|
---|
Category:Inspection Report
MONTHYEARML24032A0252024-02-0505 February 2024 NRC Initial Test Program and Operational Programs Integrated Inspection Report 05200026-2023009 ML24031A6102024-01-31031 January 2024 Cyber Security Inspection Report 05200026/2024401 - Public IR 05000424/20244032024-01-26026 January 2024 Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000424/2024403; 05000425/2024403 ML23312A3502023-11-14014 November 2023 Integrated Inspection Report 05200026/2023003 ML23318A4582023-11-14014 November 2023 Integrated Inspection Report 05200025/2023003 IR 05000424/20234022023-11-0606 November 2023 Security Baseline Inspection Report 05000424/2023402 and 05000425/2023402 IR 05000424/20230032023-10-27027 October 2023 Integrated Inspection Report 05000424/2023003 and 05000425/2023003 ML23254A2032023-09-13013 September 2023 Initial Test Program and Operational Programs Inspection Report 05200025/2023013 IR 05000424/20230912023-09-0505 September 2023 Plan Units 1 and 2 - NRC Investigation Report 2-2022-006 and Notice of Violation - NRC Inspection Report 05000424/2023091 and 05000425/2023091 ML23234A3002023-09-0101 September 2023 NRC Integrated Inspection Report 05200026/2023003 IR 05000424/20230052023-08-29029 August 2023 Updated Inspection Plan for Vogtle Electric Generating Plant, Units 1 & 2 - Report 05000424/2023005 and 05000425/2023005 ML23223A0022023-08-14014 August 2023 (Vegp), Unit 3, Integrated Inspection Report 05200025/2023002 IR 05000424/20230112023-08-11011 August 2023 Biennial Problem Identification and Resolution Inspection Report 05000424/2023011 and 05000425/2023011 ML23215A0822023-08-0404 August 2023 (Vego), Unit 3 Initial Test Program and Operational Programs Integrated 05200025/2023011 Inspection Report IR 05000424/20234012023-07-31031 July 2023 Security Baseline Inspection Report 05000424/2023401 and 05000425/2023401 (Cover Letter) ML23212B0612023-07-31031 July 2023 Security Baseline Inspection Report 05200025/2023401 ML23216A0962023-07-26026 July 2023 Document Request for Vogtle 1 & 2 RP Inspection, Report No. 05000424/2023003 and 05000425/2023003 IR 05000424/20230022023-07-24024 July 2023 Integrated Inspection Report 05000424/2023002 and 05000425/2023002 ML23198A3802023-07-19019 July 2023 NRC Integrated Inspection Report 05200026/2023002 ML23199A0892023-07-18018 July 2023 (Vegp), Unit 4 Initial Test Program and Operational Programs Integrated Inspection Report 05200026/2023007 IR 05000424/20233012023-06-30030 June 2023 NRC Operator License Examination Report 05000424/2023301 and 05000425/2023301 ML23128A2932023-05-11011 May 2023 NRC Integrated Inspection Report 05200026/2023001 ML23129A0222023-05-10010 May 2023 (Vegp), Unit 3 - Integrated Report 05200025/2023001 ML23128A3492023-05-0909 May 2023 (Vegp), Unit 4 Initial Test Program and Operational Programs Integrated Inspection Report 05200026/2023006 ML23121A3202023-05-0404 May 2023 NRC Initial Test Program and Operational Programs Integrated Inspection Report 05200025/2023010 IR 05000424/20040252023-04-28028 April 2023 Public Meeting Summary - Vogtle Electric Generating Plant, Units 1, 2, 3, & 4 Docket No. 5000424, 5000425, 5200025, 5200026, Meeting Number 20230375 IR 05000424/20230012023-04-26026 April 2023 Integrated Inspection Report 05000424/2023001 and 05000425/2023001 IR 05000424/20230902023-03-30030 March 2023 NRC Inspection Report 05000424/2023090 and 05000425/2023090, and Investigation Report 2-2022-006; and Apparent Violation ML23083B3702023-03-24024 March 2023 Security Baseline Inspection Report 05200026/2023401 IR 05000424/20220062023-03-0101 March 2023 Annual Assessment Letter for Vogtle Electric Generating Plant Units 1 and 2, NRC Inspection Reports 05000424/2022006 and 05000425/2022006 ML23044A3902023-02-14014 February 2023 Integrated Inspection Report05200025 2022007 ML23040A3612023-02-0909 February 2023 NRC Initial Test Program and Operational Programs Integrated Inspection Report 05200026/2022008 ML23040A0422023-02-0909 February 2023 NRC Initial Test Program and Operational Programs Integrated Inspection Report 05200025/2022008 ML23033A3972023-02-0707 February 2023 NRC Integrated Inspection Report 05200026/2022007 IR 05000424/20220042023-01-23023 January 2023 Integrated Inspection Report 05000424/2022004 and 05000425/2022004 ML22356A2932022-12-23023 December 2022 Information Request for the Cyber Security Baseline Security Inspection, Notification to Perform Inspection IR 05000424/20220102022-12-0202 December 2022 Design Basis Assurance Inspection (Teams) Inspection Report 05000424/2022010 and 05000425/2022010 ML22327A0532022-11-30030 November 2022 Security Baseline Inspection Report 05200026/2022401 Cover Letter IR 05000424/20224032022-11-28028 November 2022 Security Baseline Inspection Report 05000424/2022403 and 05000425/2022403 (Cover Letter) ML22314A0702022-11-14014 November 2022 NRC Integrated Inspected Reports 05200025/2022005, 05200026/2022005 ML22318A1602022-11-14014 November 2022 Integrated Inspection Report 05200025/2022010 ML22304A1812022-11-0808 November 2022 NRC Initial Test Program and Operational Programs Integrated Inspection Report 05200025/2022011 ML22311A0062022-11-0808 November 2022 NRC Initial Test Program and Operational Programs Integrated Inspection Report 05200026/2022006 IR 05000424/20220032022-10-27027 October 2022 Integrated Inspection Report 05000424/2022003 and 05000425/2022003 IR 05000424/20220052022-08-24024 August 2022 Updated Inspection Plan for Vogtle Electric Generating Plant, Units 1 & 2 - Report 05000424/2022005 and 05000425/2022005 ML22230C6702022-08-22022 August 2022 NRC Initial Test Program and Operational Programs Integrated Inspection Report 05200025/2022006 ND-22-0655, ITAAC Closure Notification on Completion of ITAAC 2.5.01.03a (Index Number 511)2022-08-12012 August 2022 ITAAC Closure Notification on Completion of ITAAC 2.5.01.03a (Index Number 511) IR 05000424/20220022022-08-11011 August 2022 Integrated Inspection Report 05000424/2022002 and 05000425/2022002 ML22220A1342022-08-0909 August 2022 Review of the Refueling Outage 1R23 (Fall 2021) Steam Generator Tube Inspection Report IR 05000424/20224012022-08-0404 August 2022 Cyber Security Inspection Report 05000424/2022401 and 05000425/2022401 2024-02-05
[Table view] Category:Letter type:NL
MONTHYEARNL-24-0031, Inservice Inspection Program Owner'S Activity Report (OAR-1) for Outage 2R232024-01-29029 January 2024 Inservice Inspection Program Owner'S Activity Report (OAR-1) for Outage 2R23 NL-24-0020, Plan, Unit 1 Responses to NRC Request for Additional Information for Refueling Outage 1R24 Steam Generator Tube Inspection Report2024-01-22022 January 2024 Plan, Unit 1 Responses to NRC Request for Additional Information for Refueling Outage 1R24 Steam Generator Tube Inspection Report NL-23-0926, Correction of Technical Specification Typographical Error2024-01-12012 January 2024 Correction of Technical Specification Typographical Error NL-23-0878, Request for Exemption from Security Event Notification Implementation2023-11-29029 November 2023 Request for Exemption from Security Event Notification Implementation NL-23-0827, Response to Requests for Additional Information for a License Amendment Request and a Proposed Alternative Related to TS 3.4.142023-11-17017 November 2023 Response to Requests for Additional Information for a License Amendment Request and a Proposed Alternative Related to TS 3.4.14 NL-23-0750, Response to Second Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the Colr2023-10-0404 October 2023 Response to Second Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the Colr NL-23-0745, Refueling Outage 1R24 Steam Generator Tube Inspection Report2023-09-22022 September 2023 Refueling Outage 1R24 Steam Generator Tube Inspection Report NL-23-0695, Response to Round 2 Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters Operating, Completion Time Extension (LAR-22-002S2)2023-08-31031 August 2023 Response to Round 2 Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters Operating, Completion Time Extension (LAR-22-002S2) NL-23-0666, License Amendment Request: Remove Combined License Appendix C (LAR 23-008)2023-08-28028 August 2023 License Amendment Request: Remove Combined License Appendix C (LAR 23-008) NL-23-0670, Response to Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-144832023-08-11011 August 2023 Response to Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-14483 NL-23-0658, Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal2023-08-11011 August 2023 Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal NL-23-0672, Licensee Guarantees of Payment of Deferred Premiums2023-08-10010 August 2023 Licensee Guarantees of Payment of Deferred Premiums NL-23-0542, CFR 50.46 ECCS Evaluation Model Annual Report for 20222023-08-0909 August 2023 CFR 50.46 ECCS Evaluation Model Annual Report for 2022 NL-23-0624, Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis2023-08-0404 August 2023 Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis NL-23-0611, Core Operating Limits Report, Cycle 11 Version 12023-07-19019 July 2023 Core Operating Limits Report, Cycle 11 Version 1 NL-23-0584, Preservice Inspection Program Owner'S Activity Report2023-07-10010 July 2023 Preservice Inspection Program Owner'S Activity Report NL-23-0555, Request for Exemption from Physical Barrier Requirement2023-07-0707 July 2023 Request for Exemption from Physical Barrier Requirement NL-23-0506, to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fq Surveillance Technical Specifications2023-07-0505 July 2023 to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fq Surveillance Technical Specifications NL-23-0541, Inservice Inspection Program Owners Activity Report for Outage 1R242023-06-28028 June 2023 Inservice Inspection Program Owners Activity Report for Outage 1R24 NL-23-0444, Quality Assurance Topical Report Submittal2023-06-15015 June 2023 Quality Assurance Topical Report Submittal NL-23-0339, Response to Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters - Operating, Completion Time Extension (LAR-22-002S1)2023-06-13013 June 2023 Response to Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters - Operating, Completion Time Extension (LAR-22-002S1) NL-23-0455, Report of 10 CFR 50.59 Changes, Tests, and Experiments and 10 CFR 52 Appendix D Departure Report2023-06-12012 June 2023 Report of 10 CFR 50.59 Changes, Tests, and Experiments and 10 CFR 52 Appendix D Departure Report NL-23-0467, Response to Request for Additional Information Regarding License Amendment Request: Timing of Unit 4 Technical Specifications Effectiveness Prior to Initial Criticality (LAR-23-005S1)2023-06-0909 June 2023 Response to Request for Additional Information Regarding License Amendment Request: Timing of Unit 4 Technical Specifications Effectiveness Prior to Initial Criticality (LAR-23-005S1) NL-23-0346, License Amendment Request for Exception to Regulatory Guide 1.163 (LAR 23-007)2023-05-25025 May 2023 License Amendment Request for Exception to Regulatory Guide 1.163 (LAR 23-007) NL-23-0383, SNC Response to Regulatory Issue Summary 2023-01:Preparation And.2023-05-19019 May 2023 SNC Response to Regulatory Issue Summary 2023-01:Preparation And. NL-23-0385, License Amendment Request: More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006R1)2023-05-17017 May 2023 License Amendment Request: More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006R1) NL-23-0398, Withdrawal of Request of License Amendment Request Regarding More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006)2023-05-16016 May 2023 Withdrawal of Request of License Amendment Request Regarding More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006) NL-23-0372, Units 1 & 2, Joseph M. Farley Nuclear Plant - Units 1 & 2, Vogtle Electric Generating Plant - Units 1 & 2, Annual Radiological Environmental Operating Reports for 20222023-05-10010 May 2023 Units 1 & 2, Joseph M. Farley Nuclear Plant - Units 1 & 2, Vogtle Electric Generating Plant - Units 1 & 2, Annual Radiological Environmental Operating Reports for 2022 NL-23-0360, Supplement to License Amendment Request and Exemptions to Allow Use of Lead Test Assemblies for Accident-Tolerant Fuel2023-05-0505 May 2023 Supplement to License Amendment Request and Exemptions to Allow Use of Lead Test Assemblies for Accident-Tolerant Fuel NL-23-0326, Response to Apparent Violation in NRC Inspection Report 05000424, 425/2023090; EA-22-1082023-05-0101 May 2023 Response to Apparent Violation in NRC Inspection Report 05000424, 425/2023090; EA-22-108 NL-23-0217, License Amendment Request to Revise Technical Specification Surveillance Requirement 3.4.14.1 and Proposed Inservice Testing Alternative ALT-VR-022023-05-0101 May 2023 License Amendment Request to Revise Technical Specification Surveillance Requirement 3.4.14.1 and Proposed Inservice Testing Alternative ALT-VR-02 NL-23-0330, Core Operating Limits Report, Cycle 25, Version 12023-04-26026 April 2023 Core Operating Limits Report, Cycle 25, Version 1 NL-23-0310, Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 20222023-04-25025 April 2023 Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 2022 NL-23-0135, License Amendment Request: Timing of Technical Specifications Effectiveness Prior to Initial Criticality (LAR-23-005)2023-04-17017 April 2023 License Amendment Request: Timing of Technical Specifications Effectiveness Prior to Initial Criticality (LAR-23-005) NL-23-0019, GEN-ISI-ALT-2023-01, Request to Use Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI2023-04-12012 April 2023 GEN-ISI-ALT-2023-01, Request to Use Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI NL-23-0152, License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-144832023-04-11011 April 2023 License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-14483 NL-23-0263, Southern Nuclear Company Submittal of Drug and Alcohol Testing Errors Identified 10 CFR 26.719(c) 30-Day Report2023-04-0505 April 2023 Southern Nuclear Company Submittal of Drug and Alcohol Testing Errors Identified 10 CFR 26.719(c) 30-Day Report NL-23-0136, License Amendment Request: More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006)2023-04-0505 April 2023 License Amendment Request: More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006) NL-23-0132, License Amendment Request: Remove Combined License Appendix C (LAR 23-001)2023-04-0404 April 2023 License Amendment Request: Remove Combined License Appendix C (LAR 23-001) NL-23-0014, Southern Nuclear Operating Co Submittal of Report on Status of Decommissioning Funding2023-03-29029 March 2023 Southern Nuclear Operating Co Submittal of Report on Status of Decommissioning Funding NL-23-0208, Independent Spent Fuel Storage Installation ISFSI, Decommissioning Funding Plan Triennial Update2023-03-29029 March 2023 Independent Spent Fuel Storage Installation ISFSI, Decommissioning Funding Plan Triennial Update NL-23-0193, Request for License Amendment: Relocation of TS 3.7.9, Spent Fuel Pool Makeup Water Sources (LAR-23-003)2023-03-24024 March 2023 Request for License Amendment: Relocation of TS 3.7.9, Spent Fuel Pool Makeup Water Sources (LAR-23-003) NL-23-0196, Response to Request for Additional Information Regarding License Amendment Request for Alternative Source Term, TSTF-51, TSTF-471, and TSTF-4902023-03-24024 March 2023 Response to Request for Additional Information Regarding License Amendment Request for Alternative Source Term, TSTF-51, TSTF-471, and TSTF-490 NL-23-0228, Nuclear Property Insurance Coverage as of April 1, 2023 and Licensee Guarantees of Payment of Deferred Premiums (10 CFR 140.21)2023-03-20020 March 2023 Nuclear Property Insurance Coverage as of April 1, 2023 and Licensee Guarantees of Payment of Deferred Premiums (10 CFR 140.21) NL-22-0977, License Amendment Request to Modify Technical Specification 5.5.11.c Acceptance Criteria for Charcoal Filter Testing2023-02-0909 February 2023 License Amendment Request to Modify Technical Specification 5.5.11.c Acceptance Criteria for Charcoal Filter Testing NL-23-0010, Response to Request for Additional Information Regarding License Amendment Request for Alternative Source Term, TSTF-51, TSTF-471, and TSTF-4902023-02-0606 February 2023 Response to Request for Additional Information Regarding License Amendment Request for Alternative Source Term, TSTF-51, TSTF-471, and TSTF-490 NL-23-0076, Exigent License Amendment Request: Technical Specification Exceptions for In-containment Refueling Water Storage Tank Operability Prior to Initial Criticality (LAR-23-004)2023-01-31031 January 2023 Exigent License Amendment Request: Technical Specification Exceptions for In-containment Refueling Water Storage Tank Operability Prior to Initial Criticality (LAR-23-004) NL-23-0013, Response to Request for Additional Information Related to 10CFR 50.75 Decommissioning Funding Assurance Requirements2023-01-30030 January 2023 Response to Request for Additional Information Related to 10CFR 50.75 Decommissioning Funding Assurance Requirements NL-23-0068, Responses to NRC Request for Additional Information Related to the Refueling Outage 2R22 Steam Generator Tube Inspection Report2023-01-27027 January 2023 Responses to NRC Request for Additional Information Related to the Refueling Outage 2R22 Steam Generator Tube Inspection Report NL-23-0012, Post-Audit Supplement to License Amendment Request and Exemptions to Allow Use of Lead Test Assemblies for Accident-Tolerant Fuel2023-01-20020 January 2023 Post-Audit Supplement to License Amendment Request and Exemptions to Allow Use of Lead Test Assemblies for Accident-Tolerant Fuel 2024-01-29
[Table view] |
Text
B. Keith Taber Southern Nuclear Vice President Operating Company, Inc.
Vogtle - Units 1 & 2 7821 River Road Waynesboro, GA 30830 Tel 706.848.3151 Fax 706.826.3321 SOUTHERN.\.
COMPANY FEB 1 9 2015 Docket Nos.: 50-424 NL-15-0014 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant, Units 1 & 2 Response to Preliminary White Finding from NRC Inspection Report 05000424/2014009 and 05000425/2014009
References:
- 1. NRC letter to Southern Nuclear Operating Company," Vogtle Electric Generating Plant, NRC Inspection Report Number 05000424/2014009 and 05000425/2014009, Preliminary Greater than Green Finding and Related Apparent Violation", dated January 22, 2015 Ladies and Gentlemen:
In Reference 1, the Nuclear Regulatory Commission (NRC) identified a preliminary White finding for an event in which a High Integrity Container (HIC) containing a Type B quantity of radioactive waste was erroneously loaded into a Type A shipping cask and transported to a waste processor.
Southern Nuclear Operating Company (SNC) agrees with the NRC on the facts regarding the finding in the letter. SNC understands the importance of safely shipping radioactive materials in accordance with regulatory requirements.
Appropriate corrective actions have been taken to address the causes for the identified condition.
By letter dated January 30, 2015, SNC informed the NRC that a regulatory conference was not requested and that a written response would be provided to submit our perspectives on the finding. The enclosure to this letter provides the response. SNC appreciates the opportunity to provide its perspectives in support of the NRC's final determination.
U. S. Nuclear Regulatory Commission NL-15-0014 Page 2 This letter contains no NRC commitments. If you have any questions, please contact George Gunn at (706) 826-3596.
Respectfully submitted,
- g. fJL B. Keith Taber Site Vice President- Vogtle 1 and 2 BKTkb/lac
Enclosure:
Response to Preliminary White Finding from NRC Inspection Report cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bast, Executive Vice President & Chief Nuclear Officer Mr. D. R. Madison, Vice President- Fleet Operations Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. K. Taber, Vice President- Vogtle 1 & 2 Mr. B. J. Adams, Vice President- Engineering Mr. G.W. Gunn, Regulatory Affairs Manager- Vogtle 1 & 2 RType: CVC7000 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager- Vogtle 1 & 2 Mr. L. M. Cain, Senior Resident Inspector- Vogtle 1 & 2
Vogtle Electric Generating Plant, Units 1 & 2 Response to Preliminary White Finding from NRC Inspection Report Numbers 05000424/201402 and 05000425/2014009 Enclosure Response to Preliminary White Finding from NRC Inspection Report
Enclosure to NL-15-0014 Response to Preliminary White Finding from NRC Inspection Report On June 24, 2014, a Type A shipping cask containing a Type 8 quantity of radioactive waste was shipped by Southern Nuclear Operating Company (SNC) from the Vogtle Electric Generating Plant (VEGP), Units 1 and 2, to the Energy Solutions radioactive waste processing facility located in Barnwell, South Carolina. The serial number of the High Integrity Container (HIC) containing the spent resin was not verified when it was removed from its storage process shield and placed into the shipping cask, with the result that in this singular case, a HIC with a Type 8 quantity of spent resin requiring a Type 8 shipping cask was transported in a Type A shipping cask.
NRC Finding Summary In Reference 1 the NRC concluded that:
A self-revealing, preliminary White, AV of Technical Specification {TS} 5.4.1.,
Procedures, occurred on June 24,2014,when a Type A shipping cask containing Type B radioactive waste (spent resin) was shipped by Southern Nuclear Operating Company (SNC) from the Vogtle Electric Generating Plant (VEGP), Units 1 and 2,to the Energy Solutions radioactive waste processing facility located in Barnwell, South Carolina. The serial number of the High Integrity Container (HIC) containing the spent resin was not verified when it was removed from its storage process shield and placed in the shipping cask, with the result that a HIC with a Type 8 quantity of resin was transported in a Type A shipping cask. This error resulted in multiple violations of NRC and Department of Transportation (DOT) regulations, which are included in . The licensee entered the event in the corrective action program (CAP) as condition report (CR) 831652. Immediate corrective actions included suspension of radioactive waste shipments at Southern Nuclear Operating Company (SNC) facilities, and requalification of plant Vogtle radioactive shippers and oversight personnel.
The licensee's failure to document the location of radioactive waste stored in the process shields, as required by licensee procedure 46111-C, "Storage of Radwaste in Outdoor Process Shields," was a performance deficiency (PO). The PO was more than minor because it was associated with the public radiation safety cornerstone attribute of Program & Process (transportation program), and adversely impacted the cornerstone objective of ensuring adequate protection of public health and safety from exposure to RAM released into the public domain. A Type B quantity of material left the licensee's facility and entered the public domain in an inadequate (Type A) container. The inspectors determined this finding has a cross-cutting aspect [ef} in the Documentation component of the Human Performance area, because the licensee did not create and maintain complete, accurate, and up-to-date documentation used in preparing shipments of radioactive waste.
E- 1
Enclosure to NL-15-0014 Response to Preliminary White Finding from NRC Inspection Report SNC Response The NRC has proposed a preliminary White finding in connection with this event.
SNC agrees with the NRC on the on the facts regarding the finding. In summary, during shipment, the exterior radiation levels of the cask did not exceed what would be expected of a normal Low Specific Activity (LSA) shipment, and there was no breach of the container. Thus there was very low additional public risk from this shipment compared to a normal LSA shipment.
Description of Event On June 11, 2014, a High Integrity Container (HIC) was prepared for shipment with what was expected to be a Type A quantity of radioactive waste from VEGP to Energy Solutions, a radioactive waste processor located in Barnwell, South Carolina.
The HIC intended for shipment was S/N #003698-19, which was assumed by Radiation Protection (RP) staff to be in Process Shield #10 based on data sheets showing H IC locations. However, in the course of a program of resampling HICs for possible waste reclassification, some H ICs had been relocated to different process shields without completion of new data sheets. In preparation for shipment, Process Shield #10 was opened, the top of the HIC was surveyed, and then the HIC was removed from the process shield and placed into a Type A shipping cask, without verifying the HIC serial number.
On June 23, 2014, the loaded DOT 7A Type A shipping cask was surveyed. External dose rates on the Type A cask met all transportation requirements of 49 CFR 173.441 and the shipping documentation was prepared. On June 24, 2014, the cask was transported to the Energy Solutions Barnwell Processing Facility. On June 25, 2014, Energy Solutions informed SNC that the HIC they had received was not S/N
- 003698-19 as indicated on the shipping manifest, but was actually S/N #605163-02.
On June 26, 2014, SNC personnel traveled to Energy Solutions in Barnwell and confirmed that an incorrect HIC had been shipped.
Upon investigation by SNC, it was found that H IC S/N #605163-02 contained a Type B quantity of radioactive waste (spent resin) which required shipment in a Type B cask. Upon survey of the H IC at the Barnwell facility, it was determined by Energy Solutions and SNC personnel to have an unshielded 3 meter dose rate of 1.3 Rem/hour, measured from the bottom of the H IC. This dose rate exceeded the limits described in 49 CFR 173.427(a)(1) for a radioactive material package to be shipped as Radioactive Material LSA/SCO. The unshielded dose rate also exceed the criterion for exemption in 10 CFR 71.14(b)(3)(i). Therefore, a shipping cask certified by the NRC (Type B shipping cask) should have been utilized for transportation of the HIC.
E-2
Enclosure to NL-15-0014 Response to Preliminary White Finding from NRC Inspection Report Risk Considerations Incorrect Package Type for Shipment The regulatory requirement for shipping Type B radioactive waste/material as LSA in a Type A shipping package is that the unshielded waste/material (in this case a HI C) cannot exceed a dose rate of 1.0 rem/hour at 3 meters. Otherwise, it must be transported in a certified Type B shipping package. The waste shipped from Plant Vogtle had a measured dose rate of 1.3 rem/hour at 3 meters (unshielded), which exceeded the regulatory requirement. The exterior surface dose rate with the loaded and assembled Type A shipping package was measured to be 10 mrem/hour on contact, which is what would be expected for Type A waste in a Type A cask. The Department of Transportation regulatory limit for contact dose rate on the exterior of the package (cask) is 200 mrem/hour. The SNC administrative limit is 160 mrem/hour. The actual exterior dose rate on the shipping cask from Plant Vogtle was very low and posed very low risk to the public.
The cask used for the shipment was previously rated as a Type 8 cask. However, this license expired as a result of regulatory changes. The cask was reclassified as a Type A cask as it does not fully meet the current criteria for a Type B cask. This cask provided additional structural features and a higher level of shielding as compared to a typical Type A cask. This higher level of shielding and protection combined with the very low measured contact dose rate resulted in very low risk to the public.
Due to the low actual dose rate and the additional structural integrity and shielding of the cask used for the shipment, SNC concluded that the risk to the public from this shipment was very low during transport.
Corrective Actions Radioactive waste shipping activities across the SNC fleet were suspended pending review of this event and implementation of fleet-wide corrective actions. A detailed review of radioactive waste shipping procedures was performed with radioactive waste shipping personnel across the fleet to ensure alignment and weaknesses were addressed at all sites. SNC has completed an Apparent Cause Determination and will perform a Root Cause Determination. The following immediate corrective actions have been completed:
- Oral boards were conducted with radioactive waste shipping personnel to assess and coach standards and behaviors. Emphasis was placed on human performance tool usage. Training emphasized that signature on the shipping manifest certifies that the material has been properly classified, packaged and labeled and is in proper condition for transportation according to applicable regulation.
- Oral boards were also performed with RP supervisory personnel to ensure oversight roles are clearly understood, and supervisory oversight is required on all high risk radiological activities.
E- 3
Enclosure to NL-15-0014 Response to Preliminary White Finding from NRC Inspection Report
- A peer review for the next waste shipment was conducted by Plant Farley and Corporate qualified RP Waste Shippers. The peer review entailed having additional oversight at Plant Vogtle to ensure the shipment was packaged and surveyed appropriately and independently verified to be correct.
- Radioactive waste/material shipment procedures were revised to require visual verification of the H IC serial number, with a verification step added to the cask and HIC inspection checklist. Procedure revisions also enhanced the inventory control of liners.
- A fleet Focused Area Self-Assessment (FASA) of RP Radwaste was performed and determined the corrective action measures to be effective.
The FASA team was composed of Southern Nuclear Corporate and Plant Vogtle station RP personnel and also included industry peers.
- The ALARA Briefing record for the H IC loading Radiation Work Permit was revised to require verification of the liner serial number, verification of the correct process shield location, and designation of individuals by name to perform the verification tasks. Approval by the Fleet RP Manager and Site Plant Manager was required prior to resumption of radioactive waste shipping. Radioactive waste shipping for VEGP was resumed on September 5, 2014.
Conclusion SNC agrees with the NRC that a performance deficiency occurred. SNC understands the high importance of safely shipping radioactive materials consistent with regulatory requirements. SNC has completed an Apparent Cause Determination and will perform a Root Cause Determination. Immediate corrective actions have been completed to address the deficiency. Additional corrective actions may emerge from the Root Cause investigation. The cask used provided additional structural features beyond those of a typical Type A cask. During shipment, the exterior radiation levels of the cask did not exceed what would be expected of a Type A shipment.
E-4