ML17235B265
| 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
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
2
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.
4
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)
5
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
6
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
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.
7
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
9
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
10
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].
11
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.
12
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
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
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
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.
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