IR 05000416/2025011

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Radiography Camera Issue Follow-up - Inspection Report 05000416/2025011
ML25135A077
Person / Time
Site: Grand Gulf 
(NPF-029)
Issue date: 05/20/2025
From: Jeffrey Josey
NRC/RGN-IV/DRSS/DIOR
To: Kapellas B
Entergy Operations
References
IR 2025011
Download: ML25135A077 (1)


Text

May 20, 2025

SUBJECT:

GRAND GULF NUCLEAR STATION - NRC INSPECTION REPORT 05000416/2025011

Dear Brad Kapellas:

On May 1, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Grand Gulf Nuclear Station and discussed the results of this inspection with Jason Richardson, General Manager of Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.

One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

No NRC-identified or self-revealing findings were identified during this inspection.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Grand Gulf Nuclear Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Jeffrey E. Josey, Chief Decomm, ISFSI and Operating Reactors Branch Division of Radiological Safety and Security Docket No. 05000416 License No. NPF-29

Enclosure:

As stated

Inspection Report

Docket Number:

05000416

License Number:

NPF-29

Report Number:

05000416/2025011

Enterprise Identifier:

I-2025-011-0022

Licensee:

Entergy Operations Incorporated

Facility:

Grand Gulf Nuclear Station

Location:

Port Gibson, MS

Inspection Dates:

November 11, 2024, to May 01, 2025

Inspectors:

L. Carson, Senior Health Physicist

N. Greene, Senior Health Physicist

Approved By:

Jeffrey E. Josey, Chief

Decomm, ISFSI and Operating Reactors Branch

Division of Radiological Safety and Security

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 Receive and Possess Byproduct Radioactive Material with an Authorized License Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000416/2025011-01 Open/Closed Not Applicable 71124.08 The NRC identified a violation of 10 CFR 30.3(a) when the licensee, Grand Gulf Nuclear Station, took receipt and possession of licensed byproduct material that they were not authorized or licensed to receive, in a specific or general license, in accordance with regulations. The licensee acknowledges that the radiography camera with category-2 quantities of radioactive material was received by the warehouse staff in the best interest of the publics health and safety.

Additional Tracking Items

None.

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

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &

Transportation Radioactive Material Storage (IP Section 03.01) (1 Partial)

The inspectors evaluated the licensees performance in controlling, labeling and securing the following radioactive materials:

(1)

(Partial)receipt of radioactive material within the licensee's owner-controlled area

INSPECTION RESULTS

Failure to Receive and Possess Byproduct Radioactive Material with an Authorized License Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000416/2025011-01 Open/Closed Not Applicable 71124.08 The NRC identified a violation of 10 CFR 30.3(a) when the licensee, Grand Gulf Nuclear Station, took receipt and possession of licensed byproduct material that they were not authorized or licensed to receive, in a specific or general license, in accordance with regulations. The licensee acknowledges that the radiography camera with category-2 quantities of radioactive material was received by the warehouse staff in the best interest of the publics health and safety.

Description:

In February 2022, the licensees non-destructive (NDE) contractor ordered a radiography camera, containing a category-2 quantity of radioactive material, to support work being done on site and used the Grand Gulf Nuclear Station (GGNS) mailing address as the receipt address. The contractor did not communicate with the licensee that they were expecting to receive the radiography camera at the GGNS facility in the owner-controlled area.

On March 7, 2022, at approximately 12:00 p.m., the licensee received via FedEx and took possession of a radioactive shipment (the radiography camera) that they were not expecting.

The licensee determined that the shipment was supposed to be sent to their NDE contractor who was not onsite. The shipment was placed in a locked radioactive material cage within the owner-controlled area, and warehouse staff contacted radiation protection staff for assistance with the delivery.

Radiation protection staff completed a radioactive material receipt survey on the shipment at 2:30 p.m., on March 7, 2022, and determined that the shipment contained a category-2 quantity of radioactive material. Subsequently, at 7:48 p.m., the licensees security force secured the radioactive material in accordance with requirements of 10 CFR Part 37 and station Procedure 11-S-21-6, "Protection of Category 1 and Category 2 Quantities of Radioactive Material," revision 2.

On March 8, 2022, at 10:56 a.m, the Security Department released the radiography camera to their contract NDE technician for storage inside the protected area, in the Turbine Building.

Subsequently, on March 9, 2022, the intended NDE vendor took possession of the radiography camera, according to records reviewed.

The licensees position is that they took the most appropriate actions for the consideration of public health and safety. NRC understands this approach and considers the best applicable NRC Enforcement Policy example that addresses these actions.

The GGNS license has conditions in section 2.B that require the licensee to follow the requirements of 10 CFR Part 30. The applicable license conditions are:

(4) EOI, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required;
(5) EOI, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and
(6) EOI, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

10 CFR 30.3(a) requires, in part, that except for persons exempted, no person shall receive or possess byproduct material except as authorized by a specific or general license issued in accordance with 10 CFR Chapter I.

Therefore, from March 7 through March 8, 2022, GGNS received and possessed byproduct material, a category-2 quantity of radioactive material in an industrial radiography device, for which GGNS did not have a specific or general license in accordance with 10 CFR 30.3(a).

Corrective Actions: The licensee identified that their procedures for receipt of radioactive material did not address actions for the receipt of a radiography device containing category-2 quantities of radioactive material. However, the licensee did not initially apply adequate corrective actions for station personnel because they had failed to recognize the issue of inappropriately receiving a radiography camera without a specific or general license in March 2022. NRC inspectors had to point this out to the licensee which resulted in initiation of CR-GGNS-2024-06669 to address this aspect. Thus, the licensee documented this issue into their corrective action program, scheduled training for licensee staff on receipt of packages not authorized by their license, and reviewed their applicable procedures for deficiencies.

Corrective Action References: CR-GGN-2022-02333, CR-GGN-2022-02663, CR-GGN-2024-06669, and CR-GGN-2025-02053

Performance Assessment:

None

Enforcement:

The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.

Severity: This issue was determined to be a Severity Level IV (SLIV), non-cited violation, consistent with NRCs Enforcement Policy, dated August 23, 2024, as informed by (materials operations) example 6.3.d.7, in which, A licensee fails to seek required NRC approval before the implementation of a change in ownership that results in little or no adverse impact on radiological or programmatic activities or on the NRCs ability to inspect licensed activities, such that the locations and types of activities are unaffected by the unauthorized license transfer. In this case, the inspectors determined that the licensee, GGNS, failed to seek NRC approval to take receipt and possession, even on a temporary basis, of a category-2 quantity of radioactive material in an industrial radiography camera, which requires a specific license, but due to the licensees implementation of radiological and Part 37 security controls, the non-compliance caused no adverse impacts.

Violation: License Condition 2.B.(4), (5), and

(6) specifies, in part, that pursuant to 10 CFR 30 the licensee is authorized receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for activities such as sample analysis, byproduct and special nuclear materials as may be produced by the operation of the facility and radiation monitoring equipment calibration, and as fission detectors.

10 CFR 30.3(a) requires, in part, that except for persons exempted, no person shall receive or possess byproduct material except as authorized by a specific or general license issued in accordance with 10 CFR Chapter I.

Contrary to the above, on March 7, 2022, the licensee received and possessed byproduct material, a category-2 quantity of radioactive material in an industrial radiography device, and they did not have a specific or general license issued to the Grand Gulf Nuclear Station in accordance with the regulations in this chapter.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

  • On May 1, 2025, the inspectors presented the NRC inspection results to Jason Richardson, General Manager of Plant Operations, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Corrective Action

Documents

CR-GGN-YYYY-

XXXXXX

22-02333, 2022-02663, 2024-06669, 2025-02053

11-S-21-6

Protection of Category 1 and Category 2 Quantities of

Radioactive Material

EN-MP-125

Control of Material

71124.08

Procedures

EN-RP-121-01

Receipt of Radioactive Material

7