IR 05000416/2017012: Difference between revisions

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{{Adams
{{Adams
| number = ML17269A031
| number = ML18038B584
| issue date = 09/21/2017
| issue date = 02/07/2018
| title = Grand Gulf, Unit 1, Reply to Notice of Violation from Inspection Report 05000416/2017012
| title = Grand Gulf Nuclear Station, Unit 1, Response To Clarification Of Initial Response To a Notice Of Violation And Nuclear Regulatory Commission Inspection Report 05000416/2017012
| author name = Larsen E A
| author name = Gepford H J
| author affiliation = Entergy Operations, Inc
| author affiliation = NRC/RGN-IV/DRS/PSB-2
| addressee name =  
| addressee name = Larson E
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| addressee affiliation = Entergy Operations, Inc
| docket = 05000416
| docket = 05000416
| license number = NPF-029
| license number = NPF-029
| contact person =  
| contact person =  
| case reference number = GNR0-2017/00059
| document report number = IR 2017012
| document report number = IR 2017012
| document type = Letter, Licensee Response to Notice of Violation
| document type = Letter
| page count = 5
| page count = 3
}}
}}


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=Text=
=Text=
{{#Wiki_filter:---Entergy GNR0-2017/00059 September 21, 2017 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
{{#Wiki_filter:
[[Issue date::February 7, 2018]]


SUBJECT: Reply to Notice of Violation Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29 Entergy Operations, Inc. 7003 Bald Hill Road P. 0. Box756 Port Gibson, MS 39150 Eric A. Larsen Vice President, Operations Tel. (601) 437-7500 REFERENCE: Grand Gulf Nuclear Station -NRC Radiation Protection Inspection Report 05000416/2017012 and Notice of Violation August 22, 2017
Mr. Eric Larson, Site Vice President Entergy Operations, Inc.


==Dear Sir or Madam:==
Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150
Entergy Operations, Inc. (Entergy) hereby submits the Reply to Notice of Violation for Grand Gulf Nuclear Station in Attachment 1. This Notice of Violation was issued in Nuclear Regulatory Commission Radiation Protection Inspection Report No. 05000416/2017012 and Notice of Violation August 22, 2017. There are no regulatory commitments contained in this letter. If you have any questions or require additional information, please contact Douglas Neve at (601) 437-2103.


Sincerely,Eric A. Larson Vice President, Operations EAUdre
SUBJECT: GRAND GULF NUCLEAR STATION, UNIT 1, RESPONSE TO CLARIFICATION OF INITIAL RESPONSE TO A NOTICE OF VIOLATION AND NUCLEAR REGULATORY COMMISSION INSPECTION REPORT 05000416/2017012


===Attachments:===
==Dear Mr. Larson:==
1. Response to Notice of Violation cc: (see next page)
Thank you for your letter of December 21, 2017, (ML17362A041) which provided clarifying information to supplement your September 21, 2017, reply (ML17269A031) to the Notice of Violation concerning calibration of the main steam line and containment/drywell high range radiation monitors. The Notice of Violation was issued on August 22, 2017, in NRC Inspection Report 05000416/2017012 (ML17235B265).
GN R0-2017 /00059 Page 2 of 2 cc: Mr. Scott Morris Acting -Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 U. S. Nuclear Regulatory Commission ATTN: Mr. Siva Lingam Mail Stop OWFN/8 G14 11555 Rockville Pike Rockville, MD 20852-2378 State Health Officer Mississippi Department of Health P. 0. Box 1700 Jackson, MS 39215-1700 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 Attachment 1 GNR0-2017/00059 Reply to Notice of Violation Attachment to GNR0-2017/00059 Page 2 of 2 REPL V TO NOTICE OF VIOLATION I. Cited Violation During a Nuclear Regulatory Commission (NRC) inspection conducted on June 10-14, 2017, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: 1 O 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 us.ing industry accepted calibration methods and tolerances. This violation is associated with a Green Significance Determination Process finding. II. The Reason for the Violation Entergy concurs with the violation. The reason for the violation is that Entergy failed to have a procedure that sufficiently implemented industry standards to calibrate the subject radiation monitors. After the issue was identified in 2012, Entergy failed to take timely actions to correct the condition, due to lapses in the implementation of the issue action plan. Ill. Corrective Steps Which Have Been Taken and Results Achieved Entergy has reviewed the previous calibrations performed and determined that, although the calibrations were not compliant with industry accepted calibration methods and tolerances, the monitors were operable/functional. The Drywell and Containment Radiation Monitors have been successfully tested in accordance with NUREG-0737, per plant operating procedure 06-IC-1D21-R-1002. This testing was performed using traceable and calibrated source material, a repeatable process, geometry, control of test fixtures, and was performed through all decades of response. The Main Steam Line Radiation Monitors have been successfully tested in accordance with American National Standards Institute (ANSI) N13.1-1969, per plant operating procedure 06-IC-1D17-R-1002. This testing was performed using traceable and calibrated source material, a repeatable process, geometry, control of test fixtures, and was performed through all decades of response.


Attachment to GNR0-2017/00059 Page 2 of 2 IV. Corrective Steps That Will be Taken There are no additional steps necessary to ensure continued compliance. V. Date When Full Compliance Will be Achieved GGN achieved full compliance on September 21, 2017.
The NRC identified several discrepancies in your initial response that required clarification. We have reviewed these clarifications in conjunction with your initial response to the Notice of Violation and find that they address the violation and the corrective actions taken. Following review of your responses to the Notice of Violation, we concluded that the surveillances performed on the main steam line and containment/drywell high range radiation monitors in response to the Notice of Violation demonstrate reasonably accurate instrument responses. However, the changes to the calibration procedures themselves warrant additional review. In particular, we noted that the procedures continue to allow tolerances significantly wider than industry norm. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
 
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice and Procedure," a copy of this letter will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access Management System (ADAMS), accessible from the NRC's Web site at http://www.nrc.gov/reading-rm/adams.html. The NRC also includes significant enforcement actions on its Web site at https://www.nrc.gov/reading-rm/doc-collections/enforcement/actions/.
 
Sincerely,/RA/
Heather J. Gepford, Ph.D., CHP Chief, Plant Support Branch 2 Division of Reactor Safety Docket No. 50-416 License No. NPF-29
 
cc: Electronic Distribution GRAND GULF NUCLEAR STATION, UNIT 1, RESPONSE TO CLARIFICATION OF INITIAL RESPONSE TO NOTICE OF VIOLATION AND NUCLEAR REGULATORY COMMISSION INSPECTION REPORT 05000416/2017012 - February 7, 2017 DISTRIBUTION: KKennedy, RA SMorris, DRA TPruett, DRP AVegel, DRS RLantz, DRP JClark, DRS SKirkwood, RC JKozal, DRP CYoung, DRP MYoung, DRP TSteadham, DRP NDay, DRP AAthar, DRP AElam, DRP JBowen, RIV/OEDO VDricks, ORA JWeil, OCA SLingam, NRR AMoreno, RIV/CAO BMaier, RSLO THipschman, IPAT EUribe, IPAT TDeBey, DRP MHerrera, DRMA R4Enforcement
 
DOCUMENT NAME: R:\_REACTORS\_GG\2017\GG2017012 Ack Ltr to GG Clarification of NOV Response.docx ADAMS ACCESSION NUMBER: ML18038B584 SUNSI Review: ADAMS:  Non-Publicly Available Non-Sensitive Keyword: By: JJO  Yes No Publicly Available  Sensitive NRC-002 OFFICE HP:DRS/PSB2 C:DRS/PSB2 C:DRP/PBC C:DRS/PSB2 NAME JO'Donnell HGepford JKozal HGepford SIGNATURE /RA/ /RA/ /RA/ /RA/ DATE 2/6/18 2/618 2/7/18 2/7/18 OFFICIAL RECORD COPY
}}
}}

Revision as of 16:44, 18 February 2018

Grand Gulf Nuclear Station, Unit 1, Response To Clarification Of Initial Response To a Notice Of Violation And Nuclear Regulatory Commission Inspection Report 05000416/2017012
ML18038B584
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 02/07/2018
From: Gepford H J
NRC/RGN-IV/DRS/PSB-2
To: Emily Larson
Entergy Operations
References
IR 2017012
Preceding documents:
Download: ML18038B584 (3)


Text

February 7, 2018

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, UNIT 1, RESPONSE TO CLARIFICATION OF INITIAL RESPONSE TO A NOTICE OF VIOLATION AND NUCLEAR REGULATORY COMMISSION INSPECTION REPORT 05000416/2017012

Dear Mr. Larson:

Thank you for your letter of December 21, 2017, (ML17362A041) which provided clarifying information to supplement your September 21, 2017, reply (ML17269A031) to the Notice of Violation concerning calibration of the main steam line and containment/drywell high range radiation monitors. The Notice of Violation was issued on August 22, 2017, in NRC Inspection Report 05000416/2017012 (ML17235B265).

The NRC identified several discrepancies in your initial response that required clarification. We have reviewed these clarifications in conjunction with your initial response to the Notice of Violation and find that they address the violation and the corrective actions taken. Following review of your responses to the Notice of Violation, we concluded that the surveillances performed on the main steam line and containment/drywell high range radiation monitors in response to the Notice of Violation demonstrate reasonably accurate instrument responses. However, the changes to the calibration procedures themselves warrant additional review. In particular, we noted that the procedures continue to allow tolerances significantly wider than industry norm. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice and Procedure," a copy of this letter will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access Management System (ADAMS), accessible from the NRC's Web site at http://www.nrc.gov/reading-rm/adams.html. The NRC also includes significant enforcement actions on its Web site at https://www.nrc.gov/reading-rm/doc-collections/enforcement/actions/.

Sincerely,/RA/

Heather J. Gepford, Ph.D., CHP Chief, Plant Support Branch 2 Division of Reactor Safety Docket No. 50-416 License No. NPF-29

cc: Electronic Distribution GRAND GULF NUCLEAR STATION, UNIT 1, RESPONSE TO CLARIFICATION OF INITIAL RESPONSE TO NOTICE OF VIOLATION AND NUCLEAR REGULATORY COMMISSION INSPECTION REPORT 05000416/2017012 - February 7, 2017 DISTRIBUTION: KKennedy, RA SMorris, DRA TPruett, DRP AVegel, DRS RLantz, DRP JClark, DRS SKirkwood, RC JKozal, DRP CYoung, DRP MYoung, DRP TSteadham, DRP NDay, DRP AAthar, DRP AElam, DRP JBowen, RIV/OEDO VDricks, ORA JWeil, OCA SLingam, NRR AMoreno, RIV/CAO BMaier, RSLO THipschman, IPAT EUribe, IPAT TDeBey, DRP MHerrera, DRMA R4Enforcement

DOCUMENT NAME: R:\_REACTORS\_GG\2017\GG2017012 Ack Ltr to GG Clarification of NOV Response.docx ADAMS ACCESSION NUMBER: ML18038B584 SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword: By: JJO Yes No Publicly Available Sensitive NRC-002 OFFICE HP:DRS/PSB2 C:DRS/PSB2 C:DRP/PBC C:DRS/PSB2 NAME JO'Donnell HGepford JKozal HGepford SIGNATURE /RA/ /RA/ /RA/ /RA/ DATE 2/6/18 2/618 2/7/18 2/7/18 OFFICIAL RECORD COPY