas flowrate of approximately 80 scfm and refrigeration temperature of approximately +15°F will achieve a decontamination factor of less than 50. The licensee performed evaluations, as documented in Apparent Cause Evaluation CR-GGN-2013-0450, and determined that corrective actions were needed to decrease the current elevated offgas flowrate into the charcoal adsorbers from approximately 80 scfm, and to reduce the vault refrigeration temperature to within design specifications. The licensee implemented some corrective actions to reduce condenser in-leakage, resulting in some improvement in the offgas flowrate (reduction from ~160 scfm to ~80 scfm). However, the offgas flowrates, charcoal adsorber flowpath, and refrigeration vault operations still remain inconsistent with the design specifications.
May 23, 2017
 
QA-14/15-201 5-GGN-1 QA Audit: Combined Radiation Protection and  
Although these deficiencies were ongoing issues, the licensee provided no documented evaluation to demonstrate that the degraded performance of the offgas system was maintaining gaseous releases as low as reasonably achievable, which the Updated Final Safety Analysis Report states is the primary design objective of the gaseous radwaste management system. The NRC inspectors discussed with the licensee that, although the airborne releases may meet the 10 CFR Part 20, Appendix I, limitations, the failure to operate the system consistent with design parameters is significantly impacting the system's ability to maintain gaseous releases as low as reasonably achievable, as evidenced by the annual effluent reports.
Radwaste
 
November 16, 2015
The licensee has developed a system improvement plan entitled, "Offgas Long Range Plan and Concluding Actions," to address how the plant may resolve the issues within the next few scheduled outages. This performance deficiency was entered into the licensee's CAP as Condition Report CR-GGN-2017-06875.
 
=====Analysis.=====
The failure to operate the offgas gaseous radwaste system within design specifications, resulting in elevated radiological effluent releases, is a performance deficiency. The finding is more than minor because it is associated with the plant equipment attribute of the Public Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure of radioactive materials released into the public domain as a result of routine civilian nuclear plant operation. Using Inspection Manual Chapter 0609, Appendix D, "Public Radiation Safety Significance Determination Process," the finding was determined to be of very low safety significance (Green) because it involved the Effluent Release Program, it did not impair the ability to assess dose, and did not exceed the 10 CFR Part 50, Appendix I, or 10 CFR 20.1301(d) limits. The finding has a cross-cutting aspect in the area of problem identification and resolution, associated with the resolution component, because the licensee did not ensure that effective corrective actions were implemented to address issues in a timely manner commensurate with the safety significance [P.3].
 
12


=====Enforcement.=====
The inspectors did not identify a violation of regulatory requirements. Although the licensee failed to operate the system within the design specifications, as described in the Grand Gulf Nuclear Station System Description, the inspectors determined this was a self-imposed standard and did not constitute a regulatory requirement. The issue was entered into the licensee's corrective action program as CR-GGN-2017-06875. Finding (FIN) 05000416-2017012-02, "Failure to Operate the Gaseous Radwaste System Within Design Specifications."
{{a|2RS7}}
==2RS7 Radiological Environmental Monitoring Program==
A1-3
{{IP sample|IP=IP 71124.07}}
Condition Reports (CR-GGNS-)
2015-01775
2015-01773
2015-02807
2015-01831
2015-01832
2016-01796
2016-04647
2016-05297
2016-08308
2016-09537
2016-09889
2017-00612
2017-04141
2017-04697
2017-06865
2017-06876
Installed Radiation Instrument Calibration Records
W/O Number
Title
Date
52628844
Main Steam Line High Radiation Monitor (PCIS)
Calibration - Channel A
February 22, 2017
52637367
Containment/Drywell High Range Area Radiation
Monitor Calibration - Channel A
March 16, 2016
Portable Radiation Instrument Calibration Records
Number
Title
Date
ASC-001
Calibration Data Sheet:  SAC-4
March 28, 2017
CHP-C-015
Calibration Data Sheet:  Model 2000(43-10) Alpha
Scaler 
July 10 2017
CHP-C-022
Calibration Data Sheet:  iSolo Alpha Scaler
April 27, 2017
CHP-CS-020
Calibration Data Sheet:  iSolo Alpha Scaler
March 23, 2017
CHP-DR-283
Calibration Data Sheet:  TelePole
June 13, 2017
HP-11431
Calibration Data Sheet:  RO-2
June 6, 2017
HP-CS-004
Calibration Data Sheet:  Model BC-4
July 6, 2017
HP-DR-563
Calibration Data Sheet:  Model 9-3
December 12, 2016
HP-DR-563
Calibration Data Sheet:  Ludlum Model-9-3
July 11, 2017
HP-DS-054
Calibration Data Sheet:  Model SAC-4
July 10, 2017
RAM-001
Calibration Data Sheet:  AMP-100
March 12, 2017
Stationary Radiation Instrument Calibration Records
Number
Title
Date
400-10-17-005
Germanium Detector No. 3 Calibration Package
March 23, 2017
400-11-17-005
Germanium Detector No. 4 Calibration Package
March 22, 2017
400-9-17-002
Germanium Detector No. 2 Calibration Package
March 15, 2017


====a. Inspection Scope====
The inspectors evaluated whether the licensee's radiological environmental monitoring program quantified the impact of radioactive effluent releases to the environment and sufficiently validated the integrity of the radioactive gaseous and liquid effluent release program. The inspectors also verified that the licensee continued to implement the voluntary NEI/Industry Ground Water Protection Initiative. The inspectors reviewed or observed the following items:
* The inspectors observed selected air sampling and dosimeter monitoring stations, sampler station modifications, and the collection and preparation of environmental samples. The inspectors reviewed calibration and maintenance records for selected air samplers, composite water samplers, and environmental sample radiation measurement instrumentation, and inter-laboratory comparison program results. The inspectors reviewed selected events documented in the annual environmental monitoring report and significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census. The inspectors evaluated the operability, calibration, and maintenance of meteorological instruments and assessed the meteorological dispersion and deposition factors. The inspectors verified the licensee had implemented sampling and monitoring program sufficient to detect leakage from structures, systems, or components with credible mechanism for licensed material to reach ground water and reviewed changes to the licensee's written program for identifying and controlling contaminated spills/leaks to groundwater.
* Groundwater protection initiative (GPI) implementation, including assessment of groundwater monitoring results, identified leakage or spill events and entries made into 10 CFR 50.75 (g) records, licensee evaluations of the extent of the contamination and the radiological source term, and reports of events associated with spills, leaks, and groundwater monitoring results.
A1-4
* Problem identification and resolution for the radiological environmental monitoring program. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.
Stationary Radiation Instrument Calibration Records
Number
Title
Date
Apex-InVivo
Analysis Report Calibration Check Count of People
Mover Whole Body Monitor
July 12, 2017
Canberra
Calibration of the Canberra/Nuclear Data People
Mover WBC System at Entergy Grand Gulf Nuclear
Station 
August 8, 2015
Other Radiation Protection Instrument Records
Number
Title
Date
CHP-DR-326
Instrument Response Check Failure Review 
January 13, 2017
CHP-TEL039
Instrument Response Check Failure Review 
May 15, 2017
CHP-TEL044
Instrument Response Check Failure Review 
March 1, 2017
HP-11431
Maintenance Data Sheet:  Failed Calibration Check
April 10, 2017
Miscellaneous Documents
Number
Title
Date
201512044
Central Radiation Protection Maintenance Data Sheet December 10, 2015
201706-012
Entergy Operations, Inc., Portable Instruments to  
Waterford-3 RP
June 19, 2017
3751
Laboratory Standard Calibration/Verification Data:
V-570 Meter
July 9, 2015
AO-987
Amersham Source Decay Data Sheet
January 26, 2017
AO-988
Amersham Source Decay Data Sheet 
January 26, 2017
ERIC Report
Instrument Status Report Calibration Needed for  
GGNS
July 11, 2017
JLS-8254
Source Verification of Source J.L. Shephard Calibrator
S/N SRC-1993003 Model-89 (400) Cs-137 Sealed
Sources at Set Positions
October 13, 2015
MP-141
AEA Technology Source Decay Sheet
January 26, 2017
MP-158
AEA Technology Source Decay Sheet
January 26, 2017


These activities constitute completion of the three required samples of radiological environmental monitoring program, as defined in Inspection Procedure 71124.07.
A1-5
Section 2RS6:  Radioactive Gaseous and Liquid Effluent Treatment
Procedures
Number
Title
Revision
04-1-01-N65-1-SU
System Operating Instruction Offgas Vault
Refrigeration
033
06-CH-1000-M-0049
Effluent Dose Calculations
104
06-CH-1D17-M-0003
Building Ventilation Gaseous Tritium
109
06-CH-1D17-M-0005
Building Ventilation Exhaust Gaseous Isotopic
109
06-CH-1D17-M-0018
Gaseous Release Points - Particulate Alpha
Activity
108
06-CH-1D17-W-0017
Gaseous Release Points - Iodines, Tritium and
Particulates
106
06-CH-1T48-M-0037
Standby Gas Treatment Exhaust Gaseous Isotopic 107
06-CH-SG17-O-0045
Radwaste Release Post-Release Calculations
105
06-CH-SG17-P-0041
Radwaste Release Pre-Release Analysis
109
06-CH-SG17-Q-0044
Radwaste Release Quarterly Composite
103
08-S-03-10
Chemistry Sampling Program
052
08-S-03-22
Installed Radiation Monitoring System Alarm
Setpoint Determination and Control
114
1-S-08-11
Radioactive Discharge Controls
114
EN-CY-108
Monitoring of Nonradioactive Systems
006
Audits and Self-Assessments
Number
Title
Date
LO-GLO-2016-0122
Pre-NRC RETS/ODCM Radiological Effluent
Occurrences Assessment
December 4, 2016
Teledyne Brown Engineering Environmental
Services
April 19, 2017
QA-2-6-2015-GGNS-1 GGNS Combined Chemistry Effluent and
Environmental Monitoring (including ODCM
and REMP) Program Audit 
October 9, 2015
Condition Reports (CR-GGNS-)
2013-00450
2015-06763
2015-06764
2015-06982
2016-02468
2016-02688
2016-07187
2016-08307
2016-08308
2017-00051
2017-00193
2017-00204
2017-00264
2017-00290
2017-00336
2017-00529
2017-03101
2017-03745
2017-04525
2017-05659
2017-06821
2017-06875


13
 
====b. Findings====
No findings were identified.
A1-6
{{a|2RS8}}
10 CFR 50.75(g) Condition Reports (CR-GGNS-)
==2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation==
2015-06763
{{IP sample|IP=IP 71124.08}}
2015-06764
 
2016-07187
====a. Inspection Scope====
2017-00336
The inspectors evaluated the effectiveness of the licensee's programs for processing, handling, storage, and transportation of radioactive material. The inspectors interviewed licensee personnel and reviewed the following items:
* Radioactive material storage, including waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition.
* Radioactive waste system, including walk-downs of the accessible portions of the radioactive waste processing systems and handling equipment. The inspectors also reviewed or observed changes made to the radioactive waste processing systems, methods for dewatering and waste stabilization, waste stream mixing methodology, and waste processing equipment that was not operational or abandoned in place.
Release Permits
* Waste characterization and classification, including radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides, and processes for waste classification including use of scaling factors and 10 CFR Part 61 analyses.
Liquid Releases
* Shipment preparation, including packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifests.
* Shipping records for LSA I, II, III, SCOI, II, Type A, or Type B radioactive material or radioactive waste shipments.
* Problem identification and resolution for radioactive solid waste processing and radioactive material handling, storage, and transportation. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution. These activities constitute completion of the six required samples of radioactive solid waste processing, and radioactive material handling, storage, and transportation program, as defined in Inspection Procedure 71124.08.
 
====b. Findings====
2015051
No findings were identified.
2015094
 
2016011
==OTHER ACTIVITIES==
2016017
{{a|4OA6}}
2016022
==4OA6 Meetings, Including Exit==
2016040
 
2016042
=====Exit Meeting Summary=====
2016044
 
2016045
On July 14, 2017, the inspectors presented the radiation safety inspection results to Mr. E. Larson, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
2016051
 
2016073
1
2017009
2017018
In-Place Filter Testing Records
Number
System
Train
Test
Date
WO 46551718
Standby Gas Treatment
B
DOP & HEPA
June 3, 2017
WO 52482060
Standby Gas Treatment
A
DOP & HEPA
March 16, 2015
WO 52618801
Control Room Air / Standby
Fresh Air
A
DOP & HEPA
October 27, 2016
WO 52655772
Control Room Air / Standby
Fresh Air
B
DOP & HEPA
December 1, 2016
Miscellaneous Documents
Number
Title
Revision
Date
2014 Annual Radioactive Effluent Release Report
April 27, 2015
2015 Annual Radioactive Effluent Release Report
April 14, 2016
2016 Annual Radioactive Effluent Release Report
April 25, 2017
Cross Contamination of Service Air System / CR-
GGN-2017-00193
February 27, 2017
Grand Gulf Service Air System I.E. Bulletin 80-10
Bounding Evaluation for Contamination of a
Nonradioactive System
March 29, 2017
Nuclear Independent Oversight Functional Area
Performance Report: Group B
May 31, 2016
Offsite Dose Calculation Manual
39
1000-1-17-002
2016 Radiochemistry INTRALAB Cross-Check
Results
January 23, 2017
GNRO-2016/00039
Supplement to Grand Gulf Nuclear Station 2015
Annual Radioactive Effluent Release Report (ARERR)
July 20, 2016
SD N64/N65
Grand Gulf Nuclear Station System Description
2
UFSAR Chapter 11
GGN Updated Final Safety Analysis Report
2016-00


=SUPPLEMENTAL INFORMATION=
A1-7
Section 2RS7:  Radiological Environmental Monitoring Program
Procedures
Number
Title
Revision
06-EN-S000-V-0001
Surveillance Procedure Radiological
Environmental Sampling
111
06-IC-SC84-SA-1003 Primary Tower Wind Speed/Direction, Air
Temperature (T/dT) and Relative Humidity
106
07-S-53-C84-7
Backup Tower Wind/Speed/Direction and Air
Temperature Calibration
0
08-S-04-964
Met Data Processing
2
ODCM
Offsite Dose Calculation Manual
39
Audits and Self-Assessments
Number
Title
Date
LO-GLO-2015-00042
Focused Self-Assessment:
Chemistry Groundwater/Environmental
Programs
November 18, 2015
2015
Environmental Dosimetry Company
Quality Assurance Status Report
February 29, 2016
2015
Teledyne Brown Engineering: 
Environmental Services
Quality Assurance Report
May 9, 2016
2016
Environmental Dosimetry Company
Quality Assurance Status Report
March 8, 2017
2016
Teledyne Brown Engineering: 
Environmental Services
Quality Assurance Report
April 19, 2017
Condition Reports (CR-GGNS-)
2015-04675
2015-05753
2015-06263
2015-06763
2016-03213
2016-03475
2016-03825
2016-05543
2016-07187
2016-07747
2016-08364
2016-09067
2017-00813
2017-00993
2017-01731
2017-02633
2017-05447


==KEY POINTS OF CONTACT==
A1-8
REMP Air Sampler Calibration Data 
Number
Title
Date
CHEM-001
LV-1D - Air Sampler (LOVOL)
July 21, 2016
CHEM-002
LV-1D - Air Sampler (LOVOL)
October 20, 2016
CHEM-003
LV-1D - Air Sampler (LOVOL)
July 19, 2016
Meteorological Instrument Calibration Records
W/O Number
Title
Date
52652328
Backup Meteorological Tower Instrument
Calibration
07-S-53-C84-7
August 29, 2016
52692658
Primary Meteorological Tower Instrument
Calibrations
06-IC-SC84-SA-1003 
August 2, 2016
Meteorological Data
Number
Title
Date
2016
ODCM Annual Average Relative Concentration
(/Q) and Relative Deposition (D/Q)
March 2017
2016
Review of Grand Gulf Meteorological Data 
March 9, 2017
Groundwater Protection Documents
Number
Title
Revision / Date
L71506
Groundwater Monitoring Report - January 2017
February 3, 2017
L71974
Groundwater Monitoring Report - February 2017
March 31, 2017
L72140
Groundwater Monitoring Report - March 2017
March 31, 2017
L72521
Groundwater Monitoring Report - April 2017
May 5, 2017
R06045-0032-002 Groundwater Monitoring Plan
6
Miscellaneous Documents
Number
Title
Date
2015
Annual Environmental Operating Report
April 19, 2016
2016
Annual Environmental Operating Report
April 27, 2017
2016
Land Use Census
December 16, 2016
2017-044
Licensing Basis Document Change Request
(LBDCR)
April 27, 2017


===Licensee Personnel===
: [[contact::J. Ashley]], Environmental Specialist, Chemistry
: [[contact::R. Benson]], Acting Manager, Radiation Protection
: [[contact::D. Byers]], Manager, System Engineering
A1-9
: [[contact::R. Gaston]], Director, Corporate Licensing
: [[contact::M. Giacini]], General Manager, Plant Operations  
Section 2RS8: Radioactive Solid Waste Processing, and Radioactive Material Handling,  
: [[contact::A. Hasanat]], Licensing Engineer, Regulatory Assurance
Storage, and Transportation
: [[contact::J. Hallanbeck]], Design Manager, Engineering
: [[contact::E. Larson]], Site Vice President
Procedures
: [[contact::M. Larson]], Supervisor, Radiation Protection  
: [[contact::K. Long]], Shipper, Radwaste  
: [[contact::J. Reese]], Specialist, Chemistry
Number
: [[contact::T. Reeves]], Supervisor, Chemistry
Title
: [[contact::F. Rosser]], Specialist, Radiation Protection
Revision
: [[contact::P. Stokes]], Support Supervisor, Radiation Protection
EN-RW-101
: [[contact::S. Sweet]], Licensing Engineer, Regulatory Assurance
Radioactive Waste Management
: [[contact::E. Wright]], Supervisor, Radiation Protection
3
: [[contact::J. Underwood]], Manager, Chemistry
EN-RW-102
Radioactive Shipping Procedure
15
EN-RW-103
Radioactive Waste Tracking Procedure
4
EN-RW-104
Scaling Factors
13
EN-RW-105
Process Control Program
5
EN-RW-106
Integrated Transportation Security Plan
6
04-S-01-G17-3
Radwaste Filters and Demineralizer
47
08-S-06-50
Radwaste Instruction: Loading Radioactive
Material
9
08-S-06-71
Radwaste Instruction: Sampling
Procedures for Waste Classification
7
07-S-14-428
Operation and Maintenance of the TRI-
NUC Underwater Filtration System  
0
08-S-02-075
Radiation Protection Instruction - Coverage
and Control of Refueling Operations and
Movement of Irradiated Materials
16
Audits and Self-Assessments
Number
Title
Date
QA-1 4/15-2015-GGN-1
Combined Radiation Protection and
Radwaste  
September 14, 2015
LO-GLO-2017-00022
Pre-NRC Inspection Module 71124-08
May 24, 2017
LO-GLO-2015-00139
10 CFR Part 37 Materials Security Review
January 8, 2016
Condition Reports (CR-HQN-)
2015-00747
2017-00904
Condition Reports (CR-GGNS-)
2015-00231
2015-05082
2016-00319
2016-00320
2016-00801
2016-00804
2016-00805
2016-00809
2016-04376
2017-00101
2017-00106
2017-01568
2017-01625
2017-01644
2017-04789
2017-05552
2017-06772
2017-06779


===NRC Personnel===
: [[contact::N. Day]], Resident Inspector
: [[contact::R. Smith]], Acting Senior Resident Inspector
: [[contact::M. Young]], Senior Resident Inspector
A1-10
: [[contact::S. Hedger]], Emergency Preparedness Inspector  
Radioactive Material and Waste Shipments
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
Number
Title
Date
GGN-2017-0101
CFFF Filters - LSA-II
January 12, 2017
GGN-2017-0102
CRD-CRDM- LSA-II
January 13, 2017
GGN-2017-0106
CPS Powdex Liner
January 20, 2017
GGN-2016-0319
WMG Sealands
March 16, 2016
GGN-2016-0320
Suppression Pool Filter Liners
March 21, 2016
GGN-2016-0324
5 Type A GE Boxes
March 23, 2016
GGN-2015-0801
RWCU-A Liner - Type B
August  3, 2017
GGN-2015-0805
RWCU-A Liner - Type B
August  3, 2017
GGN-2015-0809
RWCU-A Liner - Type B
August 16, 2017
Miscellaneous Documents
Number
Title
Date
OE-NOE-2016-00
NRC-RIS-2016-11
November 30, 2016
2017
RW/RAM Shipping Log
January 1, 2017
2016
RW/RAM Shipping Log
January 1, 2016
2015
RW/RAM Shipping Log
January 1, 2015
UFSAR Chapter 11
GGN Updated Final Safety Analysis Report
2016
Management Standard No. 36
April 25, 2017
Monitoring & Responding to Dose Rates on the
Fuel Pools
April 14, 2016
   
2015 Annual Radioactive Effluent Release
Report
April 25, 2017
2016 Annual Radioactive Effluent Release
Report
June 13, 2017
Radioactive Material Storage Container
Tracking Sheets


===Opened===
: 05000416-2017012-01 VIO Failure to Correct Instrument Calibration Process in a Timely Manner (Section 2RS5)  
===Opened and Closed===
Attachment 2
: 05000416-2017012-02 FIN Failure to Operate the Gaseous Radwaste System Within Design Specifications (Section 2RS6)   
The following items are requested for the
===Closed===
Occupational/Public Radiation Safety Inspection
: None   
at Grand Gulf Nuclear Station
===Discussed===
July 10 to 14, 2017
None   
Integrated Report 2017007
Inspection areas are listed in the attachments below. 
Please provide the requested information on or before June 14, 2017.
Please submit this information using the same lettering system as below. For example, all
contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled
1- A, applicable organization charts in file/folder 1- 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 Martin Phalen at (817) 200-1158 or
martin.phalen@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.


==LIST OF DOCUMENTS REVIEWED==
==Section 2RS5: Radiation Monitoring Instrumentation==
A2-2
5.
Radiation Monitoring Instrumentation (71124.05)
Date of Last Inspection:
March 27, 2015
A.
List of contacts and telephone numbers for the following areas:
1. Effluent monitor calibration
2. Radiation protection instrument calibration
3. Installed instrument calibrations
4. Count room and Laboratory instrument calibrations
B.
Applicable organization charts
C.
Copies of audits, self-assessments, vendor or NUPIC audits for contractor support and
LERs, written since date of last inspection, related to: 
1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey
instruments, electronic dosimeters, teledosimetry, personnel contamination monitors,
or whole body counters 
2. Installed radiation monitors
D.
Procedure index for:
1. Calibration, use and operation of continuous air monitors, criticality monitors,
portable survey instruments, temporary area radiation monitors, electronic
dosimeters, teledosimetry, personnel contamination monitors, and whole body
counters.
2. Calibration of installed radiation monitors
E.
Please provide specific procedures related to the following areas noted below. 
Additional Specific Procedures will be requested by number after the inspector reviews
the procedure indexes. 
1. Calibration of portable radiation detection instruments (for portable ion chambers)
2. Whole body counter calibration
3. Laboratory instrumentation quality control
F.
A summary list of corrective action documents (including corporate and sub-tiered
systems) written since date of last inspection, related to the following programs:
1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey
instruments, electronic dosimeters, teledosimetry, personnel contamination monitors,
whole body counters, 
2. Installed radiation monitors, 
3. Effluent radiation monitors
4. Count room radiation instruments
NOTE: The lists should indicate the significance level of each issue and the search
criteria used.  Please provide in document formats which are searchable so that
the inspector can perform word searches.
G.
Offsite dose calculation manual, technical requirements manual, or licensee controlled
specifications, which lists the effluent monitors and calibration requirements.
H.
Current calibration data for the whole body counters.


===Procedures===
: Number Title Revision 06-IC-1D17-R-1002 Main Steam Line High Radiation Monitor (PCIS) Calibration 108, 109 06-IC-1D21-R-1002 Containment/Drywell High Range Area Radiation Monitor Calibration 107, 108,109 08-S-07-83 Radiation Protection Instruction Operation and Calibration of the
   
: ND-9000 Whole Body Counter
   
: 10
A2-3  
: EN-CY-102 Laboratory Analytical Quality Control 9
I.
: EN-FAP-RP-007 Operation of the RP Central Calibration Facility 2
Primary to secondary source calibration correlation for effluent monitors.
: EN-MA-105 Control of Measuring and Test Equipment (M&TE) 13
J.  
: EN-RP-122 Alpha Monitoring 9
A list of the point of discharge effluent monitors with the two most recent calibration
: EN-RP-301 Radiation Protection Instrument Control 10
dates and the work order numbers associated with the calibrations.
: EN-RP-305 Source Maintenance
K.
: 0
Radiation Monitoring System health report for the previous 12 months
: EN-RP-317 Central Calibration Facility 0
: EN-RP-317-08 Calibration of Portable Scalers
: 1
: EN-RP-317-09 Calibration of Dosimeters 2
: EN-RP-317-10 Calibration of Portable Dose Rate Instrument 0 ODCM Offsite Dose Calculation Manual 39
: Audits and Self-Assessments Number Title Date
: OL-GLO-2017-21 Self-Assessment of RP Instrumentation Program May 23, 2017
: QA-14/15-201 5-GGN-1 QA Audit: Combined Radiation Protection and Radwaste November 16, 2015
===Condition Reports (CR-GGNS-)===
: 2015-01775 2015-01773 2015-02807 2015-01831 2015-01832 2016-01796 2016-04647 2016-05297 2016-08308 2016-09537 2016-09889 2017-00612 2017-04141 2017-04697 2017-06865 2017-06876
: Installed Radiation Instrument Calibration Records W/O Number Title Date
: 52628844 Main Steam Line High Radiation Monitor (PCIS) Calibration - Channel A February 22, 2017
: 52637367 Containment/Drywell High Range Area Radiation Monitor Calibration - Channel A March 16, 2016
: Portable Radiation Instrument Calibration Records Number Title Date
: ASC-001 Calibration Data Sheet:
: SAC-4 March 28, 2017
: CHP-C-015 Calibration Data Sheet:
: Model 2000(43-10) Alpha Scaler
: July 10 2017
: CHP-C-022 Calibration Data Sheet: iSolo Alpha Scaler April 27, 2017
: CHP-CS-020 Calibration Data Sheet: iSolo Alpha Scaler March 23, 2017
: CHP-DR-283 Calibration Data Sheet:
: TelePole June 13, 2017
: HP-11431 Calibration Data Sheet:
: RO-2 June 6, 2017
: HP-CS-004 Calibration Data Sheet:
: Model
: BC-4 July 6, 2017
: HP-DR-563 Calibration Data Sheet:
: Model 9-3 December 12, 2016HP-DR-563 Calibration Data Sheet:
: Ludlum Model-9-3 July 11, 2017
: HP-DS-054 Calibration Data Sheet:
: Model
: SAC-4 July 10, 2017
: RAM-001 Calibration Data Sheet:
: AMP-100 March 12, 2017
: Stationary Radiation Instrument Calibration Records Number Title Date 400-10-17-005 Germanium Detector No. 3 Calibration Package March 23, 2017 400-11-17-005 Germanium Detector No. 4 Calibration Package March 22, 2017 400-9-17-002 Germanium Detector No. 2 Calibration Package March 15, 2017 
: Stationary Radiation Instrument Calibration Records Number Title Date Apex-InVivo Analysis Report Calibration Check Count of People Mover Whole Body Monitor July 12, 2017 Canberra Calibration of the Canberra/Nuclear Data People Mover WBC System at Entergy Grand Gulf Nuclear Station
: August 8, 2015
: Other Radiation Protection Instrument Records Number Title Date
: CHP-DR-326 Instrument Response Check Failure Review
: January 13, 2017
: CHP-TEL039 Instrument Response Check Failure Review
: May 15, 2017
: CHP-TEL044 Instrument Response Check Failure Review
: March 1, 2017
: HP-11431 Maintenance Data Sheet:
: Failed Calibration Check April 10, 2017
===Miscellaneous Documents===
: Number Title Date
: 201512044 Central Radiation Protection Maintenance Data Sheet December 10, 2015201706-012 Entergy Operations, Inc., Portable Instruments to Waterford-3 RP June 19, 2017 3751 Laboratory Standard Calibration/Verification Data: V-570 Meter July 9, 2015
: AO-987 Amersham Source Decay Data Sheet January 26, 2017
: AO-988 Amersham Source Decay Data Sheet
: January 26, 2017
: ERIC Report Instrument Status Report Calibration Needed for GGNS July 11, 2017
: JLS-8254 Source Verification of Source J.L. Shephard Calibrator S/N
: SRC-1993003 Model-89 (400) Cs-137 Sealed Sources at Set Positions October 13, 2015
: MP-141 AEA Technology Source Decay Sheet January 26, 2017
: MP-158 AEA Technology Source Decay Sheet January 26, 2017


==Section 2RS6: Radioactive Gaseous and Liquid Effluent Treatment==
A2-4
6.
Radioactive Gaseous and Liquid Effluent Treatment (71124.06) 
Date of Last Inspection:
March 27, 2015
A.
List of contacts and telephone numbers for the following areas:
1. Radiological effluent control
2. Engineered safety feature air cleaning systems
B.
Applicable organization charts
C.
Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs
written since date of last inspection, related to:
1.  Radioactive effluents
2.  Engineered Safety Feature Air cleaning systems
D.
Procedure indexes for the following areas
1.  Radioactive effluents
2.  Engineered Safety Feature Air cleaning systems
E.
Please provide specific procedures related to the following areas noted below. 
Additional Specific Procedures will be requested by number after the inspector reviews
the procedure indexes. 
1. Sampling of radioactive effluents
2. Sample analysis
3. Generating radioactive effluent release permits
4. Laboratory instrumentation quality control
5. In-place testing of HEPA filters and charcoal adsorbers
6. New or applicable procedures for effluent programs (e.g., including ground water
monitoring programs)
F.
List of corrective action documents (including corporate and sub-tiered systems) written
since date of last inspection, associated with:
1.  Radioactive effluents
2.  Effluent radiation monitors
3.  Engineered Safety Feature Air cleaning systems
NOTE: The lists should indicate the significance level of each issue and the search
criteria used.  Please provide in document formats which are searchable so that
the inspector can perform word searches.
G.
2015 and 2016 Annual Radioactive Effluent Release Report, or the two most recent
reports.
H.
Current Copy of the Offsite Dose Calculation Manual
I.
Copy of the 2015 and 2016 inter-laboratory comparison results for laboratory quality
control performance of effluent sample analysis, or the two most recent results. 
J.
Effluent sampling schedule for the week of the inspection
K.
New entries into 10 CFR 50.75(g) files since date of last inspection


===Procedures===
: Number Title Revision 04-1-01-N65-1-SU System Operating Instruction Offgas Vault Refrigeration 033 06-CH-1000-M-0049 Effluent Dose Calculations 104 06-CH-1D17-M-0003 Building Ventilation Gaseous Tritium 109
: 06-CH-1D17-M-0005 Building Ventilation Exhaust Gaseous Isotopic 109
: 06-CH-1D17-M-0018 Gaseous Release Points - Particulate Alpha Activity 108 06-CH-1D17-W-0017 Gaseous Release Points - Iodines, Tritium and Particulates 106 06-CH-1T48-M-0037 Standby Gas Treatment Exhaust Gaseous Isotopic 107 06-CH-SG17-O-0045 Radwaste Release Post-Release Calculations 105 06-CH-SG17-P-0041 Radwaste Release Pre-Release Analysis 109 06-CH-SG17-Q-0044 Radwaste Release Quarterly Composite 103
A2-5
: 08-S-03-10 Chemistry Sampling Program 052
L.
: 08-S-03-22 Installed Radiation Monitoring System Alarm Setpoint Determination and Control 114 1-S-08-11 Radioactive Discharge Controls 114
Operations department (or other responsible dept.) log records for effluent monitors
: EN-CY-108 Monitoring of Nonradioactive Systems 006
removed from service or out of service
: Audits and Self-Assessments Number Title Date
M.
: LO-GLO-2016-0122 Pre-NRC RETS/ODCM Radiological Effluent Occurrences Assessment December 4, 2016
Listing or log of liquid and gaseous release permits since date of last inspection
: Teledyne Brown Engineering Environmental Services April 19, 2017
N.
: QA-2-6-2015-GGNS-1 GGNS Combined Chemistry Effluent and Environmental Monitoring (including ODCM and REMP) Program Audit
A list of the technical specification-required air cleaning systems with the two most
: October 9, 2015
recent surveillance test dates of in-place filter testing (of HEPA filters and charcoal
===Condition Reports (CR-GGNS-)===
adsorbers) and laboratory testing (of charcoal efficiency) and the work order numbers
: 2013-00450 2015-06763 2015-06764 2015-06982 2016-02468 2016-02688 2016-07187 2016-08307 2016-08308 2017-00051
associated with the surveillances
: 2017-00193 2017-00204 2017-00264 2017-00290 2017-00336 2017-00529 2017-03101 2017-03745 2017-04525 2017-05659 2017-06821 2017-06875     
O.
: 10
System Health Report for radiation monitoring instrumentation.  Also, please provide a
: CFR 50.75(g) Condition Reports (CR-GGNS-) 2015-06763 2015-06764 2016-07187 2017-00336
specific list of all effluent radiation monitors that were considered inoperable for 7 days
: Release Permits Liquid Releases
or more since November 2011. If applicable, please provide the relative Special Report
: 2015051
and condition report(s). 
: 2015094
P.
: 2016011
A list of all radiation monitors that are considered § 50.65/Maintenance Rule equipment.
: 2016017
Q.
: 2016022
A list of all significant changes made to the Gaseous and Liquid Effluent Process
: 2016040
Monitoring System since the last inspection.  If applicable, please provide the
: 2016042
corresponding UFSAR section in which this change was documented. 
: 2016044
R. 
: 2016045
A list of any occurrences in which a non-radioactive system was contaminated by a
: 2016051
radioactive system.  Please include any relative condition report(s).
: 2016073
: 2017009
: 2017018
: In-Place Filter Testing Records Number System Train Test Date
: WO 46551718 Standby Gas Treatment B DOP & HEPA June 3, 2017
: WO 52482060 Standby Gas Treatment A DOP & HEPA March 16, 2015
: WO 52618801 Control Room Air / Standby Fresh Air A DOP & HEPA October 27, 2016
: WO 52655772 Control Room Air / Standby Fresh Air B DOP & HEPA December 1, 2016 Miscellaneous Documents Number Title Revision Date
: 2014 Annual Radioactive Effluent Release Report April 27, 2015
: 2015 Annual Radioactive Effluent Release Report April 14, 2016
: 2016 Annual Radioactive Effluent Release Report April 25, 2017
: Cross Contamination of Service Air System /
: CR-GGN-2017-00193 February 27, 2017 Grand Gulf Service Air System I.E. Bulletin 80-10 Bounding Evaluation for Contamination of a Nonradioactive System March 29, 2017
: Nuclear Independent Oversight Functional Area Performance Report: Group B May 31, 2016
: Offsite Dose Calculation Manual 39 1000-1-17-002 2016 Radiochemistry INTRALAB Cross-Check Results January 23, 2017
: GNRO-2016/00039 Supplement to Grand Gulf Nuclear Station 2015 Annual Radioactive Effluent Release Report (ARERR) July 20, 2016 SD N64/N65 Grand Gulf Nuclear Station System Description 2 UFSAR Chapter 11 GGN Updated Final Safety Analysis Report 2016-00


==Section 2RS7: Radiological Environmental Monitoring Program==
A2-6
7.
Radiological Environmental Monitoring Program (71124.07) 
Date of Last Inspection:
March 27, 2015
A.
List of contacts and telephone numbers for the following areas:
1. Radiological environmental monitoring
2. Meteorological monitoring
B.
Applicable organization charts
C.
Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs
written since date of 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:  
1. Radiological environmental monitoring program
2. Meteorological monitoring program
E.
Please provide specific procedures related to the following areas noted below. 
Additional Specific Procedures will be requested by number after the inspector reviews
the procedure indexes. 
1. Environmental Program Description
2. Sampling, collection and preparation of environmental samples
3. Sample analysis (if applicable) 
4. Laboratory instrumentation quality control
5. Procedures associated with the Offsite Dose Calculation Manual
6. Appropriate QA Audit and program procedures, and/or sections of the stations QA
manual (which pertain to the REMP)
F.
A summary list of corrective action documents (including corporate and sub-tiered
systems) written since date of last inspection, related to the following programs:
1. Radiological environmental monitoring
2. Meteorological monitoring
NOTE: The lists should indicate the significance level of each issue and the search
criteria used.  Please provide in document formats which are searchable so that
the inspector can perform word searches.
G.
Wind Rose data and evaluations used for establishing environmental sampling locations
H.
Copies of the 2 most recent calibration packages for the meteorological tower
instruments 
I.
Copy of the 2015 and 2016 Annual Radiological Environmental Operating Report and
Land Use Census, and current revision of the Offsite Dose Calculation Manual, or the
two most recent reports.


===Procedures===
: Number Title Revision 06-EN-S000-V-0001 Surveillance Procedure Radiological Environmental Sampling 111 06-IC-SC84-SA-1003 Primary Tower Wind Speed/Direction, Air Temperature (T/dT) and Relative Humidity 106 07-S-53-C84-7 Backup Tower Wind/Speed/Direction and Air Temperature Calibration 0 08-S-04-964 Met Data Processing
: 2 ODCM Offsite Dose Calculation Manual 39
: Audits and Self-Assessments Number Title Date
A2-7  
: LO-GLO-2015-00042 Focused Self-Assessment: Chemistry Groundwater/Environmental Programs November 18, 2015 2015 Environmental Dosimetry Company Quality Assurance Status Report February 29, 2016 2015 Teledyne Brown Engineering:
J.
: Environmental Services Quality Assurance Report May 9, 2016 2016 Environmental Dosimetry Company Quality Assurance Status Report March 8, 2017 2016 Teledyne Brown Engineering:
Copy of the environmental laboratorys inter-laboratory comparison program results for
: Environmental Services Quality Assurance Report April 19, 2017
2015 and 2016, or the two most recent results, if not included in the annual radiological
===Condition Reports (CR-GGNS-)===
environmental operating report
: 2015-04675 2015-05753 2015-06263 2015-06763 2016-03213 2016-03475 2016-03825 2016-05543 2016-07187 2016-07747
K.
: 2016-08364 2016-09067 2017-00813 2017-00993 2017-01731
Data from the environmental laboratory documenting the analytical detection sensitivities
: 2017-02633 2017-05447     
for the various environmental sample media (i.e., air, water, soil, vegetation, and milk)  
: REMP Air Sampler Calibration Data
L.
: Number Title Date
Quality Assurance audits (e.g., NUPIC) for contracted services 
: CHEM-001
M.
: LV-1D - Air Sampler (LOVOL) July 21, 2016
Current NEI Groundwater Initiative Plan and status
: CHEM-002
N. 
: LV-1D - Air Sampler (LOVOL) October 20, 2016
Technical requirements manual or licensee controlled specifications which lists the
: CHEM-003
meteorological instruments calibration requirements
: LV-1D - Air Sampler (LOVOL) July 19, 2016
O.
: Meteorological Instrument Calibration Records W/O Number Title Date
A list of Regulatory Guides and/or NUREGs that you are currently committed to relative
: 52652328 Backup Meteorological Tower Instrument Calibration 07-S-53-C84-7 August 29, 2016
to the Radiological Environmental Monitoring Program.  Please include the revision
: 52692658 Primary Meteorological Tower Instrument Calibrations
and/or date for the committed item and where this can be located in your current
: 06-IC-SC84-SA-1003
licensing basis/UFSAR. 
: August 2, 2016
P.
: Meteorological Data Number Title Date 2016 ODCM Annual Average Relative Concentration (/Q) and Relative Deposition (D/Q) March 2017 2016 Review of Grand Gulf Meteorological Data
If applicable, per NEI 07-07, provide any reports that document any spills/leaks to
: March 9, 2017
groundwater since the last inspection
: Groundwater Protection Documents Number Title Revision / Date L71506 Groundwater Monitoring Report - January 2017 February 3, 2017 L71974 Groundwater Monitoring Report - February 2017 March 31, 2017 L72140 Groundwater Monitoring Report - March 2017 March 31, 2017 L72521 Groundwater Monitoring Report - April 2017 May 5, 2017
: R06045-0032-002 Groundwater Monitoring Plan 6
===Miscellaneous Documents===
: Number Title Date 2015 Annual Environmental Operating Report April 19, 2016 2016 Annual Environmental Operating Report April 27, 2017
: 2016 Land Use Census December 16, 2016
: 2017-044 Licensing Basis Document Change Request (LBDCR) April 27, 2017


==Section 2RS8: Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage, and Transportation==
A2-8
8.
Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage,  
and Transportation (71124.08) 
Date of Last Inspection:
March 27, 2015
A.
List of contacts and telephone numbers for the following areas:
1. Solid Radioactive waste processing
2. Transportation of radioactive material/waste
B.
Applicable organization charts (and list of personnel involved in solid radwaste
processing, transferring, and transportation of radioactive waste/materials)
C.
Copies of audits, department self-assessments, and LERs written since date of last
inspection related to:
1. Solid radioactive waste management
2. Radioactive material/waste transportation program
D.
Procedure index for the following areas:
1. Solid radioactive waste management
2. Radioactive material/waste transportation 
E.
Please provide specific procedures related to the following areas noted below. 
Additional Specific Procedures will be requested by number after the inspector reviews
the procedure indexes. 
1. Process control program
2. Solid and liquid radioactive waste processing 
3. Radioactive material/waste shipping 
4. Methodology used for waste concentration averaging, if applicable
5. Waste stream sampling and analysis
F.
A summary list of corrective action documents (including corporate and sub-tiered
systems) written since date of last inspection related to:
1. Solid radioactive waste
2. Transportation of radioactive material/waste
NOTE: The lists should indicate the significance level of each issue and the search
criteria used.  Please provide in document formats which are searchable so that
the inspector can perform word searches.
G.
Copies of training lesson plans for 49 CFR 172, Subpart H, for radwaste processing,
packaging, and shipping.
H.
A summary of radioactive material and radioactive waste shipments made from date of
last inspection to present
I.
Waste stream sample analyses results and resulting scaling factors for 2015 and 2016,
or the two most recent results.
J.
Waste classification reports if performed by vendors (such as for irradiated hardware)


===Procedures===
   
: Number Title Revision
   
: EN-RW-101 Radioactive Waste Management 3
   
: EN-RW-102 Radioactive Shipping Procedure 15
A2-9
: EN-RW-103 Radioactive Waste Tracking Procedure 4
K.  
: EN-RW-104 Scaling Factors 13
A listing of all on-site radwaste storage facilities. Please include a summary or listing of  
: EN-RW-105 Process Control Program 5
the items stored in each facility, including the total amount of radioactivity and the  
: EN-RW-106 Integrated Transportation Security Plan 6
highest general area dose rate.  
: 04-S-01-G17-3 Radwaste Filters and Demineralizer 47
Although it is not necessary to compile the following information, the inspector will also review:  
: 08-S-06-50 Radwaste Instruction:
L.  
: Loading Radioactive Material 9 08-S-06-71 Radwaste Instruction: Sampling Procedures for Waste Classification 7 07-S-14-428 Operation and Maintenance of the
Training, and qualifications records of personnel responsible for the conduct of  
: TRI-NUC Underwater Filtration System 0 08-S-02-075 Radiation Protection Instruction - Coverage and Control of Refueling Operations and Movement of Irradiated Materials 16
radioactive waste processing, package preparation, and shipping
: Audits and Self-Assessments Number Title Date
: QA-1 4/15-2015-GGN-1 Combined Radiation Protection and Radwaste September 14, 2015
: LO-GLO-2017-00022 Pre-NRC Inspection Module 71124-08 May 24, 2017
: LO-GLO-2015-00139 10 CFR Part 37 Materials Security Review January 8, 2016
===Condition Reports (CR-HQN-)===
: 2015-00747 2017-00904
===Condition Reports (CR-GGNS-)===
: 2015-00231 2015-05082 2016-00319 2016-00320 2016-00801 2016-00804 2016-00805 2016-00809 2016-04376 2017-00101
: 2017-00106 2017-01568 2017-01625 2017-01644 2017-04789 2017-05552 2017-06772 2017-06779   
: Radioactive Material and Waste Shipments Number Title Date
: GGN-2017-0101 CFFF Filters -
: LSA-II January 12, 2017
: GGN-2017-0102
: CRD-CRDM-
: LSA-II January 13, 2017
: GGN-2017-0106 CPS Powdex Liner January 20, 2017
: GGN-2016-0319 WMG Sealands March 16, 2016
: GGN-2016-0320 Suppression Pool Filter Liners March 21, 2016
: GGN-2016-0324 5 Type A GE Boxes March 23, 2016
: GGN-2015-0801
: RWCU-A Liner - Type B August
: 3, 2017
: GGN-2015-0805
: RWCU-A Liner - Type B August
: 3, 2017
: GGN-2015-0809
: RWCU-A Liner - Type B August 16, 2017
===Miscellaneous Documents===
: Number Title Date
: OE-NOE-2016-00
: NRC-RIS-2016-11 November 30, 2016 2017 RW/RAM Shipping Log January 1, 2017
: 2016 RW/RAM Shipping Log January 1, 2016
: 2015 RW/RAM Shipping Log January 1, 2015
: UFSAR Chapter 11 GGN Updated Final Safety Analysis Report 2016
: Management Standard No. 36 April 25, 2017
: Monitoring & Responding to Dose Rates on the Fuel Pools April 14, 2016
: 2015 Annual Radioactive Effluent Release Report April 25, 2017
: 2016 Annual Radioactive Effluent Release Report June 13, 2017
: Radioactive Material Storage Container Tracking Sheets The following items are requested for the Occupational/Public Radiation Safety Inspection at Grand Gulf Nuclear Station July 10 to 14, 2017 Integrated Report
: 2017007
: Inspection areas are listed in the attachments below.
: Please provide the requested information on or before June 14, 2017.
: Please submit this information using the same lettering system as below.
: For example, all contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled "1- A," applicable organization charts in file/folder "1- 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 Martin Phalen at (817) 200-1158 or martin.phalen@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: March 27, 2015
: A. List of contacts and telephone numbers for the following areas: 1. Effluent monitor calibration 2. Radiation protection instrument calibration
: 3. Installed instrument calibrations
: 4. Count room and Laboratory instrument calibrations B. Applicable organization charts C. Copies of audits, self-assessments, vendor or NUPIC audits for contractor support and LERs, written since date of last inspection, related to:
: 1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey instruments, electronic dosimeters, teledosimetry, personnel contamination monitors, or whole body counters
: 2. Installed radiation monitors D. Procedure index for: 1. Calibration, use and operation of continuous air monitors, criticality monitors, portable survey instruments, temporary area radiation monitors, electronic dosimeters, teledosimetry, personnel contamination monitors, and whole body counters. 2. Calibration of installed radiation monitors E. Please provide specific procedures related to the following areas noted below.
: Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes.
: 1. Calibration of portable radiation detection instruments (for portable ion chambers) 2. Whole body counter calibration 3. Laboratory instrumentation quality control F. A summary list of corrective action documents (including corporate and sub-tiered systems) written since date of last inspection, related to the following programs: 1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey instruments, electronic dosimeters, teledosimetry, personnel contamination monitors, whole body counters,
: 2. Installed radiation monitors,  
: 3. Effluent radiation monitors
: 4. Count room radiation instruments NOTE: The lists should indicate the significance level of each issue and the search criteria used.
: Please provide in document formats which are "searchable" so that the inspector can perform word searches. G. Offsite dose calculation manual, technical requirements manual, or licensee controlled specifications, which lists the effluent monitors and calibration requirements. H. Current calibration data for the whole body counters.
: I. Primary to secondary source calibration correlation for effluent monitors. J. A list of the point of discharge effluent monitors with the two most recent calibration dates and the work order numbers associated with the calibrations. K. Radiation Monitoring System health report for the previous 12 months   
: 6. Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
: Date of Last Inspection: March 27, 2015
: A. List of contacts and telephone numbers for the following areas: 1. Radiological effluent control 2. Engineered safety feature air cleaning systems B. Applicable organization charts
: C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs written since date of last inspection, related to: 1.
: Radioactive effluents 2.
: Engineered Safety Feature Air cleaning systems D. Procedure indexes for the following areas 1.
: Radioactive effluents 2.
: Engineered Safety Feature Air cleaning systems E. Please provide specific procedures related to the following areas noted below.
: Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes.
: 1. Sampling of radioactive effluents 2. Sample analysis 3. Generating radioactive effluent release permits 4. Laboratory instrumentation quality control
: 5. In-place testing of HEPA filters and charcoal adsorbers
: 6. New or applicable procedures for effluent programs (e.g., including ground water monitoring programs) F. List of corrective action documents (including corporate and sub-tiered systems) written since date of last inspection, associated with: 1.
: Radioactive effluents 2.
: Effluent radiation monitors
: 3.
: Engineered Safety Feature Air cleaning systems NOTE: The lists should indicate the significance level of each issue and the search criteria used.
: Please provide in document formats which are "searchable" so that the inspector can perform word searches. G. 2015 and 2016 Annual Radioactive Effluent Release Report, or the two most recent reports. H. Current Copy of the Offsite Dose Calculation Manual
: I. Copy of the 2015 and 2016 inter-laboratory comparison results for laboratory quality control performance of effluent sample analysis, or the two most recent results.
: J. Effluent sampling schedule for the week of the inspection
: K. New entries into 10
: CFR 50.75(g) files since date of last inspection  
: L. Operations department (or other responsible dept.) log records for effluent monitors removed from service or out of service M. Listing or log of liquid and gaseous release permits since date of last inspection N. 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 O. 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 November 2011.
: If applicable, please provide the relative Special Report and condition report(s).
: P. A list of all radiation monitors that are considered § 50.65/Maintenance Rule equipment.
: Q. A list of all significant changes made to the Gaseous and Liquid Effluent Process Monitoring System since the last inspection.
: If applicable, please provide the corresponding UFSAR section in which this change was documented.
: R.
: A list of any occurrences in which a non-radioactive system was contaminated by a radioactive system.
: Please include any relative condition report(s).   
: 7. Radiological Environmental Monitoring Program (71124.07)
: Date of Last Inspection: March 27, 2015
: A. List of contacts and telephone numbers for the following areas: 1. Radiological environmental monitoring 2. Meteorological monitoring B. Applicable organization charts
: C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs written since date of 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: 1. Radiological environmental monitoring program 2. Meteorological monitoring program E. Please provide specific procedures related to the following areas noted below.
: Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes.
: 1. Environmental Program Description 2. Sampling, collection and preparation of environmental samples
: 3. Sample analysis (if applicable)  
: 4. Laboratory instrumentation quality control
: 5. Procedures associated with the Offsite Dose Calculation Manual
: 6. Appropriate QA Audit and program procedures, and/or sections of the station's QA manual (which pertain to the REMP) F. A summary list of corrective action documents (including corporate and sub-tiered systems) written since date of last inspection, related to the following programs: 1. Radiological environmental monitoring 2. Meteorological monitoring NOTE: The lists should indicate the significance level of each issue and the search criteria used.
: Please provide in document formats which are "searchable" so that the inspector can perform word searches. G. Wind Rose data and evaluations used for establishing environmental sampling locations H. Copies of the 2 most recent calibration packages for the meteorological tower instruments
: I. Copy of the 2015 and 2016 Annual Radiological Environmental Operating Report and Land Use Census, and current revision of the Offsite Dose Calculation Manual, or the two most recent reports.
: J. Copy of the environmental laboratory's inter-laboratory comparison program results for 2015 and 2016, or the two most recent results, 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 Initiative Plan and status
: N.
: Technical requirements manual or licensee controlled specifications which lists the meteorological instruments calibration requirements O. A list of Regulatory Guides and/or NUREGs that you are currently committed to relative to the Radiological Environmental Monitoring Program.
: Please include the revision and/or date for the committed item and where this can be located in your current licensing basis/UFSAR.
: P. If applicable, per
: NEI 07-07, provide any reports that document any spills/leaks to groundwater since the last inspection 
: 8. Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage, and Transportation (71124.08)
: Date of Last Inspection: March 27, 2015
: A. List of contacts and telephone numbers for the following areas: 1. Solid Radioactive waste processing 2. Transportation of radioactive material/waste B. Applicable organization charts (and list of personnel involved in solid radwaste processing, transferring, and transportation of radioactive waste/materials) C. Copies of audits, department self-assessments, and LERs written since date of last inspection related to: 1. Solid radioactive waste management 2. Radioactive material/waste transportation program D. Procedure index for the following areas: 1. Solid radioactive waste management 2. Radioactive material/waste transportation
: E. Please provide specific procedures related to the following areas noted below.
: Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes.
: 1. Process control program 2. Solid and liquid radioactive waste processing 
: 3. Radioactive material/waste shipping 
: 4. Methodology used for waste concentration averaging, if applicable
: 5. Waste stream sampling and analysis F. A summary list of corrective action documents (including corporate and sub-tiered systems) written since date of last inspection related to: 1. Solid radioactive waste 2. Transportation of radioactive material/waste NOTE: The lists should indicate the significance level of each issue and the search criteria used.
: Please provide in document formats which are "searchable" so that the inspector can perform word searches. G. Copies of training lesson plans for 49
: CFR 172, Subpart H, for radwaste processing, packaging, and shipping. H. A summary of radioactive material and radioactive waste shipments made from date of last inspection to present I. Waste stream sample analyses results and resulting scaling factors for 2015 and 2016, or the two most recent results. J. Waste classification reports if performed by vendors (such as for irradiated hardware) 
: K. A listing of all on-site radwaste storage facilities.
: Please include a summary or listing of the items stored in each facility, including the total amount of radioactivity and the highest general area dose rate. Although it is not necessary to compile the following information, the inspector will also review: L. Training, and qualifications records of personnel responsible for the conduct of radioactive waste processing, package preparation, and shipping
}}
}}

Latest revision as of 12:51, 8 January 2025

NRC Radiation Protection Inspection Report 05000416/2017012 and Notice of Violation
ML17235B265
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 08/22/2017
From: Heather Gepford
Plant Support Branch-1
To: Emily Larson
Entergy Operations
References
IR 2017012
Download: ML17235B265 (36)
v • d • e


See also: IR 05000416/2017012

Text

August 22, 2017

Mr. Eric Larson, Site Vice President

Entergy Operations, Inc.

Grand Gulf Nuclear Station

P.O. Box 756

Port Gibson, MS 39150

SUBJECT: GRAND GULF NUCLEAR STATION - NRC RADIATION PROTECTION

INSPECTION REPORT 05000416/2017012 AND NOTICE OF VIOLATION

Dear Mr. Larson:

On July 14, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at

the Grand Gulf Nuclear Station and discussed the results of this inspection with you and other

members of your staff. The results of this inspection are documented in the enclosed report.

Based on the results of this inspection, the NRC has identified two issues that were evaluated

under the risk significance determination process as having very low safety significance

(Green). The NRC also determined that one violation is associated with these issues.

This violation was evaluated in accordance with the NRC Enforcement Policy. The

current Enforcement Policy is included in the NRCs Web site at http://www.nrc.gov/about-

nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in the enclosed Notice of

Violation (Notice) and the circumstances surround it are described in detail in the subject

inspection report. The violation is being cited because this violation did not meet the criteria to

be treated as a non-cited violation because the licensee failed to restore compliance within a

reasonable period of time after it was identified.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. If you have additional information that you

believe the NRC should consider, you may provide it in your response to the Notice. The NRC

review of your response will also determine whether further enforcement action is necessary to

ensure your compliance with regulatory requirements.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a

regulatory requirement 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.

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD

ARLINGTON, TX 76011-4511

E. Larson

2

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter will be

made available for public inspection in the NRC Public Document Room from the NRCs Agency

wide Documents Access and Management System (ADAMS), accessible from the NRC Web

site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should

not include any personal, privacy, or proprietary information so that it can be made available to

the public without redaction.

Sincerely,

/RA/

Heather J. Gepford, Ph.D., CHP, Branch Chief

Plant Support Branch 1

Division of Reactor Safety

Docket No. 50-416

License No. NPF-29

Enclosure:

Inspection Report 05000416/2017012

w/Attachments:

1. Supplemental Information

2. Request for Information

ML17235B265

SUNSI Review

ADAMS:

Non-Publicly Available

Non-Sensitive

Keyword:

By: HGepford

Yes No

Publicly Available

Sensitive

NRC-002

OFFICE

SHP:PSB2

HP:PSB2

HP:PSB2

SHP:RIII

C:PSB2

C:PSB2

NAME

LCarson

NGreene

JODonnell

TGo

HGepford

JKozal

SIGNATURE

/RA/

/RA/

/RA/

/RA/

/RA/

/RA/

DATE

8/17/17

8/17/17

8/17/17

8/17/17

8/17/17

8/22/17

OFFICE

ACES

C:PSB2

NAME

MHay

HGepford

SIGNATURE

/RA/

/RA/

DATE

8/22/17

8/22/17

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket:

05000416

Report:

05000416/2017012

Facility:

Grand Gulf Nuclear Station

Dates:

July 10 through July 14, 2017

Inspectors:

L. Carson II, Sr. Health Physicist

N. Greene, PhD, Health Physicist

J. ODonnell, CHP, Health Physicist

T. Go, Health Physicist (RIII)

Accompanied by S. Money, Health Physicist

Approved By:

Heather Gepford, PhD, CHP

Chief, Plant Support Branch 2

Division of Reactor Safety

2

NOTICE OF VIOLATION

Entergy Operations, Inc.

Docket No. 05000416

Grand Gulf Nuclear Station

License No. NPF-29

During an NRC inspection conducted from July 10-14, 2017, a violation of NRC requirements

was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

10 CFR 20.1501(c) requires, in part, that the licensee shall ensure that instruments and

equipment used for quantitative radiation measurements are calibrated periodically for

the radiation measured.

Contrary to the above, since January 1, 2012, the licensee failed to ensure that

instruments and equipment used for quantitative radiation measurements were

calibrated periodically for the radiation measured. Specifically, the licensee failed to

properly calibrate the containment/drywell high range radiation monitors and the main

steam line radiation monitors using industry accepted calibration methods and

tolerances.

This violation is associated with a Green SDP finding.

Pursuant to the provisions of 10 CFR 2.201, Entergy Operations, Inc., is hereby required to

submit a written statement or explanation to the U.S. Nuclear Regulatory Commission,

ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional

Administrator, Region IV, 1600 E. Lamar Blvd., Arlington, TX 76011, and a copy to the NRC

Resident Inspector at the Grand Gulf Nuclear Station, within 30 days of the date of the letter

transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to

a Notice of Violation" and should include for the violation: (1) the reason for the violation or, if

contested, the basis for disputing the violation or severity level, (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

previous docketed correspondence if the correspondence adequately addresses the required

response. If an adequate reply is not received within the time specified in this Notice, an order

or a Demand for Information may be issued as to why the license should not be modified,

suspended, or revoked, or why such other action as may be proper should not be taken. Where

good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response with the

basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory

Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the

NRC Public Document Room or from the NRCs document system (ADAMS), accessible from

the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should

not include any personal privacy, proprietary, or safeguards information so that it can be made

available to the public without redaction. If personal privacy or proprietary information is

necessary to provide an acceptable response, then please provide a bracketed copy of your

response that identifies the information that should be protected and a redacted copy of your

response that deletes such information. If you request withholding of such material, you must

specifically identify the portions of your response that you seek to have withheld and provide in

3

detail the bases for your claim of withholding (e.g., explain why the disclosure of information will

create an unwarranted invasion of personal privacy or provide the information required by

10 CFR 2.390(b) to support a request for withholding confidential commercial or financial

information). If Safeguards Information is necessary to provide an acceptable response, please

provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working

days of receipt.

Dated this 22nd day of August 2017

4

SUMMARY

IR 05000416/2017012; 07/10/2017 - 07/14/2017; Grand Gulf Nuclear Station; Radiation

Monitoring Instrumentation (71124.05), Radioactive Gaseous and Liquid Effluent Treatment

(71124.06)

Cornerstone: Public Radiation Safety

Green. The inspectors identified a violation of 10 CFR 20.1501(c) for the failure

to properly calibrate installed radiation monitors using industry accepted calibration

methods and tolerances. Specifically, since January 2012, the licensee failed to

properly calibrate the following radiation monitors: main steam line, containment

high range, and the drywell high range. This violation was originally entered into

the licensees corrective action program in March 2015 as Condition

Report CR-GGNS-2015-01832. However, in 2017, inspectors determined that

subsequent to 2015, the licensee failed to implement corrective actions to properly

calibrate the instruments. The licensee entered this repetitive issue into their corrective

action process as Condition Report CR-GGN-2017-06826.

The failure to properly calibrate radiation monitors is a performance deficiency. The

performance deficiency is more than minor because it is associated with the cornerstone

attribute of plant instrumentation and adversely affects the cornerstone objective to

ensure adequate protection of employee health and safety during routine civilian nuclear

reactor operation and is therefore a finding. Specifically, the failure to properly calibrate

radiation monitors impacts the licensees ability to assess dose rates. Using Inspection

Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance

Determination Process, dated August 19, 2008, the inspectors determined the finding to

be of very low safety significance because it was not an as low as reasonably achievable

(ALARA) issue, there was no overexposure or substantial potential for overexposure,

and the licensees ability to assess dose was not compromised. This finding has a

cross-cutting aspect in the resources component of the Problem Identification and

Resolution area because the licensee did not ensure that effective corrective actions

were implemented to address issues in a timely manner commensurate with the safety

significance [P.3]. (Section 2RS5)

Green. The inspectors identified a finding associated with the licensees failure to

operate the gaseous radwaste system within design specifications. These deficiencies

in design specifications were associated with the off gas charcoal adsorber and vault

refrigeration components of the gaseous radwaste system, which has impacted the

systems reliability and efficiency since at least 2007. The design parameters for

offgas flow rate into the charcoal adsorbers and vault refrigeration temperature were

30 scfm and 0 degrees Fahrenheit, respectively. In contrast, the gaseous radwaste

system is being operated with an approximate flow rate is 80 scfm and vault refrigeration

temperature is 15 degrees Fahrenheit. The licensee has developed a system

improvement plan to address resolution of these issues during the next scheduled

outages. This performance deficiency was entered into the licensees corrective action

program as Condition Report CR-GGN-2017-06875.

5

The failure to operate the offgas gaseous radwaste system within design specifications,

resulting in elevated radiological effluent releases, is a performance deficiency. The

finding is more than minor because it is associated with the plant equipment attribute of

the Public Radiation Safety cornerstone and adversely affected the cornerstone

objective to ensure adequate protection of public health and safety from exposure of

radioactive materials released into the public domain as a result of routine civilian

nuclear plant operation. Using Inspection Manual Chapter 0609, Appendix D, Public

Radiation Safety Significance Determination Process, the finding was determined to be

of very low safety significance (Green) because it involved the Effluent Release

Program, it did not impair the ability to assess dose, and did not exceed the

10 CFR Part 50, Appendix I, or 10 CFR 20.1301(d) limits. The finding has a

cross-cutting aspect in the area of problem identification and resolution, associated with

the resolution component, because the licensee failed to take effective corrective actions

in a timely manner to minimize the unreliability and inefficiency of the gaseous radwaste

system [P.3]. (Section 2RS6)

6

REPORT DETAILS

2.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS5 Radiation Monitoring Instrumentation (71124.05)

a.

Inspection Scope

The inspectors evaluated the accuracy and operability of the radiation monitoring

equipment used by the licensee to monitor areas, materials, and workers to ensure a

radiologically safe work environment. This evaluation included equipment used to

monitor radiological conditions related to normal plant operations, anticipated operational

occurrences, and conditions resulting from postulated accidents. The inspectors

interviewed licensee personnel, walked down various portions of the plant, and reviewed

licensee performance associated with radiation monitoring instrumentation, as described

below:

The inspectors performed walk downs and observations of selected plant

radiation monitoring equipment and instrumentation, including portable survey

instruments, area radiation monitors, continuous air monitors, personnel

contamination monitors, portal monitors, and small article monitors. The

inspectors assessed material condition and operability, evaluated positioning of

instruments relative to the radiation sources or areas they were intended to

monitor, and verified performance of source checks and calibrations.

The inspectors evaluated the calibration and testing program, including

laboratory instrumentation, whole body counters, post-accident monitoring

instrumentation, portal monitors, personnel contamination monitors, small article

monitors, portable survey instruments, area radiation monitors, electronic

dosimetry, air samplers, and continuous air monitors.

The inspectors assessed problem identification and resolution for radiation

monitoring instrumentation. The inspectors reviewed audits, self-assessments,

and corrective action program documents to verify problems were being

identified and properly addressed for resolution.

These activities constitute completion of the three required samples of radiation

monitoring instrumentation, as defined in Inspection Procedure 71124.05.

b.

Findings

Introduction. The inspectors identified a violation of 10 CFR 20.1501(c) for the failure to

properly calibrate installed radiation monitors using industry accepted calibration

methods and tolerances. Specifically, the main steam line, containment high range, and

drywell high range radiation monitors have not been properly calibrated since at least

January 2012. This violation was originally entered into the licensees corrective action

program in March 2015 as Condition Report CR-GGNS-2015-01832. However, in 2017,

inspectors determined that the licensee failed to implement appropriate corrective

7

actions to properly calibrate the instruments. The licensee entered this repetitive issue

into their corrective action process as Condition Report CR-GGN-2017-06826.

Description. The failure to properly calibrate the main steam line and

containment/drywell high range area radiation monitors was previously identified

and documented as a non-cited violation during an inspection in March of 2015:

NCV 05000416/2015001-04, Failure to Properly Calibrate Main Steam Line Radiation

Monitors and Containment/Drywall High Range Radiation Monitors.

During this inspection, the inspectors reviewed the revised calibration procedures and

calibration data for main steam line, containment high range, and drywell high range

radiation monitors. The main steam line radiation monitors provide reactor operators

with early indication of gross release of fission products from the fuel. This monitor has

an automatic response function that isolates the reactor water sample line to limit the

release of radioactive materials. The containment high range and drywell high radiation

monitors provide reactor operators and emergency response organization members

information about the radiological conditions inside the containment building and the

drywell. This information is used to make informed decisions about what actions to take

during an accident as well as make emergency declarations. As such, it is important

that these radiation monitors be properly calibrated. However, it was determined that

the improper calibrations did not adversely affect the licensees ability to implement the

Emergency Plan.

Based on their review of the current revisions of the applicable procedures, corrective

action documents, and calibration data, the inspectors determined that the licensee had

not corrected the calibration method from the previous non-cited violation. The licensee

procedures did not address the required reproducible source-to-detector geometry or the

characterization of the calibration sources used. Additionally, because the main steam

line monitor calibration requires two different sources in the procedure, each source

should have been characterized in a reproducible geometry.

The licensee revised Procedure 06-IC-1D17-R-1002, Main Steam Line High Radiation

Monitor (PCIS) Calibration, Revision 109, on April 3, 2017. The previous revision (108)

was dated December 13, 2011. Section 5.37 of this procedure describes the radiation

calibration method. The calibration method, as described in this section, fails to employ

a reproducible geometry or calibrated radiation sources. Further, the calibration method,

as described in this section, only addresses calibration of two of the six decades of the

logarithmic monitor.

The licensee also revised Procedure 06-IC-1D21-R-1002, Containment/Drywell High

Range Area Radiation Monitor Calibration, Revision 108, on April 3, 2017. The

previous revision (107) was dated September 12, 2011. Section 5.87 describes the

radiation functional test portion of this procedure. The calibration method described in

this section fails to employ a reproducible geometry or a calibrated radiation source.

Further, the acceptance criteria in this section are twice that allowed in American

National Standards Institute (ANSI) N323D-2002, American National Standard for

Installed Radiation Protection Instrumentation, approved on September 3, 2002. In

addition, the electronic calibration method in this procedure as allowed by NUREG 0737,

Clarification of TMI Action Plan Requirements, dated November 1980, only addresses

calibration of three of the seven decades of the logarithmic monitor.

8

The inspectors concluded that the licensee had continued to improperly calibrate

these process radiation monitors since the previous inspection in March 2015.

Procedure 06-IC-1D17-R-1002 rocedure is used for all four channels of the main

steam line monitors and Procedure 06-IC-1D21-R-1002 is used for both channels of

the drywell and containment high range radiation monitors. Because both procedures

failed to use appropriate calibration methodologies, the inspectors determined that

none of the containment/drywell high range and main steam line radiation monitors

had been properly calibrated since at least the date of the procedure revisions,

September 12, 2011, and December 13, 2011, respectively.

In evaluating the underlying cause of the licensees failure to correct the calibration

issue, the inspectors noted the following. On January 20, 2017, a corrective action

document (CR-GGN-2017-00612) was initiated identifying a non-conforming condition of

a Condition Adverse to Quality that the calibration procedure for the containment high

range and drywell high radiation monitors does not control the source geometry to the

monitor. The CR further described the required calibration traceability not being

maintained. In the self-assessment report of the radiation protection instrument program

(OL-GLO-2017-21) completed on May 23, 2017, the assessment team rated Objective 2,

the review of the prior inspection report, as unsatisfactory. This rating was given

because actions related to this issue were not complete after a considerable amount of

time, which included at least five due date extensions and an extended outage that

should have allowed completion of the corrective action.

Analysis. The failure to properly calibrate radiation monitors is a performance

deficiency. The performance deficiency is more than minor because it is associated with

the cornerstone attribute of plant instrumentation and adversely affects the cornerstone

objective to ensure adequate protection of employee health and safety during routine

civilian nuclear reactor operation and is therefore a finding. Specifically, the failure to

properly calibrate radiation monitors impacts the licensees ability to assess dose rates.

Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety

Significance Determination Process, dated August 19, 2008, the inspectors determined

the finding to be of very low safety significance because it was not an as low as

reasonably achievable (ALARA) issue, there was no overexposure or substantial

potential for overexposure, and the licensees ability to assess dose was not

compromised. This finding has a cross-cutting aspect in the area of problem

identification and resolution, associated with the resolution component, because the

licensee did not ensure that effective corrective actions were implemented to address

issues in a timely manner commensurate with the safety significance [P.3].

Enforcement. Title 10 CFR 20.1501(c) requires, in part, that the licensee shall

ensure that instruments and equipment used for quantitative radiation measurements

are calibrated periodically for the radiation measured. Contrary to the above, since at

least January 1, 2012, the licensee failed to ensure that instruments and equipment

used for quantitative radiation measurements were calibrated periodically for the

radiation measured. Specifically, the licensee failed to properly calibrate the

containment/drywell high range radiation monitors and the main steam line

radiation monitors using industry accepted calibration methods and tolerances.

This issue was entered into the licensees corrective action program as Condition

Report CR-GGN-2017-06826.

9

This issue was previously identified during an inspection in March of 2015, as

NCV 05000416/2015001-04 and was treated as a non-cited violation, consistent with

Section 2.3.2.a of the Enforcement Policy. Since the licensee did not restore

compliance in a reasonable period of time, this violation is being cited, consistent with

the NRC Enforcement Policy, Section 2.3.2, which states, in part, that the licensee must

restore compliance within a reasonable period of time (i.e., in a timeframe

commensurate with the significance of the violation) after a violation is identified. A

Notice of Violation is attached. VIO 05000416/2017012-01, Failure to Properly

Calibrate Installed Radiation Monitors Using Industry Accepted Calibration Methods and

Tolerances.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

a.

Inspection Scope

The inspectors evaluated whether the licensee maintained gaseous and liquid effluent

processing systems and properly mitigated, monitored, and evaluated radiological

discharges with respect to public exposure. The inspectors verified that abnormal

radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors

are out-of-service, were controlled in accordance with the applicable regulatory

requirements and licensee procedures. The inspectors verified that the licensees

quality control program ensured radioactive effluent sampling and analysis adequately

quantified and evaluated discharges of radioactive materials. The inspectors verified the

adequacy of public dose projections resulting from radioactive effluent discharges. The

inspectors interviewed licensee personnel and reviewed licensee performance in the

following areas:

During walk downs and observations of selected portions of the radioactive

gaseous and liquid effluent equipment, the inspectors evaluated routine

processing and discharge of effluents, including sample collection and analysis.

The inspectors observed equipment configuration and flow paths of selected

gaseous and liquid discharge system components, effluent monitoring systems,

filtered ventilation system material condition, and significant changes to effluent

release points.

Calibration and testing program for process and effluent monitors, including

National Institute of Standards and Technology traceability of sources, primary

and secondary calibration data, channel calibrations, set-point determination

bases, and surveillance test results.

Sampling and analysis controls used to ensure representative sampling and

appropriate compensatory sampling. Reviews included results of the inter-

laboratory comparison program,

Instrumentation and equipment, including effluent flow measuring instruments, air

cleaning systems, and post-accident effluent monitoring instruments.

Dose calculations for effluent releases. The inspectors reviewed a selection of

radioactive liquid and gaseous waste discharge permits and abnormal gaseous

or liquid tank discharges, and verified the projected doses were accurate. The

10

inspectors also reviewed 10 CFR Part 61 analyses and methods used to

determine which isotopes were included in the source term. The inspectors

reviewed land use census results, offsite dose calculation manual changes, and

significant changes in reported dose values from previous years.

Problem identification and resolution for radioactive gaseous and liquid effluent

treatment. The inspectors reviewed audits, self-assessments, and corrective

action program documents to verify problems were being identified and properly

addressed for resolution.

These activities constitute completion of the six required samples of radioactive gaseous

and liquid effluent treatment program, as defined in Inspection Procedure 71124.06.

b.

Findings

Introduction. The inspectors identified a Green finding for the licensees failure to

operate their gaseous radwaste system within design specifications, resulting in elevated

radiological effluent releases that were not as low as reasonably achievable. These

deficiencies in meeting the design specifications/parameters are associated with the

offgas charcoal adsorber and vault refrigeration components of the offgas system, which

have impacted the systems reliability and efficiency since at least 2007.

Description. When reviewing the licensees annual effluent release reports, the

inspectors identified that in calendar year 2013, the licensee had total airborne releases

of fission and activation gases of 1920 curies (Ci), including a peak release of 1540 Ci

during the third quarter. The inspectors noted that this annual gaseous release was

significantly higher than the previous annual releases of approximately 450 Ci in

calendar years 2010 thru 2012. The licensee stated the primary reason for the elevated

activity of gaseous releases was associated with refrigeration equipment issues affecting

charcoal adsorption efficiency. Upon further evaluation, NRC inspectors determined that

such issues with the charcoal adsorbers and vault refrigeration systems were long-term,

ongoing, unresolved deficiencies in the gaseous radwaste system primarily due to

numerous condenser in-leakages that remain unrepaired.

The Grand Gulf Nuclear Station System Description, Revision 2, for the gaseous

radwaste system notes that there are two sets of four charcoal adsorber vessels

arranged in series, totaling eight charcoal adsorber beds. As the offgas flows from the

condenser system via the steam jet air ejectors into the charcoal adsorption system, the

charcoal acts as a medium to delay the flow of krypton and xenon gases to allow them to

decay to radiation levels acceptable for atmospheric release. In addition, the activated

charcoal adsorbs the radioactive isotopes of iodine removing them for decay.

The adsorption of xenon, krypton, and iodine offgas on charcoal depends on gas

flowrate, holdup time, mass of charcoal, and the dynamic adsorption coefficient. The

inspectors determined the nominal flowrate for the licensees charcoal system to operate

efficiently is specified as 30 scfm, to achieve proper holdup times of offgases. However,

the licensee has been consistently running the system at 80 scfm.

The Grand Gulf Nuclear Station System Description also states the charcoal adsorbers

must be operated under controlled temperature and humidity conditions, maintaining a

steady state temperature of about 0 degrees Fahrenheit (°F). However, for optimal

11

performance, a refrigeration temperature of 0 to -40°F is specified. The inspectors

reviewed Figure 10 of Section 4.1.7 of Grand Gulf Nuclear Station System Description,

entitled Comparative Curie Decontamination Factors for 8, 12, and 16 Bed Systems,

which illustrated that the charcoal low temperature, eight bed system is designed to

operate at a decontamination factor of 1000 with the specified design parameters

(i.e., 30 scfm, 0ºF). However, the inspectors determined licensees current offgas

flowrate of approximately 80 scfm and refrigeration temperature of approximately +15°F

will achieve a decontamination factor of less than 50.

The licensee performed evaluations, as documented in Apparent Cause

Evaluation CR-GGN-2013-0450, and determined that corrective actions were needed to

decrease the current elevated offgas flowrate into the charcoal adsorbers from

approximately 80 scfm, and to reduce the vault refrigeration temperature to within

design specifications. The licensee implemented some corrective actions to reduce

condenser in-leakage, resulting in some improvement in the offgas flowrate (reduction

from ~160 scfm to ~80 scfm). However, the offgas flowrates, charcoal adsorber

flowpath, and refrigeration vault operations still remain inconsistent with the design

specifications.

Although these deficiencies were ongoing issues, the licensee provided no documented

evaluation to demonstrate that the degraded performance of the offgas system was

maintaining gaseous releases as low as reasonably achievable, which the Updated Final

Safety Analysis Report states is the primary design objective of the gaseous radwaste

management system. The NRC inspectors discussed with the licensee that, although

the airborne releases may meet the 10 CFR Part 20, Appendix I, limitations, the failure

to operate the system consistent with design parameters is significantly impacting the

systems ability to maintain gaseous releases as low as reasonably achievable, as

evidenced by the annual effluent reports.

The licensee has developed a system improvement plan entitled, Offgas Long Range

Plan and Concluding Actions, to address how the plant may resolve the issues within

the next few scheduled outages. This performance deficiency was entered into the

licensees CAP as Condition Report CR-GGN-2017-06875.

Analysis. The failure to operate the offgas gaseous radwaste system within design

specifications, resulting in elevated radiological effluent releases, is a performance

deficiency. The finding is more than minor because it is associated with the plant

equipment attribute of the Public Radiation Safety cornerstone and adversely affected

the cornerstone objective to ensure adequate protection of public health and safety from

exposure of radioactive materials released into the public domain as a result of routine

civilian nuclear plant operation. Using Inspection Manual Chapter 0609, Appendix D,

Public Radiation Safety Significance Determination Process, the finding was

determined to be of very low safety significance (Green) because it involved the

Effluent Release Program, it did not impair the ability to assess dose, and did not

exceed the 10 CFR Part 50, Appendix I, or 10 CFR 20.1301(d) limits. The finding has a

cross-cutting aspect in the area of problem identification and resolution, associated with

the resolution component, because the licensee did not ensure that effective corrective

actions were implemented to address issues in a timely manner commensurate with the

safety significance [P.3].

12

Enforcement. The inspectors did not identify a violation of regulatory requirements.

Although the licensee failed to operate the system within the design specifications, as

described in the Grand Gulf Nuclear Station System Description, the inspectors

determined this was a self-imposed standard and did not constitute a regulatory

requirement. The issue was entered into the licensees corrective action program as

CR-GGN-2017-06875. Finding (FIN)05000416-2017012-02, Failure to Operate the

Gaseous Radwaste System Within Design Specifications.

2RS7 Radiological Environmental Monitoring Program (71124.07)

a.

Inspection Scope

The inspectors evaluated whether the licensees radiological environmental monitoring

program quantified the impact of radioactive effluent releases to the environment and

sufficiently validated the integrity of the radioactive gaseous and liquid effluent release

program. The inspectors also verified that the licensee continued to implement the

voluntary NEI/Industry Ground Water Protection Initiative. The inspectors reviewed or

observed the following items:

The inspectors observed selected air sampling and dosimeter monitoring

stations, sampler station modifications, and the collection and preparation of

environmental samples. The inspectors reviewed calibration and maintenance

records for selected air samplers, composite water samplers, and environmental

sample radiation measurement instrumentation, and inter-laboratory comparison

program results. The inspectors reviewed selected events documented in the

annual environmental monitoring report and significant changes made by the

licensee to the offsite dose calculation manual as the result of changes to the

land census. The inspectors evaluated the operability, calibration, and

maintenance of meteorological instruments and assessed the meteorological

dispersion and deposition factors. The inspectors verified the licensee had

implemented sampling and monitoring program sufficient to detect leakage from

structures, systems, or components with credible mechanism for licensed

material to reach ground water and reviewed changes to the licensees written

program for identifying and controlling contaminated spills/leaks to groundwater.

Groundwater protection initiative (GPI) implementation, including assessment of

groundwater monitoring results, identified leakage or spill events and entries

made into 10 CFR 50.75 (g) records, licensee evaluations of the extent of the

contamination and the radiological source term, and reports of events associated

with spills, leaks, and groundwater monitoring results.

Problem identification and resolution for the radiological environmental

monitoring program. The inspectors reviewed audits, self-assessments, and

corrective action program documents to verify problems were being identified

and properly addressed for resolution.

These activities constitute completion of the three required samples of radiological

environmental monitoring program, as defined in Inspection Procedure 71124.07.

13

b.

Findings

No findings were identified.

2RS8

Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08)

a.

Inspection Scope

The inspectors evaluated the effectiveness of the licensees programs for processing,

handling, storage, and transportation of radioactive material. The inspectors interviewed

licensee personnel and reviewed the following items:

Radioactive material storage, including waste storage areas including container

labeling/marking and monitoring containers for deformation or signs of waste

decomposition.

Radioactive waste system, including walk-downs of the accessible portions of the

radioactive waste processing systems and handling equipment. The inspectors

also reviewed or observed changes made to the radioactive waste processing

systems, methods for dewatering and waste stabilization, waste stream mixing

methodology, and waste processing equipment that was not operational or

abandoned in place.

Waste characterization and classification, including radio-chemical sample

analysis results for radioactive waste streams and use of scaling factors and

calculations to account for difficult-to-measure radionuclides, and processes for

waste classification including use of scaling factors and 10 CFR Part 61

analyses.

Shipment preparation, including packaging, surveying, labeling, marking,

placarding, vehicle checking, driver instructing, and preparation of the disposal

manifests.

Shipping records for LSA I, II, III, SCOI, II, Type A, or Type B radioactive material

or radioactive waste shipments.

Problem identification and resolution for radioactive solid waste processing and

radioactive material handling, storage, and transportation. The inspectors

reviewed audits, self-assessments, and corrective action program documents to

verify problems were being identified and properly addressed for resolution.

These activities constitute completion of the six required samples of radioactive solid

waste processing, and radioactive material handling, storage, and transportation

program, as defined in Inspection Procedure 71124.08.

b.

Findings

No findings were identified.

14

4.

OTHER ACTIVITIES

4OA6 Meetings, Including Exit

Exit Meeting Summary

On July 14, 2017, the inspectors presented the radiation safety inspection results to

Mr. E. Larson, Site Vice President, and other members of the licensee staff. The licensee

acknowledged the issues presented. The licensee confirmed that any proprietary information

reviewed by the inspectors had been returned or destroyed.

Attachment 1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Ashley, Environmental Specialist, Chemistry

R. Benson, Acting Manager, Radiation Protection

D. Byers, Manager, System Engineering

R. Gaston, Director, Corporate Licensing

M. Giacini, General Manager, Plant Operations

A. Hasanat, Licensing Engineer, Regulatory Assurance

J. Hallanbeck, Design Manager, Engineering

E. Larson, Site Vice President

M. Larson, Supervisor, Radiation Protection

K. Long, Shipper, Radwaste

J. Reese, Specialist, Chemistry

T. Reeves, Supervisor, Chemistry

F. Rosser, Specialist, Radiation Protection

P. Stokes, Support Supervisor, Radiation Protection

S. Sweet, Licensing Engineer, Regulatory Assurance

E. Wright, Supervisor, Radiation Protection

J. Underwood, Manager, Chemistry

NRC Personnel

N. Day, Resident Inspector

R. Smith, Acting Senior Resident Inspector

M. Young, Senior Resident Inspector

S. Hedger, Emergency Preparedness Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened 05000416-2017012-01

VIO

Failure to Correct Instrument Calibration Process in a Timely

Manner (Section 2RS5)

Opened and Closed 05000416-2017012-02

FIN

Failure to Operate the Gaseous Radwaste System Within Design

Specifications (Section 2RS6)

Closed

None

Discussed

None

A1-2

LIST OF DOCUMENTS REVIEWED

Section 2RS5: Radiation Monitoring Instrumentation

Procedures

Number

Title

Revision

06-IC-1D17-R-1002

Main Steam Line High Radiation Monitor

(PCIS) Calibration

108, 109

06-IC-1D21-R-1002

Containment/Drywell High Range Area

Radiation Monitor Calibration

107, 108,109

08-S-07-83

Radiation Protection Instruction Operation

and Calibration of the ND-9000 Whole Body

Counter

10

EN-CY-102

Laboratory Analytical Quality Control

9

EN-FAP-RP-007

Operation of the RP Central Calibration

Facility

2

EN-MA-105

Control of Measuring and Test Equipment

(M&TE)

13

EN-RP-122

Alpha Monitoring

9

EN-RP-301

Radiation Protection Instrument Control

10

EN-RP-305

Source Maintenance

0

EN-RP-317

Central Calibration Facility

0

EN-RP-317-08

Calibration of Portable Scalers

1

EN-RP-317-09

Calibration of Dosimeters

2

EN-RP-317-10

Calibration of Portable Dose Rate Instrument 0

ODCM

Offsite Dose Calculation Manual

39

Audits and Self-Assessments

Number

Title

Date

OL-GLO-2017-21

Self-Assessment of RP Instrumentation

Program

May 23, 2017

QA-14/15-201 5-GGN-1 QA Audit: Combined Radiation Protection and

Radwaste

November 16, 2015

A1-3

Condition Reports (CR-GGNS-)

2015-01775

2015-01773

2015-02807

2015-01831

2015-01832

2016-01796

2016-04647

2016-05297

2016-08308

2016-09537

2016-09889

2017-00612

2017-04141

2017-04697

2017-06865

2017-06876

Installed Radiation Instrument Calibration Records

W/O Number

Title

Date

52628844

Main Steam Line High Radiation Monitor (PCIS)

Calibration - Channel A

February 22, 2017

52637367

Containment/Drywell High Range Area Radiation

Monitor Calibration - Channel A

March 16, 2016

Portable Radiation Instrument Calibration Records

Number

Title

Date

ASC-001

Calibration Data Sheet: SAC-4

March 28, 2017

CHP-C-015

Calibration Data Sheet: Model 2000(43-10) Alpha

Scaler

July 10 2017

CHP-C-022

Calibration Data Sheet: iSolo Alpha Scaler

April 27, 2017

CHP-CS-020

Calibration Data Sheet: iSolo Alpha Scaler

March 23, 2017

CHP-DR-283

Calibration Data Sheet: TelePole

June 13, 2017

HP-11431

Calibration Data Sheet: RO-2

June 6, 2017

HP-CS-004

Calibration Data Sheet: Model BC-4

July 6, 2017

HP-DR-563

Calibration Data Sheet: Model 9-3

December 12, 2016

HP-DR-563

Calibration Data Sheet: Ludlum Model-9-3

July 11, 2017

HP-DS-054

Calibration Data Sheet: Model SAC-4

July 10, 2017

RAM-001

Calibration Data Sheet: AMP-100

March 12, 2017

Stationary Radiation Instrument Calibration Records

Number

Title

Date

400-10-17-005

Germanium Detector No. 3 Calibration Package

March 23, 2017

400-11-17-005

Germanium Detector No. 4 Calibration Package

March 22, 2017

400-9-17-002

Germanium Detector No. 2 Calibration Package

March 15, 2017

A1-4

Stationary Radiation Instrument Calibration Records

Number

Title

Date

Apex-InVivo

Analysis Report Calibration Check Count of People

Mover Whole Body Monitor

July 12, 2017

Canberra

Calibration of the Canberra/Nuclear Data People

Mover WBC System at Entergy Grand Gulf Nuclear

Station

August 8, 2015

Other Radiation Protection Instrument Records

Number

Title

Date

CHP-DR-326

Instrument Response Check Failure Review

January 13, 2017

CHP-TEL039

Instrument Response Check Failure Review

May 15, 2017

CHP-TEL044

Instrument Response Check Failure Review

March 1, 2017

HP-11431

Maintenance Data Sheet: Failed Calibration Check

April 10, 2017

Miscellaneous Documents

Number

Title

Date

201512044

Central Radiation Protection Maintenance Data Sheet December 10, 2015

201706-012

Entergy Operations, Inc., Portable Instruments to

Waterford-3 RP

June 19, 2017

3751

Laboratory Standard Calibration/Verification Data:

V-570 Meter

July 9, 2015

AO-987

Amersham Source Decay Data Sheet

January 26, 2017

AO-988

Amersham Source Decay Data Sheet

January 26, 2017

ERIC Report

Instrument Status Report Calibration Needed for

GGNS

July 11, 2017

JLS-8254

Source Verification of Source J.L. Shephard Calibrator

S/N SRC-1993003 Model-89 (400) Cs-137 Sealed

Sources at Set Positions

October 13, 2015

MP-141

AEA Technology Source Decay Sheet

January 26, 2017

MP-158

AEA Technology Source Decay Sheet

January 26, 2017

A1-5

Section 2RS6: Radioactive Gaseous and Liquid Effluent Treatment

Procedures

Number

Title

Revision

04-1-01-N65-1-SU

System Operating Instruction Offgas Vault

Refrigeration

033

06-CH-1000-M-0049

Effluent Dose Calculations

104

06-CH-1D17-M-0003

Building Ventilation Gaseous Tritium

109

06-CH-1D17-M-0005

Building Ventilation Exhaust Gaseous Isotopic

109

06-CH-1D17-M-0018

Gaseous Release Points - Particulate Alpha

Activity

108

06-CH-1D17-W-0017

Gaseous Release Points - Iodines, Tritium and

Particulates

106

06-CH-1T48-M-0037

Standby Gas Treatment Exhaust Gaseous Isotopic 107

06-CH-SG17-O-0045

Radwaste Release Post-Release Calculations

105

06-CH-SG17-P-0041

Radwaste Release Pre-Release Analysis

109

06-CH-SG17-Q-0044

Radwaste Release Quarterly Composite

103

08-S-03-10

Chemistry Sampling Program

052

08-S-03-22

Installed Radiation Monitoring System Alarm

Setpoint Determination and Control

114

1-S-08-11

Radioactive Discharge Controls

114

EN-CY-108

Monitoring of Nonradioactive Systems

006

Audits and Self-Assessments

Number

Title

Date

LO-GLO-2016-0122

Pre-NRC RETS/ODCM Radiological Effluent

Occurrences Assessment

December 4, 2016

Teledyne Brown Engineering Environmental

Services

April 19, 2017

QA-2-6-2015-GGNS-1 GGNS Combined Chemistry Effluent and

Environmental Monitoring (including ODCM

and REMP) Program Audit

October 9, 2015

Condition Reports (CR-GGNS-)

2013-00450

2015-06763

2015-06764

2015-06982

2016-02468

2016-02688

2016-07187

2016-08307

2016-08308

2017-00051

2017-00193

2017-00204

2017-00264

2017-00290

2017-00336

2017-00529

2017-03101

2017-03745

2017-04525

2017-05659

2017-06821

2017-06875

A1-6

10 CFR 50.75(g) Condition Reports (CR-GGNS-)

2015-06763

2015-06764

2016-07187

2017-00336

Release Permits

Liquid Releases

2015051

2015094

2016011

2016017

2016022

2016040

2016042

2016044

2016045

2016051

2016073

2017009

2017018

In-Place Filter Testing Records

Number

System

Train

Test

Date

WO 46551718

Standby Gas Treatment

B

DOP & HEPA

June 3, 2017

WO 52482060

Standby Gas Treatment

A

DOP & HEPA

March 16, 2015

WO 52618801

Control Room Air / Standby

Fresh Air

A

DOP & HEPA

October 27, 2016

WO 52655772

Control Room Air / Standby

Fresh Air

B

DOP & HEPA

December 1, 2016

Miscellaneous Documents

Number

Title

Revision

Date

2014 Annual Radioactive Effluent Release Report

April 27, 2015

2015 Annual Radioactive Effluent Release Report

April 14, 2016

2016 Annual Radioactive Effluent Release Report

April 25, 2017

Cross Contamination of Service Air System / CR-

GGN-2017-00193

February 27, 2017

Grand Gulf Service Air System I.E.Bulletin 80-10

Bounding Evaluation for Contamination of a

Nonradioactive System

March 29, 2017

Nuclear Independent Oversight Functional Area

Performance Report: Group B

May 31, 2016

Offsite Dose Calculation Manual

39

1000-1-17-002

2016 Radiochemistry INTRALAB Cross-Check

Results

January 23, 2017

GNRO-2016/00039

Supplement to Grand Gulf Nuclear Station 2015

Annual Radioactive Effluent Release Report (ARERR)

July 20, 2016

SD N64/N65

Grand Gulf Nuclear Station System Description

2

UFSAR Chapter 11

GGN Updated Final Safety Analysis Report

2016-00

A1-7

Section 2RS7: Radiological Environmental Monitoring Program

Procedures

Number

Title

Revision

06-EN-S000-V-0001

Surveillance Procedure Radiological

Environmental Sampling

111

06-IC-SC84-SA-1003 Primary Tower Wind Speed/Direction, Air

Temperature (T/dT) and Relative Humidity

106

07-S-53-C84-7

Backup Tower Wind/Speed/Direction and Air

Temperature Calibration

0

08-S-04-964

Met Data Processing

2

ODCM

Offsite Dose Calculation Manual

39

Audits and Self-Assessments

Number

Title

Date

LO-GLO-2015-00042

Focused Self-Assessment:

Chemistry Groundwater/Environmental

Programs

November 18, 2015

2015

Environmental Dosimetry Company

Quality Assurance Status Report

February 29, 2016

2015

Teledyne Brown Engineering:

Environmental Services

Quality Assurance Report

May 9, 2016

2016

Environmental Dosimetry Company

Quality Assurance Status Report

March 8, 2017

2016

Teledyne Brown Engineering:

Environmental Services

Quality Assurance Report

April 19, 2017

Condition Reports (CR-GGNS-)

2015-04675

2015-05753

2015-06263

2015-06763

2016-03213

2016-03475

2016-03825

2016-05543

2016-07187

2016-07747

2016-08364

2016-09067

2017-00813

2017-00993

2017-01731

2017-02633

2017-05447

A1-8

REMP Air Sampler Calibration Data

Number

Title

Date

CHEM-001

LV-1D - Air Sampler (LOVOL)

July 21, 2016

CHEM-002

LV-1D - Air Sampler (LOVOL)

October 20, 2016

CHEM-003

LV-1D - Air Sampler (LOVOL)

July 19, 2016

Meteorological Instrument Calibration Records

W/O Number

Title

Date

52652328

Backup Meteorological Tower Instrument

Calibration

07-S-53-C84-7

August 29, 2016

52692658

Primary Meteorological Tower Instrument

Calibrations

06-IC-SC84-SA-1003

August 2, 2016

Meteorological Data

Number

Title

Date

2016

ODCM Annual Average Relative Concentration

(/Q) and Relative Deposition (D/Q)

March 2017

2016

Review of Grand Gulf Meteorological Data

March 9, 2017

Groundwater Protection Documents

Number

Title

Revision / Date

L71506

Groundwater Monitoring Report - January 2017

February 3, 2017

L71974

Groundwater Monitoring Report - February 2017

March 31, 2017

L72140

Groundwater Monitoring Report - March 2017

March 31, 2017

L72521

Groundwater Monitoring Report - April 2017

May 5, 2017

R06045-0032-002 Groundwater Monitoring Plan

6

Miscellaneous Documents

Number

Title

Date

2015

Annual Environmental Operating Report

April 19, 2016

2016

Annual Environmental Operating Report

April 27, 2017

2016

Land Use Census

December 16, 2016

2017-044

Licensing Basis Document Change Request

(LBDCR)

April 27, 2017

A1-9

Section 2RS8: Radioactive Solid Waste Processing, and Radioactive Material Handling,

Storage, and Transportation

Procedures

Number

Title

Revision

EN-RW-101

Radioactive Waste Management

3

EN-RW-102

Radioactive Shipping Procedure

15

EN-RW-103

Radioactive Waste Tracking Procedure

4

EN-RW-104

Scaling Factors

13

EN-RW-105

Process Control Program

5

EN-RW-106

Integrated Transportation Security Plan

6

04-S-01-G17-3

Radwaste Filters and Demineralizer

47

08-S-06-50

Radwaste Instruction: Loading Radioactive

Material

9

08-S-06-71

Radwaste Instruction: Sampling

Procedures for Waste Classification

7

07-S-14-428

Operation and Maintenance of the TRI-

NUC Underwater Filtration System

0

08-S-02-075

Radiation Protection Instruction - Coverage

and Control of Refueling Operations and

Movement of Irradiated Materials

16

Audits and Self-Assessments

Number

Title

Date

QA-1 4/15-2015-GGN-1

Combined Radiation Protection and

Radwaste

September 14, 2015

LO-GLO-2017-00022

Pre-NRC Inspection Module 71124-08

May 24, 2017

LO-GLO-2015-00139

10 CFR Part 37 Materials Security Review

January 8, 2016

Condition Reports (CR-HQN-)

2015-00747

2017-00904

Condition Reports (CR-GGNS-)

2015-00231

2015-05082

2016-00319

2016-00320

2016-00801

2016-00804

2016-00805

2016-00809

2016-04376

2017-00101

2017-00106

2017-01568

2017-01625

2017-01644

2017-04789

2017-05552

2017-06772

2017-06779

A1-10

Radioactive Material and Waste Shipments

Number

Title

Date

GGN-2017-0101

CFFF Filters - LSA-II

January 12, 2017

GGN-2017-0102

CRD-CRDM- LSA-II

January 13, 2017

GGN-2017-0106

CPS Powdex Liner

January 20, 2017

GGN-2016-0319

WMG Sealands

March 16, 2016

GGN-2016-0320

Suppression Pool Filter Liners

March 21, 2016

GGN-2016-0324

5 Type A GE Boxes

March 23, 2016

GGN-2015-0801

RWCU-A Liner - Type B

August 3, 2017

GGN-2015-0805

RWCU-A Liner - Type B

August 3, 2017

GGN-2015-0809

RWCU-A Liner - Type B

August 16, 2017

Miscellaneous Documents

Number

Title

Date

OE-NOE-2016-00

NRC-RIS-2016-11

November 30, 2016

2017

RW/RAM Shipping Log

January 1, 2017

2016

RW/RAM Shipping Log

January 1, 2016

2015

RW/RAM Shipping Log

January 1, 2015

UFSAR Chapter 11

GGN Updated Final Safety Analysis Report

2016

Management Standard No. 36

April 25, 2017

Monitoring & Responding to Dose Rates on the

Fuel Pools

April 14, 2016

2015 Annual Radioactive Effluent Release

Report

April 25, 2017

2016 Annual Radioactive Effluent Release

Report

June 13, 2017

Radioactive Material Storage Container

Tracking Sheets

Attachment 2

The following items are requested for the

Occupational/Public Radiation Safety Inspection

at Grand Gulf Nuclear Station

July 10 to 14, 2017

Integrated Report 2017007

Inspection areas are listed in the attachments below.

Please provide the requested information on or before June 14, 2017.

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

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

1- A, applicable organization charts in file/folder 1- 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 Martin Phalen at (817) 200-1158 or

martin.phalen@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.

A2-2

5.

Radiation Monitoring Instrumentation (71124.05)

Date of Last Inspection:

March 27, 2015

A.

List of contacts and telephone numbers for the following areas:

1. Effluent monitor calibration

2. Radiation protection instrument calibration

3. Installed instrument calibrations

4. Count room and Laboratory instrument calibrations

B.

Applicable organization charts

C.

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

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

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

instruments, electronic dosimeters, teledosimetry, personnel contamination monitors,

or whole body counters

2. Installed radiation monitors

D.

Procedure index for:

1. Calibration, use and operation of continuous air monitors, criticality monitors,

portable survey instruments, temporary area radiation monitors, electronic

dosimeters, teledosimetry, personnel contamination monitors, and whole body

counters.

2. Calibration of installed radiation monitors

E.

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

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Calibration of portable radiation detection instruments (for portable ion chambers)

2. Whole body counter calibration

3. Laboratory instrumentation quality control

F.

A summary list of corrective action documents (including corporate and sub-tiered

systems) written since date of last inspection, related to the following programs:

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

instruments, electronic dosimeters, teledosimetry, personnel contamination monitors,

whole body counters,

2. Installed radiation monitors,

3. Effluent radiation monitors

4. Count room radiation instruments

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G.

Offsite dose calculation manual, technical requirements manual, or licensee controlled

specifications, which lists the effluent monitors and calibration requirements.

H.

Current calibration data for the whole body counters.

A2-3

I.

Primary to secondary source calibration correlation for effluent monitors.

J.

A list of the point of discharge effluent monitors with the two most recent calibration

dates and the work order numbers associated with the calibrations.

K.

Radiation Monitoring System health report for the previous 12 months

A2-4

6.

Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

Date of Last Inspection:

March 27, 2015

A.

List of contacts and telephone numbers for the following areas:

1. Radiological effluent control

2. Engineered safety feature air cleaning systems

B.

Applicable organization charts

C.

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

written since date of last inspection, related to:

1. Radioactive effluents

2. Engineered Safety Feature Air cleaning systems

D.

Procedure indexes for the following areas

1. Radioactive effluents

2. Engineered Safety Feature Air cleaning systems

E.

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

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Sampling of radioactive effluents

2. Sample analysis

3. Generating radioactive effluent release permits

4. Laboratory instrumentation quality control

5. In-place testing of HEPA filters and charcoal adsorbers

6. New or applicable procedures for effluent programs (e.g., including ground water

monitoring programs)

F.

List of corrective action documents (including corporate and sub-tiered systems) written

since date of last inspection, associated with:

1. Radioactive effluents

2. Effluent radiation monitors

3. Engineered Safety Feature Air cleaning systems

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G.

2015 and 2016 Annual Radioactive Effluent Release Report, or the two most recent

reports.

H.

Current Copy of the Offsite Dose Calculation Manual

I.

Copy of the 2015 and 2016 inter-laboratory comparison results for laboratory quality

control performance of effluent sample analysis, or the two most recent results.

J.

Effluent sampling schedule for the week of the inspection

K.

New entries into 10 CFR 50.75(g) files since date of last inspection

A2-5

L.

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

removed from service or out of service

M.

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

N.

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

O.

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 November 2011. If applicable, please provide the relative Special Report

and condition report(s).

P.

A list of all radiation monitors that are considered § 50.65/Maintenance Rule equipment.

Q.

A list of all significant changes made to the Gaseous and Liquid Effluent Process

Monitoring System since the last inspection. If applicable, please provide the

corresponding UFSAR section in which this change was documented.

R.

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

radioactive system. Please include any relative condition report(s).

A2-6

7.

Radiological Environmental Monitoring Program (71124.07)

Date of Last Inspection:

March 27, 2015

A.

List of contacts and telephone numbers for the following areas:

1. Radiological environmental monitoring

2. Meteorological monitoring

B.

Applicable organization charts

C.

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

written since date of 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:

1. Radiological environmental monitoring program

2. Meteorological monitoring program

E.

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

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Environmental Program Description

2. Sampling, collection and preparation of environmental samples

3. Sample analysis (if applicable)

4. Laboratory instrumentation quality control

5. Procedures associated with the Offsite Dose Calculation Manual

6. Appropriate QA Audit and program procedures, and/or sections of the stations QA

manual (which pertain to the REMP)

F.

A summary list of corrective action documents (including corporate and sub-tiered

systems) written since date of last inspection, related to the following programs:

1. Radiological environmental monitoring

2. Meteorological monitoring

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G.

Wind Rose data and evaluations used for establishing environmental sampling locations

H.

Copies of the 2 most recent calibration packages for the meteorological tower

instruments

I.

Copy of the 2015 and 2016 Annual Radiological Environmental Operating Report and

Land Use Census, and current revision of the Offsite Dose Calculation Manual, or the

two most recent reports.

A2-7

J.

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

2015 and 2016, or the two most recent results, 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 Initiative Plan and status

N.

Technical requirements manual or licensee controlled specifications which lists the

meteorological instruments calibration requirements

O.

A list of Regulatory Guides and/or NUREGs that you are currently committed to relative

to the Radiological Environmental Monitoring Program. Please include the revision

and/or date for the committed item and where this can be located in your current

licensing basis/UFSAR.

P.

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

groundwater since the last inspection

A2-8

8.

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

and Transportation (71124.08)

Date of Last Inspection:

March 27, 2015

A.

List of contacts and telephone numbers for the following areas:

1. Solid Radioactive waste processing

2. Transportation of radioactive material/waste

B.

Applicable organization charts (and list of personnel involved in solid radwaste

processing, transferring, and transportation of radioactive waste/materials)

C.

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

inspection related to:

1. Solid radioactive waste management

2. Radioactive material/waste transportation program

D.

Procedure index for the following areas:

1. Solid radioactive waste management

2. Radioactive material/waste transportation

E.

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

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Process control program

2. Solid and liquid radioactive waste processing

3. Radioactive material/waste shipping

4. Methodology used for waste concentration averaging, if applicable

5. Waste stream sampling and analysis

F.

A summary list of corrective action documents (including corporate and sub-tiered

systems) written since date of last inspection related to:

1. Solid radioactive waste

2. Transportation of radioactive material/waste

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G.

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

packaging, and shipping.

H.

A summary of radioactive material and radioactive waste shipments made from date of

last inspection to present

I.

Waste stream sample analyses results and resulting scaling factors for 2015 and 2016,

or the two most recent results.

J.

Waste classification reports if performed by vendors (such as for irradiated hardware)

A2-9

K.

A listing of all on-site radwaste storage facilities. Please include a summary or listing of

the items stored in each facility, including the total amount of radioactivity and the

highest general area dose rate.

Although it is not necessary to compile the following information, the inspector will also review:

L.

Training, and qualifications records of personnel responsible for the conduct of

radioactive waste processing, package preparation, and shipping

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