GO2-17-075, Confirmatory Order EA-14-240, Element V.J.2 - Conclusion Report
| ML17103A640 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/13/2017 |
| From: | Hettel W Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation, NRC Region 4 |
| References | |
| EA-14-240, GO2-17-075 | |
| Download: ML17103A640 (9) | |
Text
William G. Hettel ENERGY Vice President, Operations P.O. Box 968, Mail Drop PE23 NORTHWEST Richland, WA 99352-0968 Ph. so9-3n-242s F. 509-3n-4674 wghettel @energy-northwest.com April 13, 2017 G02-17-075 U.S. NRC Region IV ATTN: Director, Division of Reactor Safety 1600 East Lamar Blvd.
Arlington, Texas 76011-4511
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 CONFIRMATORY ORDER EA-14-240, ELEMENT V.J.2 -CONCLUSION REPORT
Reference:
Letter EA-14-240 from M. L. Dapas (NRC) to M. E. Reddemann (Energy Northwest), "Confirmatory Order - NRC Security Inspection Report 05000397/2015407 and NRC Investigation Report 4-2014-009 Columbia Generating Station," dated September 28, 2015
Dear Sir:
The purpose of this letter is to provide the conclusion report on the actions required by the above referenced confirmatory order. These actions were a result of an Alternative Dispute Resolution mediation session that was held on August 6, 2015, and a signed "Consent and Hearing Waiver Form," dated September 21, 2015 agreed to the issuance of the confirmatory order. The enclosure to this letter provides the statements of completion and bases for each of the confirmatory order action requirements as executed to date by Energy Northwest.
There are no new commitments being made to the Nuclear Regulatory Commission (NRC) by this letter. Should you have any questions, please contact Ms. D. M.
Wolfgramm, Regulatory Compliance Supervisor, at (509) 377-4792.
Executed this lli day of A~L , 2017.
Respectfully, W-~---,
W. G. Hettel Vice President, Operations
G02-17-075 Page 2 of 2
Enclosure:
Columbia Generating Station Confirmatory Order EA-14-240 Element V.J.2
-Conclusion Report cc:
NRG Director-Division of Reactor Safety, Region IV NRG Region IV Administrator NRG NRA Project Manager NRG Sr. Resident lnspector/988C CD Sonoda - BPA/1399 w/o enclosure WA Horin - Winston & Strawn w/o enclosure
COLUMBIA GENERATING STATION CONFIRMATORY ORDER EA-14-240 Element V.J.2 - CONCLUSION REPORT Enclosure Page 1 of 7 Confirmatory Order Commitment V.A: Common Cause Evaluation Requirements Within 3 months of the date of this Confirmatory Order, Energy Northwest will conduct a common cause evaluation related to the events that formed the basis of this matter.
V.A.1: The common cause evaluation will be conducted by a trained individual outside of the Emergency Services organization at the Columbia Generating Station (CGS).
V.A.2: The results will be incorporated into Energy Northwest's corrective action program at CGS, as appropriate.
V.A.3: A copy of the completed evaluation will be made available for NRC review.
Actions Taken Within three months of receiving the Confirmatory Order, Energy Northwest identified a qualified cause analysis evaluator outside of the Emergency Services Department to conduct the common cause evaluation. The common cause evaluation was completed on November 19, 2015 and Energy Northwest followed the appropriate process and the evaluation was reviewed and approved by the Stations Corrective Action Review Board on December 15, 2015. The common cause evaluation was submitted to the NRC through correspondence letter GO2-15-182 on December 28, 2015, which completed the requirements set forth by the Confirmatory Order sections V.A.1, V.A.2, and V.A.3.
No comments were received from the NRC.
Confirmatory Order Commitment V.B: Install Wide-Angle Cameras Requirements Within 18 months of the date of this Confirmatory Order, Energy Northwest will install wide-angle cameras in Bullet Resistant Enclosures (BREs) to monitor the availability of nuclear security officers.
V.B.1: The cameras will be monitored by security supervisors (i.e., Sergeant or Lieutenant) at a frequency of not less than twice per shift per BRE when cameras are functional.
V.B.2: When the cameras are not functional, security supervisors (i.e., Sergeant or Lieutenant) will conduct security post checks at a frequency of not less than twice per shift, provided there is adequate staffing (i.e., one Lieutenant and two Sergeants) to ensure other commitments can be met.
V.B.3: Until cameras are installed in the BREs, Energy Northwest security management will continue to perform a minimum of two post checks per shift, provided there is
COLUMBIA GENERATING STATION CONFIRMATORY ORDER EA-14-240 Element V.J.2 - CONCLUSION REPORT Enclosure Page 2 of 7 adequate staffing (i.e., one Lieutenant and two Sergeants) to ensure other commitments can be met.
V.B.4: Use of cameras to monitor the availability of Nuclear Security Officers (NSOs) inside BREs will be documented.
Actions Taken Within 18 months of receiving the Confirmatory Order, Energy Northwest installed wide-angle cameras in all of the plants Bullet Resistant Enclosures (BREs) for the purpose of monitoring the availability of nuclear security officers. Energy Northwest negotiated and implemented BRE monitoring requirements into the NSO union agreements. Interim corrective actions were established while BRE cameras were not functional, which required security supervisors (i.e., Sergeant or Lieutenant) to conduct security post checks at a frequency of not less than twice per shift, provided there was adequate staffing (i.e., one Lieutenant and two Sergeants) to ensure other commitments could be met. This process is documented through the security shift activity log completed daily by security supervisors. The interim corrective action has been proceduralized; when current BRE cameras are not functional security supervisors are to conduct post checks as stated in section V.B.2. The completion of BRE cameras installation was submitted through correspondence letter GO2-17-058 on March 14, 2017, which completed the requirements set forth by the Confirmatory Order sections V.B.1, V.B.2, V.B.3, and V.B.4.
Confirmatory Order Commitment V.C: Compliance and Ethics Training Requirements Within 6 months of the date of this Confirmatory Order, Energy Northwest will revise its annual compliance and ethics computer-based training to address deliberate misconduct (10 CFR 50.5), compliance therewith, and consequences for non-compliance.
V.C.1: Prior to conducting the training, Energy Northwest will provide its proposed training plan to the NRC for its review. The NRC will communicate to the licensee any concerns regarding the plan within 30 days of submittal for resolution in a manner acceptable to both parties.
V.C.2: Energy Northwest will complete administration of this training within 6 months of the date of this Confirmatory Order.
Actions Taken Within six months of receiveing the Confirmatory Order, Energy Northwest revised its annual compliance and ethics computer-based training (CBT) to address deliberate misconduct (10 CFR 50.5), compliance therewith, and consequences for non-compliance. A copy of the CBT was sent to NRC for review through correspondence
COLUMBIA GENERATING STATION CONFIRMATORY ORDER EA-14-240 Element V.J.2 - CONCLUSION REPORT Enclosure Page 3 of 7 GO2-16-007. NRC comments were communicated to Energy Northwest via telephone conference on February 17, 2016 and incorporated into the CBT.
All green badged employees with unescorted access were required to complete the compliance and ethics training by March 23, 2016. Those green badged employees that did not complete the required training had their badges deactivated until compliance and ethics training was completed, which was tracked through the Stations personnel qualification database (PQD). The revised Energy Northwests annual compliance and ethics CBT was submitted to the NRC through correspondence letter GO2-16-007 on January 11, 2016, and completion of CBT training was communicated to the NRC through correspondence letter GO2-16-089 on June 27, 2016, which completed the requirements set forth by the Confirmatory Order sections V.C.1 and V.C.2.
Confirmatory Order Commitment V.D: Regulatory Compliance Affirmation Requirements Energy Northwest will ensure its NSOs understand the need to comply with regulations and the consequences for non-compliance by having NSOs sign a statement affirming the same. This statement will be signed by current NSOs within 6 months of the date of this Confirmatory Order and within 30 days of hire for new NSOs, subject to collective bargaining.
Actions Taken Within six months of receiving the Confirmatory Order, Energy Northwest had all current NSOs read and sign that they understood the need to comply with regulations and the associated consequences of non-compliance. Information was provided to the NSOs union and presented by Security Management to all NSOs. Completion of these actions has been captured in the Stations Corrective Action Program as well as through training attendance records. The non-compliance read and sign has been incorporated into the Human Resources process for new NSO hires and is conducted within the 30 days for new NSO hires. The completion of the non-compliance read and sign was communicated to the NRC through correspondence letter GO2-16-052 on March 24, 2016, which completed the requirements set forth by the Confirmatory Order section V.D.
Confirmatory Order Commitment V.E: Lessons Learned Presentation Requirements Energy Northwest will prepare a "lessons learned" presentation, derived from the common cause evaluation, to be delivered to Energy Northwest's Nuclear Security Department at CGS concerning the incidents that formed the basis for this violation and the consequences.
COLUMBIA GENERATING STATION CONFIRMATORY ORDER EA-14-240 Element V.J.2 - CONCLUSION REPORT Enclosure Page 4 of 7 V.E.1: Prior to offering this presentation, Energy Northwest will provide its proposed presentation to the NRC for its review. The NRC will communicate to the licensee any concerns regarding the presentation within 30 days of submittal for resolution in a manner acceptable to both parties.
V.E.2: Energy Northwest will deliver the presentation to the Nuclear Security Department at CGS within 6 months of the date of this Confirmatory Order.
Actions Taken Within six months of receiving the Confirmatory Order, Energy Northwest completed and delivered to the NRC the lessons learned presentation which was derived from the common cause evaluation. Prior to delivering the presentation to the stations Nuclear Security Department, it was sent to the NRC for review through correspondence GO2-16-006. The NRC comments were communicated to Energy Northwest via telephone conference on February 17, 2016 and incorporated into the lessons learned presentation. The presentation was then administered to the Nuclear Security Department at Energy Northwest during several sessions held between February 17 and March 21, 2016. The internal PQD process was utilized to ensure administering the lessons learned presentation to Nuclear Security Department staff upon their return to duty after short or long term leaves, disability leave, or military duty assignments. The completion of the lessons learned presentations was communicated to the NRC through correspondence letter GO2-16-052 on March 24, 2016, which completed the requirements set forth by the Confirmatory Order sections V.E.1 and V.E.2.
Confirmatory Order Commitment V.F: Lessons Learned Incorporation Requirements Energy Northwest will incorporate the lessons learned, derived from the common cause evaluation referenced in Commitment V.A, and revise procedures at CGS as appropriate. A copy of the revised procedures will be made available for NRC review.
Actions Taken Upon completion of section V.A, Common Cause Evaluation, lessons learned were incorporated into the procedure process, and affected Energy Northwest Security procedures were identified. Two corrective actions to revise security program implementing procedures SPIP-SEC-01 and SPIP-SEC-14 were completed. The revised procedures were submitted to the NRC through correspondence letter GO2 054 on March 24, 2016, which completed the requirements set forth by the Confirmatory Order section V.F. No comments were received from the NRC on the revised procedures.
COLUMBIA GENERATING STATION CONFIRMATORY ORDER EA-14-240 Element V.J.2 - CONCLUSION REPORT Enclosure Page 5 of 7 Confirmatory Order Commitment V.G: Incidents Presentation Requirements Within 12 months of the date of this Confirmatory Order, Energy Northwest will prepare a presentation communicating the incidents that formed the basis for this violation to be delivered to an appropriate industry forum (e.g., the NEI Nuclear Security Working Group) subject to acceptance of the conference organizing committees.
V.G.1: This presentation will include, among other things, the significance of the incidents that formed the basis for this violation; the consequences of the actions; and the significant responsibilities of NSOs.
V.G.2: Prior to making the presentation, Energy Northwest will provide its proposed presentation to the NRC for its review. The NRC will communicate to the licensee any concerns regarding the presentation within 30 days of submittal for resolution in a manner acceptable to both parties.
V.G.3: Energy Northwest will deliver the presentation within 12 months of the date of this Confirmatory Order.
Actions Taken Within 12 months of receiving the Confirmatory Order, Energy Northwest presented to an Industry Forum (NEI Nuclear Security Working Group) the significance of the incidents that formed the basis for this violation; the consequences of the actions; and the significant responsibilities of NSOs. Prior to delivering the presentation to the NEI Nuclear Security Working Group, the presentation was provided to the NRC for review through correspondence GO2-16-026 on February 8, 2016. NRC comments were communicated to Energy Northwest via telephone conference on March 11, 2016 and incorporated into the presentation that was delivered to the NEI Nuclear Security Working Group on May 11, 2016. The completion of the presentation was communicated to the NRC through correspondence letter GO2-16-089 on June 27, 2016, which completed the requirements set forth by the Confirmatory Order sections V.G.1, V.G.2, and V.G.3.
Confirmatory Order Commitment V.H: Safety Culture Assessment Requirements Within 6 months of the date of this Confirmatory Order, Energy Northwest will ensure that an independent third party will conduct a targeted nuclear safety culture assessment of the security organization at CGS.
V.H.1: Based on the results of the assessment, Energy Northwest will incorporate recommended actions from the assessment into its corrective action program, as appropriate.
COLUMBIA GENERATING STATION CONFIRMATORY ORDER EA-14-240 Element V.J.2 - CONCLUSION REPORT Enclosure Page 6 of 7 V.H.2: A copy of the completed assessment will be made available for NRC review within 30 days of the completion of the assessment.
Actions Taken Within six months of receiving the Confirmatory Order, Energy Northwest hired an independent legal firm, The Zaffuts Group, to conduct a targeted Nuclear Safety Culture assessment of the Nuclear Security organization. The Zaffuts Group completed this assessment by November 25, 2015 and an assessment report was completed on December 21, 2015. The identified recommendations from the assessment were entered into the Stations Corrective Action Program. Upon receiving the completed assessment report from The Zaffuts Group, it was provided to the NRC for review within 30 days. The completed targeted nuclear safety culture assessment was submitted through correspondence letter GO2-16-019 on January 19, 2016, which completed the requirements set forth by the Confirmatory Order sections V.H.1 and V.H.2. No comments were received from the NRC.
Confirmatory Order Commitment V.I: Revise Investigatory Procedures Requirements Within 4 months of the date of this Confirmatory Order, Energy Northwest will revise its investigatory procedures to incorporate lessons learned from this matter (e.g., to engage the NRC Regional Office on Energy Northwest's plans to conduct regulatory violation investigations in parallel with the NRC's Office of Investigations).
Actions Taken Within four months of receiving the Confirmatory Order, Energy Northwest revised its investigatory procedures. Lessons learned from this matter were incorporated into the affected procedures, which were implemented on January 14, 2016. The completion of the revised investigatory precedures was documented in the correspondence letter GO2-16-052 on March 24, 2016, which completed the requirements set forth by the Confirmatory Order secion V.I.
Confirmatory Order Commitment V.J: Provide Action Status Reports Requirements Notifications to NRC when actions are completed.
V.J.1: Unless otherwise specified, Energy Northwest will submit written notification to the Director, Division of Reactor Safety, U. S. NRC Region IV, 1600 East Lamar Blvd., Arlington, Texas 76011-4511, at intervals not to exceed 3 months until the terms of this Confirmatory Order are completed, providing a status of each item in the Confirmatory Order.
COLUMBIA GENERATING STATION CONFIRMATORY ORDER EA-14-240 Element V.J.2 - CONCLUSION REPORT Enclosure Page 7 of 7 V.J.2: Energy Northwest will provide its basis for concluding that the terms of this Confirmatory Order have been satisfied, to the NRC, in writing.
Actions Taken As documented in the chart below a written notification was sumitted to the address identified in section V.J.1 at an interval that did not exceed three months, which provided the status of each item in the Confirmatory Order. All the submittals met the due date requirements in the Confirmaory Order.
Status Reports Due Date Energy Northwests Submittal Letter First Action Status December 28, 2015 GO2-15-183 Second Action Status March 28, 2016 GO2-16-052 Third Action Status June 28, 2016 GO2-16-089 Fourth Action Status September 28, 2016 GO2-16-137 Fifth Action Status December 28, 2016 GO2-16-170 Sixth Action Status March 28, 2017 GO2-17-058 As documented in this correspondence letter, GO2-17-075, the Confirmatory Order Conclusion Report has been completed and is herewith submitted in accordance with the requirements set forth by the Confirmatory Order sections V.J.1 and V.J.2.
Confirmatory Order Commitment V.K: Civil Penalty Requirements Within 30 days of the date of this Confirmatory Order, Energy Northwest shall pay a civil penalty of $35,000.
Actions Taken Within 30 days of receiving the Confirmatory Order, Energy Northwest made payment in the amount of $35,000 that was documented through correspondance letter GO2 140 on October 19, 2015, which completed the requirements set forth by the Confirmatory Order secion V.K.