The inspectors identified a Green
NCV of
10 CFR 71.5, Transportation of Licensed Material, and 49 CFR 172, Subpart I, Safety and Security Plans. Specifically, Entergy personnel shipped a radioactive quantity of category 2 Radioactive Material in Quantities of Concern (
RAM-QC) on the public highways to a waste processor without adhering to its transportation security plan. Prior to shipment, Entergy staff failed to recognize that the quantity of radioactive material met the definition of
RAM-QC. Entergy staff entered this issue into their corrective action program (
CAP) as condition report (CR)-JAF-2014-02337. The issue was more than minor because it was associated with the Program and Process attribute of the
Public Radiation Safety cornerstone and affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain. In accordance with
IMC 0609, Appendix D, "
Public Radiation Safety Significance Determination Process," the finding was determined to be of very low safety significance (Green) because Entergy had an issue involving transportation of radioactive material, but it did not involve: (1) a radiation limit exceeded; (2) a breach of package during transport; (3) a certificate of compliance issue; (4) a low level burial ground nonconformance; or (5) a failure to make notifications or provide emergency information. This finding had a cross-cutting aspect in the area of Human Performance, Work Processes, in that the documentation (procedures) to support this activity was inadequate [H.7].
