ML23122A163

NRC Inspection Report 05000416/2023090 and Preliminary White Finding

ML23122A163
Person / Time
Site:	Grand Gulf
Issue date:	05/18/2023
From:	Geoffrey Miller NRC/RGN-IV/DRSS
To:	Kapellas B Entergy Operations
Greene N
References
EA-23-019 IR 2023090
Download: ML23122A163 (15)

See also: IR 05000416/2023090

Text

May 18, 2023

EA-23-019

Brad Kapellas, Site Vice President

Entergy Operations, Inc.

P.O. Box 756

Port Gibson, MS 39150

SUBJECT: GRAND GULF NUCLEAR STATION - NRC INSPECTION REPORT

05000416/2023090 AND PRELIMINARY WHITE FINDING

Dear Brad Kapellas:

This letter refers to the inspection conducted from November 14, 2022, to April 5, 2023, by the

U.S. Nuclear Regulatory Commission (NRC) at the Grand Gulf Nuclear Station. The purpose of

the inspection was to verify Entergy Operations, Inc. (licensee) is ensuring the accuracy and

operability of radiation monitoring instruments that are used to monitor areas, materials, and

workers to ensure a radiologically safe work environment and detect and quantify radioactive

process streams and effluent releases. On April 5, 2023, a final exit briefing was conducted with

you and other members of your staff. The results of the inspection are documented in the

enclosed report.

The enclosed report discusses a preliminary White finding (i.e., a finding with low-to-moderate

safety significance that may require additional NRC inspections), with three associated

apparent violations. As described in the enclosed report, during the week of November 14,

2022, NRC inspectors reviewed documents related to your radiation monitoring instrumentation

program and identified calibration failures for the drywell and containment high range area

radiation monitors. The finding was assessed based on the best available information, using the

applicable significance determination process (SDP). The final resolution of this finding will be

conveyed in separate correspondence.

The finding has three associated apparent violations which are being considered for escalated

enforcement action in accordance with the NRC Enforcement Policy, which can be found at

http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The apparent violations

involve the failure to: (1) calibrate primary drywell and containment high range area radiation

monitors in accordance with 10 CFR 20.1501(c); (2) follow and maintain the effectiveness of an

emergency plan that meets the requirements in 10 CFR Part 50, Appendix E, and the planning

standards of 10 CFR 50.47(b); and (3) maintain the drywell and containment high range area

radiation monitors operable or else initiate action to prepare and submit a Special Report to the

NRC immediately.

B. Kapellas 2

In accordance with NRC Inspection Manual Chapter 0609, we intend to complete our evaluation

using the best available information and issue our final significance determination and

enforcement decision, in writing, within 90 days from the date of this letter. The significance

determination process encourages an open dialogue between your staff and the NRC; however,

the dialogue should not impact the timeliness of our final determination.

Before we make a final decision on this matter, we are providing you with an opportunity to

either (1) attend a Regulatory Conference where you can present to the NRC your perspective

on the facts and assumptions the NRC used to arrive at the finding and assess its significance,

or (2) submit your position on the finding to the NRC in writing. If you request a Regulatory

Conference, it should be held within 40 days of the receipt of this letter, and we encourage you

to submit supporting documentation at least one week prior to the conference in an effort to

make the conference more efficient and effective. The focus of the Regulatory Conference is to

discuss the significance of the finding and not necessarily the root cause(s) or corrective

action(s) associated with the finding. If a Regulatory Conference is held, it will be open for public

observation. If you decide to submit only a written response, such submittal should be sent to

the NRC within 40 days of your receipt of this letter.

If you decline to request a Regulatory Conference or to submit a written response, you

relinquish your right to appeal the final SDP determination, in that by not doing either, you fail to

meet the appeal requirements stated in the Prerequisite and Limitation sections of Attachment 2

of NRC Inspection Manual Chapter 0609.

If you choose to send a written response, it should be clearly marked as a Response to

Apparent Violations in NRC Inspection Report 05000416/2023090; EA-23-019 and should

include for the apparent violations: (1) the reason for the apparent violations or, if contested, the

basis for disputing the apparent violations; (2) the corrective steps that have been taken and the

results achieved; (3) the corrective steps that will be taken; and (4) the date when full

compliance will be achieved. Your response may reference or include previously docketed

correspondence if the correspondence adequately addresses the required response.

Additionally, your written response should be sent to the U.S. Nuclear Regulatory Commission,

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

Division of Radiological Safety and Security, U.S. Nuclear Regulatory Commission, Region IV,

1600 East Lamar Blvd., Arlington, Texas 76011-4511, and the NRC Resident Inspector at the

Grand Gulf Nuclear Station, and emailed to R4Enforcement@nrc.gov, within 40 days of the date

of this letter. If an adequate response is not received within the time specified or an extension of

time has not been granted by the NRC, the NRC will proceed with its enforcement decision or

schedule a Regulatory Conference.

Please contact Gregory Warnick at 817-200-1249 within 10 days from the issue date of this

letter to notify the NRC of your intentions. If we have not heard from you within 10 days, we will

continue with our significance determination and enforcement decision. The final resolution of

this matter will be conveyed in separate correspondence.

Because the NRC has not made a final determination in this matter, a Notice of Violation is not

being issued at this time. In addition, please be advised that the number and characterization of

the apparent violations described in the enclosed inspection report may change as a result of

further NRC review.

B. Kapellas 3

In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a

copy of this letter, its enclosure, and your response, if you choose to provide one, will be made

available electronically for public inspection in the NRC Public Document Room and from the

NRCs Agencywide Documents Access and Management System (ADAMS), accessible from

the NRC website at http://www.nrc.gov/reading-rm/adams.html.

If you have any questions concerning this matter, please contact Gregory Warnick of my staff

at 817-200-1249.

Sincerely,

Rivera-Varona, Aida signing on behalf

of Miller, Geoffrey

on 05/18/23

Geoffrey B. Miller, Director (Acting)

Division of Radiological Safety & Security

Docket No. 05000416

License No. NPF-29

Enclosure:

NRC Inspection Report 05000416/2023090

cc w/ encl: Distribution via LISTSERV

ML23122A163

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: ACR Yes No Publicly Available Sensitive NRC-002

OFFICE ES:ACES HP:DIOR SHP:DIOR C:DIOR C:PBA TL:ACES

NAME ARoberts DAntonangeli NGreene GWarnick JJosey RKumana

SIGNATURE /RA/ E /RA/ E /RA/ E /RA/ E /RA/ E /RA/ E

DATE 05/02/23 /05/02/23 05/02/23 05/02/23 05/02/23 05/04/23

OFFICE RC NRR NSIR OE D:DORS D:DRSS

NAME DCylkowski RFelts MMcCoppin JPeralta RLantz AXR1 for GMiller

SIGNATURE /RA/ E /RA/ E /RA/ E /RA/ E /RA/ E /RA/ E

DATE 05/05/23 05/09/23 05/15/23 05/11/23 05/16/23 05/18/23

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000416

License Number: NPF-29

Report Number: 05000416/2023090

Licensee: Entergy Operations, Inc.

Facility: Grand Gulf Nuclear Station

Location: Port Gibson, MS

Inspection Dates: November 14, 2022 to April 5, 2023

Inspectors: D. Antonangeli, Health Physicist

N. Greene, Senior Health Physicist

S. Hedger, Senior Emergency Preparedness Inspector

Approved By: Gregory G. Warnick, Chief

Decommissioning, ISFSI & Operating Reactors Branch

Division of Radiological Safety & Security

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees

performance by conducting a NRC inspection at Grand Gulf Nuclear Station, in accordance with

the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for

overseeing the safe operation of commercial nuclear power reactors. Refer to

https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Failure to calibrate primary drywell and containment high range area radiation monitors in

accordance with 10 CFR 20.1501(c)

Cornerstone Significance Cross-Cutting Report

Aspect Section

Emergency Preliminary White [H.9] - Training 71124.05

Preparedness AV 05000416/2023090-01

Open

EA-23-019

During the week of November 14, 2022, NRC inspectors reviewed documents related to the

licensees radiation monitoring instrumentation program and identified calibration failures for

their drywell and containment high range area radiation monitors (1D21K648A, 1D21K648B,

1D21K648C, and 1D21K648D). The calibration failures impacted all four radiation monitors.

The licensee failed to perform a calibration in accordance with NRC requirements of

10 CFR 20.1501(c). The licensee then failed to declare these radiation monitors inoperable in

accordance with their technical specification requirements (TS 3.3.3.1 and TS 3.0.1) and

perform the associated limiting condition for operation (LCO) action. Inoperable radiation

monitors would be unable to perform their intended function for Emergency Preparedness

actions in accordance with 10 CFR 50.54(q)(2).

Additional Tracking Items

None.

2

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in

effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with

their attached revision histories are located on the public website at http://www.nrc.gov/reading-

rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared

complete when the IP requirements most appropriate to the inspection activity were met

consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection

Program - Operations Phase. The inspectors reviewed selected procedures and records,

observed activities, and interviewed personnel to assess licensee performance and compliance

with Commission rules and regulations, license conditions, site procedures, and standards.

RADIATION SAFETY

71124.05 - Radiation Monitoring Instrumentation

Calibration and Testing Program (IP Section 03.02) (4 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection

instruments per procedure 06-IC-1D21-R-1002:

(1) drywell high range area monitor, plant I.D: 1D21K648A

(2) drywell high range area monitor, plant I.D: 1D21K648D

(3) containment high range area monitor, plant I.D: 1D21K648B

(4) containment high range area monitor, plant I.D: 1D21K648C

INSPECTION RESULTS

Failure to calibrate primary drywell and containment high range area radiation monitors in

accordance with 10 CFR 20.1501(c)

Cornerstone Significance Cross-Cutting Report

Aspect Section

Emergency Preliminary White [H.9] - Training 71124.05

Preparedness AV 05000416/2023090-01

Open

EA-23-019

During the week of November 14, 2022, NRC inspectors reviewed documents related to the

licensees radiation monitoring instrumentation program and identified calibration failures for

their drywell and containment high range area radiation monitors (1D21K648A, 1D21K648B,

1D21K648C, and 1D21K648D). The calibration failures impacted all four radiation monitors.

The licensee failed to perform a calibration in accordance with NRC requirements of

10 CFR 20.1501(c). The licensee then failed to declare these radiation monitors inoperable in

accordance with their technical specification requirements (TS 3.3.3.1 and TS 3.0.1) and

perform the associated limiting condition for operation (LCO) action. Inoperable radiation

monitors would be unable to perform their intended function for Emergency Preparedness

actions in accordance with 10 CFR 50.54(q)(2).

Description: The NRC inspectors reviewed documents related to the licensees radiation

monitoring instrumentation program. The inspectors identified documented failures of

selected radiation monitoring instruments associated with the sensitivity parameters. Upon

further review, inspectors determined that all four of the licensees accident high range

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radiation monitors (two drywell - detectors A and D, two containment - detectors B and C)

failed to be within the sensitivity tolerances during their last two calibrations cycles.

The sensitivity parameter represents the fundamental way the detector (in this case an ion

chamber) works. This parameter relates the output signal of the detector to the amount of

radiation present. The calibration process uses this parameter to demonstrate the

instruments ability to accurately detect radiation. For context, the sensitivity parameter was

determined in a controlled laboratory environment where the detector was exposed to a

known radiation field (in roentgens per hour (R/hr)) that resulted in a corresponding output

current (in amps) based on the collection efficiency of the detector. This was how the

sensitivity parameter value for the detector was determined, in the units of amps (A) per R/hr

(A/R/hr). The vendor established the sensitivity parameter value by testing three decades of

response and averaging them. This established the linear and consistent response on the

detector side of the calibration. In this case, the vendor provided an average value of

6.8 E-11 A/R/hr with a tolerance of +/- 10 percent (%), as a requirement, to maintain a

successful calibration check of the system. Moreover, for accident high range radiation

monitors, NUREG 0737, Clarification of TMI Action Plan requirements, describes a

calibration variance for not checking the entire detector range using radiation. This means

that the sensitivity parameter check plays a more important role in the detector calibration.

There is only one radiation level measurement made and this is the only indication of how the

detector will respond on the higher radiological ranges that are not being checked within the

licensees calibration process. The sensitivity parameter check verifies that the current output

on any range of the instrument between calibrations is displayed within a reasonable

tolerance of the actual radiological conditions. This allows the control room operators to make

an acceptable determination of actions during/post an accident.

This sensitivity parameter was introduced to the licensee's calibration program and process

by the corrective actions for a Notice of Violation (NOV) accompanying Inspection Report 05000416/2017012, which the licensee received from the NRC by letter dated August 22,

2017 (ADAMS Accession No. ML17235B265). The licensee added the sensitivity parameter

check to the calibration procedure as a corrective action of the 2017 violation since it was

required by the vendor manual for a successful calibration. Since implementation of this

sensitivity parameter to calibration procedure 06-IC-1D21-R-1002, Containment/Drywell High

Range Area Radiation Monitor Calibration, the licensee has not been able to successfully

determine the detector sensitivity parameter within the vendors stated tolerance. The

licensee has initiated condition reports (CRs), for tracking purposes, when the sensitivity

failed to be within required tolerance, but the CR evaluations consistently conclude that the

sensitivity parameter tolerance is not a technical specification acceptance criterion; therefore,

the calibrations were completed without meeting the tolerance or completion of Section 5.89

of calibration procedure 06-IC-1D21-R-1002. The calibration procedure states that completion

of the procedure is a successful performance of the calibration surveillance. However, the

NRC asserts that the calibration procedure is inadequate and/or incomplete because the

results conflict with the acceptance criterion.

In addition, the licensee conducted operability evaluations for these drywell and containment

high range radiation monitors and concluded that the calibration procedure was inadequate.

Specifically, the licensee determined these sensitivity values cannot be collected adequately

without factoring background radiation/current into the calculation. The licensee also

concluded that an additional step in the procedure related to collecting background data was

needed. The licensee stated to the NRC that they agree the calibration procedure was

inadequate relative to the way in which they handle the sensitivity parameter value. However,

4

the licensee maintained that the radiation monitors were properly calibrated based on

meeting the radiation source check tolerance of +/- 36%, as described in Section 5.87,

Radiation Calibration, of their calibration procedure 06-IC-1D21-R-1002.

The licensee is committed to perform calibration of the drywell and containment high range

radiation monitors in accordance with NUREG-0737, and in compliance with the vendor

manual. Per NUREG-0737, the licensee must complete a special calibration for at least one

decade below 10 R/hr. In this case, the licensees radiation source check, involves exposing

the detector to a known radiation source, at approximately 4.5 rem per hour (R/hr), that

verifies the radiation detector is within tolerance, and thus, adequately calibrated. The

inspectors identified that the radiation source check tolerance of +/- 36%, as established by

the licensee from the vendor manual, is inappropriate because the tolerance of +/- 36% is

applicable to the overall system accuracy of the detector (i.e., across a wide range of

radiation intensity and radiation energy) and is not applicable for a single point reading on the

lowest decade as performed with the radiation source check. Based on ANSI N320-1978, as

the licensee commits to, the radiation system calibration shall be within +/- 40%, and +/- 15%

precision for any single sample. The calibration data provided by the licensee, and reviewed

by the NRC, demonstrates a single point error as high as +/- 33% for three of the four (A, B,

and D) drywell/containment high range area radiation monitors, and would significantly

challenge meeting the overall system accuracy of +/- 36% when factoring in other system

losses and errors across the other seven decade readings required for a successful

calibration. In fact, during the NRCs communication with the licensee and vendor, the vendor

stated that based on the available data, the overall system accuracy was likely greater than

+/- 40% for these detectors. The NRC requested the licensee assess the system accuracy of

their containment and drywell radiation monitoring systems for confirmation.

It is noteworthy that following issuance of the 2017 NOV, the licensee used their corrective

action process, in part, to respond to this violation. In condition report CR-GGN-2017-06876,

the licensee documented a validation of the calibration of containment area radiation monitors

(B and C) and stated the following, Based on the calibration sheets, the installed monitors

were exposed to a field of 4.95 R/hr. In both cases, the associated control room monitors

indicated 4 R/hr. This is within 20% [19.2%] of the actual field, and therefore acceptable. The

total stated accuracy of the instrument loop (detector, monitor, and indicator) is +/-36% of the

input radiation per vendor manual 460000136. This verifies that the Containment Area

Radiation Monitors are capable of detecting and measuring the radiation level within the

reactor containment during and following an accident with sufficient accuracy to provide

usable information, as per NUREG-0737. This statement shows that the licensee understood

the acceptance criteria and acceptable tolerances for the radiation source check and system

loop accuracy for a successful calibration. This data was used to satisfy the NRCs concern in

2017 in its determination that the calibrations of these monitors were successful, within

tolerance, and operable. As of the date of this report, the inspectors were not able to

determine if the calibrations were successful based on the data provided to the NRC at the

time of our inspection.

Specifically, inspectors reviewed procedure 06-IC-1D21-R-1002, revision 113, in which

Step 5.87.5 instructs the licensee to record the As Found meter and recorder readings.

These are the readings used for the radiation calibration for the detectors. It further instructs

the licensee to immediately notify the supervisor if the As Found values are not within

tolerance, but unfortunately, the tolerance is inappropriately documented as +/- 36%, which

as stated above, does not comply with the vendor manual requirements or applicable ANSI

5

standards. Thus, the licensee consistently and inappropriately considered this calibration

verification as successful, due to meeting the documented tolerance.

In response to these errors, the inspectors requested that the licensee demonstrates to the

NRC that the overall system accuracy meets the tolerance of +/- 36% from the vendor or the

+/- 40% from the ANSI standard, which would comply with the vendor manual requirements.

As of the end of the inspection, NRC had not received this information for the drywell and

containment high range area radiation monitors.

A successful calibration is required to ensure the radiation detectors are operable, and thus,

able to both timely and accurately inform the licensee of in-situ radiological conditions during

and post an accident. These radiological readings are then used to make determinations for

various emergency response action levels (EALs), in accordance with the licensees EAL

Technical Bases Emergency Plan.

The licensee responded to questions provided by the inspectors focused on understanding

the effects of the errors on EAL classification and dose assessment capabilities. Based on

review of the evaluations and supplemental information provided by the licensee, including

the licensees Emergency Plan Table F-1, Fission Product Barrier Threshold Matrix, the

inspectors determined:

For detectors A/D: the two drywell detectors would be used to classify up to an

Unusual Event or Alert classification

For detectors B/C: the two primary containment area radiation monitors would be

used to classify up to a Site Area Emergency (SAE)

For detectors A/B/C/D: all four detectors are used to classify up to a General

Emergency (GE)

The primary concern on the EAL classification impacts is that the licensee has not

demonstrated that they would be able to timely and accurately classify a GE in cases where

they could have at least 20% fuel clad damage, but with reactor vessel levels remaining

greater than the reactor pressure vessel (RPV) levels that trigger other EAL fission product

barrier criteria. In the document Grand Gulf Nuclear Station EAL Technical Bases,

Table F-1 (revision 1), it states that there is a fuel clad barrier loss and a containment

barrier potential loss when site Severe Accident Procedures (SAPs) are entered.

Procedure 05-S-01-EP-2, RPV Control, revision 3, indicates that SAPs are entered when

RPV level cannot be maintained above -191 inches. In cases where the RPV level remains

above -191 inches and significant fuel clad damage exists, the licensee hasnt demonstrated

that there are other EAL criteria that could be credited to compensate for not having the

capability to classify the GE based on containment radiation monitor readings at the timing

expected for EAL FG1, i.e., earlier than would otherwise occur from other EALs in the

approved EAL scheme.

Based on NRC's review of Table 5.4-1 of the licensees EAL Technical Bases Emergency

Plan, although the licensee may enter their SAP due to factors such as the RPV water level

hitting its threshold for a SAE, the inability to use their radiation monitors to indicate actual

radiation levels in the release pathway provides a degraded aspect of their ability to timely

and accurately classify a GE. This has a direct impact on offsite response organizations being

able to effectively implement protective action strategies to protect the public. While entry into

6

the SAP due to the RPV water level is a mitigating factor, for the purpose of significance per

IMC 0609, Appendix B, the accuracy and timeliness of EAL classifications, and the required

protective action recommendation, are considered degraded and not lost.

Corrective Actions: The licensee performed an operability evaluation, as documented in

CR-GGN-2022-10690, supplemented by CR-GGN-2022-11351, which states that, The

conditions identified in CR-2022-2940 for detector 1D21N048D and CR-2022-3094 for

detector 1D21N048D did not meet detector sensitivity criteria provided in procedure. In both

cases, the instruments passed their loop calibrations checks providing reasonable assurance

of operability. The licensee informed the inspectors that they are conducting an uncertainty

analysis, which will be used in their response to this violation, and as available, will be

evaluated by the NRC.

Corrective Action References: CR-GGN-2022-10690

Performance Assessment:

Performance Deficiency: The licensee failed to perform a calibration in accordance with NRC

requirements of 10 CFR 20.1501(c). The licensee then failed to declare these radiation

monitors (1D21K648A, 1D21K648B, 1D21K648C, and 1D21K648D) inoperable in

accordance with their technical specification requirements (TS 3.3.3.1 and TS 3.0.1) and

perform the associated limiting condition for operation (LCO) action. Inoperable radiation

monitors would be unable to perform their intended function for Emergency Preparedness

actions in accordance with 10 CFR 50.54(q)(2).

Screening: The inspectors determined the performance deficiency was more than minor

because it was associated with the Facilities and Equipment attribute of the Emergency

Preparedness cornerstone and adversely affected the cornerstone objective to ensure that

the licensee is capable of implementing adequate measures to protect the health and safety

of the public in the event of a radiological emergency. Specifically, the finding was more than

minor because it was associated with equipment needed (i.e., the drywell and containment

high range radiation monitors) for EAL determinations, which is considered a risk-significant

planning standard (RSPS) (i.e., 10 CFR 50.47(b)(4)) and adversely affected the Emergency

Preparedness cornerstone objective to ensure that the performance expectation of

reasonable assurance exists so that the licensee can effectively implement the approved

emergency plan.

Significance: The inspectors assessed the significance of the finding using IMC 0609

Appendix B, Emergency Preparedness SDP. Using Attachment 2 to IMC 0609, Appendix B,

the finding is a failure to comply with RSPSs. Based on Table 5.4-1 of the licensees

Emergency Plan, the inspectors determined that an EAL has been rendered ineffective such

that any GE would not be declared for a particular off-normal event, but because of other

EALs, an appropriate declaration could be made in a degraded manner (i.e., delayed). Since

the GE classification would most likely be made at some point by entering the licensees

SAP, the finding is not a loss of RSPS function but rather a degraded RSPS function when

the staff considers all relevant mitigating factors. Thus, entry into the SAP has not been

determined as both timely and accurate in all accident scenarios. Moreover, the actual

containment and drywell high range monitor calibration data reviewed by inspectors for the

radiation source check readout on the meter face and control room panels seem to

consistently under-respond to radiation.

7

Thus, inoperable drywell and primary containment high range area radiation monitors

affects the licensees ability to make both timely and accurate EAL classifications per the

licensees Emergency Plan. Therefore, the violation is preliminary determined as a finding of

WHITE significance.

Cross-Cutting Aspect: H.9 - Training: The organization provides training and ensures

knowledge transfer to maintain a knowledgeable, technically competent workforce and instill

nuclear safety values. Specifically, since at least 2017, the licensee has not demonstrated

that their staff performing the calibration verifications of these radiation monitors has the

technical knowledge to understand the full breadth of meeting acceptance criteria and

requirements established for a successful calibration. Furthermore, their surveillance

requirement 3.0.1 states, in part, that a failure to meet a surveillance is a failure to meet the

LCO. NRC staff has engaged with the licensee multiple times to discuss these calibration

aspects and establish a common understanding that the calibration data reviewed does not

support these radiation monitors as being calibrated, and thus, they are not operable.

Enforcement:

Violation:

Apparent Violation #1: 10 CFR 20.1501(c) - Failure to calibrate the drywell and containment

high range area radiation monitors

Title 10 CFR 20.1501(c) requires that the licensee shall ensure that instruments and

equipment used for quantitative radiation measurements (e.g., dose rate and effluent

monitoring) are calibrated periodically for the radiation measured.

Contrary to the above, from September 2019 to April 5, 2023, the licensee failed to ensure

that instruments and equipment used for quantitative radiation measurements (e.g., dose rate

and effluent monitoring) were calibrated periodically for the radiation measured. Specifically,

the licensee failed to adequately calibrate and maintain the drywell and containment high

range area radiation monitors in accordance with industry and vendor standards, as

committed to, for a successful calibration.

Apparent Violation #2: 10 CFR 50.54(q)(2) - Failure to follow and maintain the effectiveness

of an emergency plan and standards of 10 CFR 50.47(b)(4)

Title 10 CFR 50.54(q)(2) requires, in part, that a holder of a license under 10 CFR Part 50

shall follow and maintain the effectiveness of an emergency plan that meets the requirements

in 10 CFR Part 50, Appendix E, and the planning standards of 10 CFR 50.47(b).

Title 10 CFR 50.47(b)(4) requires, in part, that a standard emergency classification and action

level scheme is in use by the nuclear facility licensee, and State and local response plans call

for reliance on information provided by facility licensees for determinations of minimum initial

offsite response measures.

Contrary to the above, from September 2019 to April 5, 2023, the licensee failed to follow and

maintain the effectiveness of an emergency plan which met the requirements in

10 CFR Part 50 Appendix E and the planning standards of 10 CFR 50.47(b). Specifically, the

licensee failed to maintain a standard emergency classification scheme as required by

10 CFR 50.47(b)(4) as a result of calibration errors for drywell and containment area radiation

monitors used for making General Emergency (GE) classifications. These calibration errors

8

failed to provide reasonable assurance that the monitors will remain operable and provide

timely and accurate radiological information to the licensee during accident conditions.

Apparent Violation #3: TS 3.3.3.1 LCO Action - Failure to maintain the drywell and

containment high range area radiation monitors operable and initiate action to prepare and

submit a Special Report to the NRC immediately

Technical Specification (TS) 3.3.3.1 requires, in part, that the post-accident monitoring (PAM)

instrumentation for each function in Table 3.3.3.1-1 shall be operable. Condition C requires,

in part, that with one or more functions with two required channels inoperable, restore one

required channel to operable status with 7 days. Condition D requires, in part, that with the

required action and associated completion time of Condition C not met, enter the Condition

referenced in Table 3.3.3.1-1 for the channel immediately. Table 3.3.3.1-1 Function 12,

Primary Containment Area Radiation, and Function 13, Drywell Area Radiation, reference

Condition F. Condition F requires, in part, that as required by required action D.1 and

referenced in Table 3.3.3.1-1, initiate action to prepare and submit a Special Report

immediately.

Contrary to the above, on December 23, 2022, the licensee failed to initiate an action to

prepare and submit a Special Report after 7 days had elapsed with two required PAM

instrumentation channels inoperable. Specifically, on December 16, 2022, NRC inspectors

reviewed the radiation source check data and sensitivity parameter data for each of the

drywell and containment high range monitors (detectors) during the calibration surveillance in

accordance with procedure 06-IC-1D21-R-1002 and identified the value for all four detectors

was outside of acceptable tolerances per industry acceptance criteria and standards, but the

licensee still declared them operable. As a result, the licensee failed to initiate the LCO

action.

Enforcement Action: These violations are being treated as apparent violations pending a final

significance (enforcement) determination.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On April 5, 2023, the inspectors presented the preliminary White significance inspection

results to Brad Kapellas, Site Vice President, and other members of the licensee staff.

9

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.05 Corrective Action CR-GGN-YYYY- 2017-00612, 2017-06876, 2022-02940, 2022-03094, 2022-

Documents XXXXX 10690, 2022-11351

71124.05 Miscellaneous Assessment of Calibration Status for Grand Gulf High Range 02/28/2023

Area Monitors

71124.05 Miscellaneous Grand Gulf Emergency Preparedness (EP) Position Paper 12/20/2022

22-01: All Channels of Containment and Drywell Radiation

Monitoring declared INOPERABLE

71124.05 Miscellaneous NRC Questions and Responses from EP Position Paper 22- 01/17/2023

01

71124.05 Miscellaneous GG Responses to NRC Questions on Operability Evaluation 01/17/2023

per CR-GGN-2022-11351

71124.05 Miscellaneous Licensee Response to Questions from the 12/02/22 RP 12/15/2022

Inspection Status Update Call

71124.05 Miscellaneous 460000136 Victoreen Radiation Monitors Vendor Manual 08/08/1995

71124.05 Miscellaneous 877-1-1 Fluke Biomedical Victoreen 875 High Range Containment 05/2021

Monitor Operators Manual

71124.05 Miscellaneous GIN 2021-00062 Grand Gulf Nuclear Station EAL Technical Basis - 1

Emergency Plan

71124.05 Miscellaneous ML15127A549 GRAND GULF NUCLEAR STATION - NRC INTEGRATED 05/12/2015

INSPECTION REPORT 05000416/2015001

71124.05 Miscellaneous ML17235B265 GRAND GULF NUCLEAR STATION - NRC RADIATION 08/22/2017

PROTECTION INSPECTION REPORT 05000416/2017012

AND NOTICE OF VIOLATION

71124.05 Operability CR-GGN-2022- Operability Evaluation of Containment/Drywell High Range 11/22/2022

Evaluations 10690 Radiation Monitors - Sensitivity Check

71124.05 Operability CR-GGN-2022- Operability Evaluation of Containment/Drywell High Range 12/19/2022

Evaluations 11351 Radiation Monitors - Sensitivity Check

71124.05 Procedures 06-IC-1D21-R- Containment/Drywell High Range Area Radiation Monitor 113

1002 Calibration

71124.05 Procedures EN-OP-104 Operability Determination Process 17

05-S-01-EP-2 RPV Control 3

71124.05 Work Orders WO 00542468-01 1D21N048A: Replace In-Drywell Radiation Detector 03/17/2022

10

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.05 Work Orders WO 00542472-01 1D21N048D: Replace In-Drywell Radiation Detector 03/18/2022

71124.05 Work Orders WO 52782236-01 06IC1D21-R-1002-03 Channel B (Containment) Calibration 09/05/2019

Record

71124.05 Work Orders WO 52782237-01 06IC1D21-R-1002-03 Channel C (Containment) Calibration 10/30/2019

Record

71124.05 Work Orders WO 52842051-01 06IC1D21-R-1002-03 Channel A (Drywell) Calibration 04/05/2020

Record

71124.05 Work Orders WO 52842512-01 06IC1D21-R-1002-03 Channel D (Drywell) Calibration 04/05/2020

Record

71124.05 Work Orders WO 52900509-01 06IC1D21-R-1002-03 Channel B (Containment) Calibration 09/02/2021

Record

71124.05 Work Orders WO 52906611-01 06IC1D21-R-1002-03 Channel C (Containment) Calibration 06/24/2021

Record

11