ML20357B061

Enc 3 - Entergy Slides for Regulatory Conference December 2020 - Final

ML20357B061
Person / Time
Site:	Grand Gulf
Issue date:	12/16/2020
From:	Entergy Operations
To:	NRC Region 4
References
Download: ML20357B061 (31)

Text

Grand Gulf Nuclear Station Radioactive Material Transportation Regulatory Conference December 10, 2020 ML20357B061

Introduction and Agenda Jim Shaw Regulatory Assurance Manager Grand Gulf Nuclear Station 1

Agenda Introduction and Agenda Jim Shaw, Regulatory Assurance Manager Management Overview Bob Franssen, Site Vice President - Grand Gulf Condition Description and Event Details Mark Travis, Radiation Protection Manager Root Cause and Corrective Actions Brad Cole, Senior Manager - Fleet Radiation Protection Safety Significance Jim Shaw, Regulatory Assurance Manager Closing Comments Bob Franssen, Site Vice President - Grand Gulf 2

Management Overview Bob Franssen Vice President Grand Gulf Nuclear Station 3

4 Condition Description and Event Details Mark Travis Radiation Protection Manager Grand Gulf Nuclear Station 5

Condition Description

• On May 22, 2020, a radioactive waste shipment left Grand Gulf Nuclear Station (Grand Gulf) with incorrect radioactive material shipment marking, numbering, and provision of emergency response information. This error caused violations of federal regulations:

10 CFR 71 (Compliance with 49 CFR 172) 49 CFR (Transportation Characterization and Packaging Requirements) 6

Based on the facts that the radioactive waste was shipped in the proper cask, transported correctly and relevant information about the ERGs, Entergys assessment is that this issue has very low safety significance.

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Cask is Robust Designed to 10 CFR 71.71 and 10 CFR 71.73 requirements for Normal Conditions of Transport (NCT) and Hypothetical Accident Conditions (HAC)

Approved by NRC for transport Outer shell - 1.5 thick steel Inner shell - 0.75 thick steel Annular space between the shells is 3.35 and is filled with lead Cask base is (2) 3.25 thick circular steel plates Cask lid is (2) 3.25 thick circular steel plates Top and bottom of the cask have impact limiters Pre-shipment leak testing is performed by a qualified test individual to assure package integrity 8-120 Type B Shipping Package 8

Example of Robust Cast Transportation Configuration 9

Shipment Preparation

• Package Characterization Preparation Resin loaded Waste stream selected Container weighed and surveyed Surveys used for characterization Proper Shipping Name selected

• Shipping Cask Classification Preparation Inspected Container loaded in cask Cask closed and leak tested Cask surveyed Shipping papers created and provided to driver 10

Actual Cask For May 22, 2020 Shipment 11

As shipped Correct marking First Responders and Carrier required to have 12

Page 80 Page 65 13

ERG 162 ERG 163 14

ERG Summary In this case, the Emergency Response Guidance provided by the Hazard Identification Number would have provided the necessary actions to first responders ERG 162 and ERG 163 have no significant differing directions to first responders for this shipment Because of the information from ERG 162, public safety would have been appropriately provided for this shipment 15

Root Cause and Corrective Actions Brad Cole Entergy Fleet Senior Manager Radiation Protection 16

Root Cause Evaluation Root Cause: The Grand Gulf process for preparing and shipping Type A and Type B radioactive material shipments did not include designation for risk significance and consequently the opportunity for Grand Gulf leadership to have the necessary level of added oversight and management of the shipment preparation.

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Completed Corrective Actions

• Revised Fleet Radiological Risk Procedure, EN-RP-110-04 Radioactive Shipments involving Type B packaging are now considered high risk Provides visibility of work during planning that has a high-risk task Requires Radiation Protection Manager approval of mitigating plan Embeds mitigating strategies, where identified, in work control documents or Radiation Work Permit Requires direct leadership oversight 18

Completed Corrective Actions

• EN-RW-102, Radioactive Shipping Procedure

• Clarified the Independent Reviewer Responsibilities

• Clarified the role and proficiency requirements to perform the independent verification sign offs during the review of technical information 19

Completed Corrective Actions Procedure Revision Measured data will be used versus calculated data when available Process steps that, if performed incorrectly, could weaken barriers for public safety are required to have an independent verification Revised specific guidance for use of the override function of RADMAN software 20

Safety Significance Jim Shaw Regulatory Assurance Manager Grand Gulf Nuclear Station 21

Safety Significance Apparent Violation Violation of 49 CFR 172 involving Grand Gulf Nuclear Stations failure to ensure that shipment was manifested and marked, and driver was provided with correct emergency response information 22

Safety Significance Assessed under the NRCs Reactor Oversight Process (ROP)

Public Radiation Safety Significance Determination Process (SDP)

• Transportation branch of the logic diagram focuses on the licensees radioactive material packaging and transportation program o Assesses the licensees ability to safely transport radioactive material on public roadways in accordance with regulations o The regulatory basis for the transportation program is contained in 10 CFR Parts 20, 61, and 71, and Department of Transportation regulations contained in 49 CFR Parts 170-189 23

NRC Preliminary Significance Assessment (Based on Grand Gulf NRC Inspection Report 2020-015 / EA 20-094)

Failure to make notifications or No Green provide emergency info The significance of the finding was assessed using IMC 0609, Appendix D, Public Radiation Safety SDP.

The finding was preliminarily determined to be of low to moderate safety significance (WHITE) because it was a finding in the transportation branch in which ... it was a failure to provide emergency response Yes information as required by 49 CFR 172.602.

N2 No N3 No N4 No N1 No Failure to provide Failure to Failure to Failure to emergency respond during make Green comply with 10 CFR 71.97 response info actual request notification Yes Yes Yes Yes White White White White For Block N2, if the licensee fails to provide the required emergency response information to the shipment carrier (the shipment leaves the Licensees facility and control without the required information), the finding is WHITE. If the carrier misplaces or loses the information (beyond the licensees control), the finding is GREEN. 24

Entergys Assessment of Significance IMC 0609, Appendix D, Section VII: Failure to provide these required notifications could seriously hamper or prevent the ability of the federal, state and local agencies to adequately respond as needed to transportation events and accidents. By hampering or preventing this regulatory response, the public health and safety could be negatively impacted.

Entergys Assessment:

Entergy provided sufficient information that would not seriously hamper or prevent an adequate response to a transportation event or accident. The public health and safety was not and would not have been negatively impacted.

Safety Significance is Very Low 25

Enforcement Perspective Possibility of a Release of Radioactivity was Very Low (robust, correct cask used)

Potential Consequences to the Public was Very Low (acceptable emergency response information)

Grand Gulf - May 22, 2020 Radioactive Waste Shipment Public Confidence Maintained For this Shipment 26

Possibility of a Release of Radioactivity was Very Low Package meets requirements of 10 CFR 71.71 and 71.73 Properly tested and packaged as Type B Properly placarded Category II requirements met Radiation limits not exceeded No breach in transit - safely transported No Certificate of Compliance issues 27

Potential Consequences to the Public was Very Low Assessed the significance of the impact to public health and safety (IMC 0609, Appendix D)

Potential impact is very low based on package testing and qualification Qualification encompass potential scenarios that impact public safety Cask is accepted and certified by the NRC The Emergency Response telephone number was provided with the shipment Actual emergency response would likely not have been impacted due to the similarities of the ERGs in this instance 28

Public Confidence Maintained For This Shipment Emergency Response Information in ERG 162 and ERG 163 very similar with no significant differing direction to first responders Possibility of a Release of Radioactivity was Very Low Potential Consequences to the Public was Very Low Shipment arrived safely in correct package with no actual consequences IMC 0609, Appendix D - should be assessed as very low safety significance Entergys view is that the significance of the apparent violations at Grand Gulf should be assessed as one finding of very low safety significance (GREEN) 29

Closing Remarks Bob Franssen Vice President Grand Gulf Nuclear Station 30