ML17235B265

NRC Radiation Protection Inspection Report 05000416/2017012 and Notice of Violation

ML17235B265
Person / Time
Site:	Grand Gulf
Issue date:	08/22/2017
From:	Heather Gepford Plant Support Branch-1
To:	Emily Larson Entergy Operations
References
IR 2017012
Download: ML17235B265 (36)

See also: IR 05000416/2017012

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD

ARLINGTON, TX 76011-4511

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.

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

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

Enclosure

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

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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

3

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.

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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)

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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

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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.

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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.

8

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

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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

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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].

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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.

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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.

13

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.

14

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

Failure to Correct Instrument Calibration Process in a Timely

05000416-2017012-01 VIO

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

Attachment 1

LIST OF DOCUMENTS REVIEWED

Section 2RS5: Radiation Monitoring Instrumentation

Procedures

Number Title Revision

06-IC-1D17-R-1002 Main Steam Line High Radiation Monitor 108, 109

(PCIS) Calibration

06-IC-1D21-R-1002 Containment/Drywell High Range Area 107, 108,109

Radiation Monitor Calibration

08-S-07-83 Radiation Protection Instruction Operation 10

and Calibration of the ND-9000 Whole Body

Counter

EN-CY-102 Laboratory Analytical Quality Control 9

EN-FAP-RP-007 Operation of the RP Central Calibration 2

Facility

EN-MA-105 Control of Measuring and Test Equipment 13

(M&TE)

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 May 23, 2017

Program

QA-14/15-201 5-GGN-1 QA Audit: Combined Radiation Protection and November 16, 2015

Radwaste

A1-2

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) February 22, 2017

Calibration - Channel A

52637367 Containment/Drywell High Range Area Radiation March 16, 2016

Monitor Calibration - Channel A

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 July 10 2017

Scaler

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

A1-3

Stationary Radiation Instrument Calibration Records

Number Title Date

Apex-InVivo Analysis Report Calibration Check Count of People July 12, 2017

Mover Whole Body Monitor

Canberra Calibration of the Canberra/Nuclear Data People August 8, 2015

Mover WBC System at Entergy Grand Gulf Nuclear

Station

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 June 19, 2017

Waterford-3 RP

3751 Laboratory Standard Calibration/Verification Data: July 9, 2015

V-570 Meter

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 July 11, 2017

GGNS

JLS-8254 Source Verification of Source J.L. Shephard Calibrator October 13, 2015

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

Sources at Set Positions

MP-141 AEA Technology Source Decay Sheet January 26, 2017

MP-158 AEA Technology Source Decay Sheet January 26, 2017

A1-4

Section 2RS6: Radioactive Gaseous and Liquid Effluent Treatment

Procedures

Number Title Revision

04-1-01-N65-1-SU System Operating Instruction Offgas Vault 033

Refrigeration

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 108

Activity

06-CH-1D17-W-0017 Gaseous Release Points - Iodines, Tritium and 106

Particulates

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 114

Setpoint Determination and Control

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 December 4, 2016

Occurrences Assessment

Teledyne Brown Engineering Environmental April 19, 2017

Services

QA-2-6-2015-GGNS-1 GGNS Combined Chemistry Effluent and October 9, 2015

Environmental Monitoring (including ODCM

and REMP) Program Audit

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

A1-5

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 DOP & HEPA October 27, 2016

A

Fresh Air

WO 52655772 Control Room Air / Standby B DOP & HEPA December 1, 2016

Fresh Air

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- February 27, 2017

GGN-2017-00193

Grand Gulf Service Air System I.E.Bulletin 80-10 March 29, 2017

Bounding Evaluation for Contamination of a

Nonradioactive System

Nuclear Independent Oversight Functional Area May 31, 2016

Performance Report: Group B

Offsite Dose Calculation Manual 39

1000-1-17-002 2016 Radiochemistry INTRALAB Cross-Check January 23, 2017

Results

GNRO-2016/00039 Supplement to Grand Gulf Nuclear Station 2015 July 20, 2016

Annual Radioactive Effluent Release Report (ARERR)

SD N64/N65 Grand Gulf Nuclear Station System Description 2

UFSAR Chapter 11 GGN Updated Final Safety Analysis Report 2016-00

A1-6

Section 2RS7: Radiological Environmental Monitoring Program

Procedures

Number Title Revision

06-EN-S000-V-0001 Surveillance Procedure Radiological 111

Environmental Sampling

06-IC-SC84-SA-1003 Primary Tower Wind Speed/Direction, Air 106

Temperature (T/dT) and Relative Humidity

07-S-53-C84-7 Backup Tower Wind/Speed/Direction and Air 0

Temperature Calibration

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: November 18, 2015

Chemistry Groundwater/Environmental

Programs

2015 Environmental Dosimetry Company February 29, 2016

Quality Assurance Status Report

2015 Teledyne Brown Engineering: May 9, 2016

Environmental Services

Quality Assurance Report

2016 Environmental Dosimetry Company March 8, 2017

Quality Assurance Status Report

2016 Teledyne Brown Engineering: April 19, 2017

Environmental Services

Quality Assurance Report

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

A1-7

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 August 29, 2016

Calibration

07-S-53-C84-7

52692658 Primary Meteorological Tower Instrument August 2, 2016

Calibrations

06-IC-SC84-SA-1003

Meteorological Data

Number Title Date

2016 ODCM Annual Average Relative Concentration March 2017

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

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 April 27, 2017

(LBDCR)

A1-8

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 9

Material

08-S-06-71 Radwaste Instruction: Sampling 7

Procedures for Waste Classification

07-S-14-428 Operation and Maintenance of the TRI- 0

NUC Underwater Filtration System

08-S-02-075 Radiation Protection Instruction - Coverage 16

and Control of Refueling Operations and

Movement of Irradiated Materials

Audits and Self-Assessments

Number Title Date

QA-1 4/15-2015-GGN-1 Combined Radiation Protection and September 14, 2015

Radwaste

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

A1-9

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 April 14, 2016

Fuel Pools

2015 Annual Radioactive Effluent Release April 25, 2017

Report

2016 Annual Radioactive Effluent Release June 13, 2017

Report

Radioactive Material Storage Container

Tracking Sheets

A1-10

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.

Attachment 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.

A2-2

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

A2-3

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

A2-4

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).

A2-5

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.

A2-6

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

A2-7

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)

A2-8

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

A2-9