ML20357B059

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Enc 2 - Grand Gulf Nuclear Station Regulatory Conference December 2020 - NRC Presentation
ML20357B059
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 12/16/2020
From:
NRC Region 4
To:
Entergy Operations
References
Download: ML20357B059 (24)
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Text

NRC Virtual (via WebEx)

Regulatory Conference Entergy Operations, Inc.

Grand Gulf Nuclear Station USNRC Region IV Thursday, December 10, 2020 Category I Public Meeting ML20357B059 To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Meeting Logistics

  • Operation of WebEx
  • Please MUTE cellular phones
  • Scheduled break (15-minute)
  • NRC caucus (Team Meetings)
  • Public Question Session (Press *1 on phone to raise hand, then await for the Moderator to acknowledge you)

To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

MEETING AGENDA Topic Participants NRC Opening Remarks and Introductions Scott Morris Licensee Opening Remarks and Introductions Entergy, Grand Gulf Nuclear Station Regulatory Conference Process Linda Howell Agenda NRCs Dispositioning Process & Outcomes Natasha Greene, PhD Summary of Apparent Violations Greg Warnick Licensee Presentation Entergy, Grand Gulf Nuclear Station Questions and Discussion All Conference Participants Break and NRC Caucus (via Teams Meeting) NRC and Conference Participants Questions and Discussion All Conference Participants Licensee Closing Remarks Entergy, Grand Gulf Nuclear Station NRC Closing Remarks Scott Morris Public Question and Answer Session Public Attendees To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

NRC Principal Participants Linda Howell, RIV DNMS Scott Morris, USNRC Deputy Director RIV Administrator Greg Warnick, RIV Natasha Greene, PhD, DNMS/RxIB Chief RIV DNMS/RxIB Sr. HP To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Entergy Operations Inc.

Opening Remarks / Introductions To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Purpose of Regulatory Conference

  • The NRC normally provides an opportunity for a licensee to address apparent violations before the NRC takes escalated enforcement action, or makes a final decision on the significance.

and gain their perspective on the apparent violations.

  • The significance assessment determines whether an escalated enforcement action will be considered (i.e., a Notice of Violation associated with a white, yellow, or red SDP finding). Licensee input during this conference is also considered in making a final decision.

To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Todays Meeting

  • No Final Decision on safety significance or enforcement action will be made today.
  • Our NRC Inspection Report provided our current understanding and perspective on the issue.
  • We Want Your Perspective
  • Any additional details NRC should consider
  • Whether violations occurred
  • Perceived significance of the violations
  • Corrective actions implemented and/or Planned Timeline To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Public Meeting Disclaimer

  • This is a Category 1 Public Meeting.
  • At a Category I meeting, the public is invited to observe the meeting and will have one or more opportunities to communicate with the NRC after the business portion, but before the meeting is adjourned.

To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Grand Gulf Non-LSA Shipment Event NRC informed on June 2, 2020 NRC issued a Choice Letter to GGNS on October 29, 2020 (ML20303A214; EA-20-094)

To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Performance Deficiency 5/22/2020 Per our understanding, the licensee failed to meet NRC requirement of 10 CFR 71.5(a) for failure to comply with all DOT regulations in 49 CFR Parts 171 through 180. Specifically, as required by 49 CFR Parts 172 and 173, the licensee failed to identify that the radiation dose rates, measured 3 meters from the unshielded liner, were higher than the calculated value for the primary resin liner associated with shipment GGN-2020-0515, exceeding 1 Rem/hour. This failure led the licensee to assign the incorrect basic description and markings to the shipment package and caused the licensee to supply the carrier with the incorrect emergency response information.

To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Reactor Oversight Process:

Significance Determination Process To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Possible Outcomes

  • The NRC determines there is no violation resulting in no enforcement action.
  • The NRC determines the apparent violations are of very low safety significance resulting in non-escalated enforcement (Green Non-Cited Violation).
  • The NRC determines the apparent violations are of low to moderate safety significance resulting in escalated enforcement (a White Finding and associated Notice of Violation).

To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Licensee's Appeal Rights

  • A licensee has the right to challenge any NRC determination/action that may be presented.
  • Instructions for challenging a NRC enforcement action are included in our transmittal letter and the action itself.

To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Apparent Violation #1

  • Title 49 CFR 172.600(c) requires, in part, that emergency response information conforming to 49 CFR 172 Subpart G is immediately available for use at all times the hazardous material is present during transport.
  • Title 49 CFR 172.602(a) requires, in part, the emergency response information, as a minimum, must contain the basic description and technical name of the hazardous material, the immediate hazards to health, and the immediate precautions to be taken in the event of an accident or incident.
  • Contrary to the above, on May 22, 2020, the licensee delivered to a carrier for transport licensed material, and the emergency response information that accompanied the shipment did not include the correct basic description of the hazardous material, the immediate hazards to health, and the immediate precautions to be taken in the event of an accident or incident, as required by 49 CFR 172.600(c) and 49 CFR 172.602(a).

To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Dispositioning the Issue:

More than Minor and Significance

  • The inspectors determined the performance deficiency was more than minor because it adversely affected the Public Radiation Safety cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation.
  • Using NRC Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, the violation was preliminarily determined to be of low to moderate safety significance (WHITE) because it was a finding in the transportation branch in which: (1) radiation limits were not exceeded, (2) there was no breach of the package during transit, (3) there were no Certificate of Compliance issues, (4) it was not a low-level burial ground nonconformance, but (5) it was a failure to provide emergency response information as required by 49 CFR 172.602 (See Figure 1 - Block N2).

To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

IMC 0609, Appendix D - Transportation Branch of SDP To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Apparent Violation #2

  • Title 49 CFR 172.101 requires, in part, that the designation of UN 3321 be assigned to LSA-II, non-fissile or fissile-excepted packages and the designation of UN 2916 be assigned to Type B(U), non-fissile or fissile-excepted packages.
  • Contrary to the above, on May 22, 2020, the licensee offered for transportation or transport a hazardous material in bulk packaging, and the licensee failed to mark the packaging with the identification number marking specified for this material in 49 CFR 172.101.

To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Apparent Violation #3

  • Title 49 CFR 173.427(a)(1) requires, in part, that low specific activity material must be transported in accordance with the condition that the external dose rate may not exceed an external radiation level of 1 Rem/hour at 10 feet from the unshielded material.
  • Contrary to the above, on May 22, 2020, the licensee delivered licensed material to a carrier for transport with an external dose rate that exceeded an external radiation level of 1 Rem/hour at 10 feet from the unshielded material.

To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Apparent Violation #4

  • Title 49 CFR 173.22(a)(1) requires, in part, that except as otherwise provided in 49 CFR Part 173, a person may offer a hazardous material for transportation in a packaging or container required by 49 CFR Part 173 only if the person shall class and describe the hazardous material in accordance with 49 CFR Parts 172 and 173.
  • Contrary to the above, on May 22, 2020, the licensee offered hazardous material for transportation in a packaging or container required by 49 CFR Part 173 and failed to describe the hazardous material in accordance with 49 CFR Parts 172 and 173.

To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Entergy - Grand Gulf Nuclear Station Presentation Agenda To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

NRC and Entergy Staff Q&A Session To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

NRC Regulatory Conference with Entergy Operations, Inc.

Grand Gulf Nuclear Station NRC Caucus in Session Returning Shortly To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Conference Closing Remarks

  • Licensees Closing Remarks
  • NRCs Closing Remarks
  • Next Steps / Expectations
  • The platform is now OPEN to questions from our public attendees PLEASE press *1 on your phone and await the Moderator to announce you.

To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

Any Questions from the Public Attendees?

(Please press *1 on your phone to raise your hand and await the Moderator)

To hear the audio portion of this presentation, dial 1-888-813-9023 and enter participant code # 9612303.

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