ML20352A119
| ML20352A119 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 12/10/2020 |
| From: | Saporito T Nuclear Energy Oversight Project |
| To: | NRC/OE, Division of Nuclear Materials Safety IV |
| References | |
| Download: ML20352A119 (3) | |
Text
From:
R4Enforcement To:
Howell, Linda; Warnick, Greg; Greene, Natasha Cc:
Groom, Jeremy
Subject:
Email from Thomas Saporito Date:
Thursday, December 10, 2020 4:13:45 PM Attachments:
2020.12.10 Grand Gulf Nuclear Plant.pdf The email below and the attached file were in the R4Enforcement mailbox.
From: Thomas Saporito <saporito@gmx.com>
Sent: Thursday, December 10, 2020 12:02 PM To: R4Enforcement <R4Enforcement.Resource@nrc.gov>
Cc: Doane, Margaret <Margaret.Doane@nrc.gov>; Pensacola Grand Hotel
<esmith792_xbf@indeedemail.com>
Subject:
[External_Sender] December 10, 2020 NRC Regulatory Conference - Grand Gulf Nuclear Plant
The Nuclear Energy Oversight Project (NEOP) is providing a written copy of comments made by Thomas Saporito, Executive Director, during the subject matter NRC Regulatory Conference. Please review the attached NEOP document.
Should you have any questions regarding this matter, please contact me at your convenience.
Best regards, Thomas Saporito Nuclear Energy Oversight Project Thomas Saporito, Executive Director 9995 SE Federal Hwy UNIT 1763 Hobe Sound, FL 33475 Phone: 772-206-2489
Nuclear Energy Oversight Project Oversight of the U.S. Nuclear Regulatory Commission to protect public health and safety and the environment 9995 SE Federal Hwy. Unit 1763 Thomas Saporito Hobe Sound, Florida 33475 Executive Director Email: saporito@gmx.com Phone: (772) 206-2489 December 10, 2020 NRC Regulatory Conference Grand Gulf Nuclear Plant NRC Inspection Report 05000416/2020015 PUBLIC CONFIDENCE ISSUE First concern regarding public confidence is the fact that the apparent violation occurred on May 22, 2020, but was not identified to the NRC until June 2, 2020.
Second concern regarding public confidence is that the licensee relies on the integrity of the type B shipping cask asserting that a low risk to the health and safety of the public due to the construction of the type B shipping cask.
Here the licensee's assertions are erroneous because public confidence depends on whether or not an unwarranted release of radiological particles into the environment would occur during a "worst case scenario" where the shipping carrier's vehicle transporting the type B cask would collide with a fuel tank truck vehicle. Such a collision would have a very HIGH probability of actually melting the type B shipping cask and thereby breaching the integrity of the cask. The resultant plum of radiological particles with a dose rate of at least 1 millirem or greater would then be released into the environment and could travel in excess of 100 miles dependent of the prevailing winds at that time.
To the extent that the drive or anyone else survived the accident and was able to notify emergency first responder personnel, the time lapse would significantly place the health and safety of the public in great jeopardy, from exposure to the radiological airborne release.
To the extent that no person survived the accident, the delay for emergency first responder personnel to arrive and to assess the situation would further significantly place the health and safety of the public in great jeopardy, from exposure to the radiological airborne release.
Here the licensee's corrective actions should include modification to their station 1/2
procedures to include prior notification to emergency first responder agencies about the date and time and route of the expected shipment classified as ERG 163 to enable emergency first responder agencies to adequately prepare and be on alert for responding to such an emergency.
The licensee's corrective actions should also include modification to their station procedures to include a visual confirmation that the transport driver has the required "orange book" or whatever emergency information is required to transport the respective radiological shipment.
The licensee's corrective actions should also include modification to their station procedures to involve the Quality Assurance and Quality Control personnel with a sign off step to verify the radiological dose rate and identification of the shipment.
The licensee's corrective actions should also include modification to their station procedures to ensure that human radiological dose rate measurements are taken and recorded in addition to the licensee's use of the RADMAN computer program.
Third concern regarding public confidence concerning this event is that the licensee appears to have a training deficiency which the licensee has not fully addressed today with the NRC.
Finally, public confidence is further eroded concerning this event to the extent that the licensee attempted to defend a public confidence issue by assertions about the structure integrity of the shipping container - rather than recognize that public confidence related to this event requires the licensee to strictly follow and/or modify their station procedures and enhance personnel training to prevent recurrence of violation NRC regulations and requirements related to the shipment of radiological materials.
For all these reasons, the NRC should regard this event to be a high risk to the health and safety of the public and classify this event a WHITE with a proper notice of violation and civil monetary penalty to prevent recurrence.
The licensee's self-identification of this event was very late and the licensee's corrective actions are seriously deficient and do not warrant any credit towards NRC enforcement actions.
For the Nuclear Energy Oversight Project Thomas Saporito Executive Director 2/2