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Category:Letter type:GO
MONTHYEARGO2-24-004, License Amendment Request to Revise Emergency Plan2024-01-30030 January 2024 License Amendment Request to Revise Emergency Plan GO2-24-003, Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing2024-01-29029 January 2024 Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing GO2-24-005, Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-1702024-01-0808 January 2024 Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-170 GO2-23-136, Guarantee of Payment of Deferred Premium2023-12-20020 December 2023 Guarantee of Payment of Deferred Premium GO2-23-135, Notice of Readiness for Supplemental Inspection2023-12-14014 December 2023 Notice of Readiness for Supplemental Inspection GO2-23-130, Reply to a Notice of Violation; EA-23-0542023-12-14014 December 2023 Reply to a Notice of Violation; EA-23-054 GO2-23-105, Licensing Basis Document Update and Biennial Commitment Change Report2023-12-12012 December 2023 Licensing Basis Document Update and Biennial Commitment Change Report GO2-23-107, Application to Revise Technical Specifications to Adopt TSTS-584, Eliminate Automatic RWCU System Isolation on SLC Initiation2023-12-0505 December 2023 Application to Revise Technical Specifications to Adopt TSTS-584, Eliminate Automatic RWCU System Isolation on SLC Initiation GO2-23-126, Docket No. 50-397 Voluntary Response to Regulatory Issue Summary 2023-012023-11-28028 November 2023 Docket No. 50-397 Voluntary Response to Regulatory Issue Summary 2023-01 GO2-23-121, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-27027 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation GO2-23-097, In-Service Inspection Summary Report for the Twenty-Sixth Refueling Outage (R26)2023-09-0606 September 2023 In-Service Inspection Summary Report for the Twenty-Sixth Refueling Outage (R26) GO2-23-100, Technical Specification Section 5.6.4 Post Accident Monitoring Instrumentation 14-Day Report for Inoperable Suppression Pool Level Indication2023-08-31031 August 2023 Technical Specification Section 5.6.4 Post Accident Monitoring Instrumentation 14-Day Report for Inoperable Suppression Pool Level Indication GO2-23-056, Application to Revise Technical Specifications to Adopt TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling2023-08-29029 August 2023 Application to Revise Technical Specifications to Adopt TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling GO2-23-093, Supplement to Reply to a Notice of Violation: EA-21-1702023-07-27027 July 2023 Supplement to Reply to a Notice of Violation: EA-21-170 GO2-23-068, Notification of Completion of Commitments Required Prior to Entry Into the Period of Extended Operation2023-07-19019 July 2023 Notification of Completion of Commitments Required Prior to Entry Into the Period of Extended Operation GO2-23-090, Reply to a Notice of Violation2023-07-12012 July 2023 Reply to a Notice of Violation GO2-23-073, Notification of NPDES Permit Issuance2023-06-26026 June 2023 Notification of NPDES Permit Issuance GO2-23-072, Cycle 27 Core Operating Limits Report2023-06-0505 June 2023 Cycle 27 Core Operating Limits Report GO2-23-055, Independent Spent Fuel Storage Installation, 2022 Annual Radiological Environmental Operating Report2023-05-15015 May 2023 Independent Spent Fuel Storage Installation, 2022 Annual Radiological Environmental Operating Report GO2-23-006, License Amendment Request to Clean-Up Operating License and Appendix a Technical Specifications2023-05-0101 May 2023 License Amendment Request to Clean-Up Operating License and Appendix a Technical Specifications GO2-23-053, 2022 Annual Environmental Operating Report2023-04-26026 April 2023 2022 Annual Environmental Operating Report GO2-23-057, 2022 Annual Radioactive Effluent Release Report2023-04-25025 April 2023 2022 Annual Radioactive Effluent Release Report GO2-23-012, Application to Revise Technical Specifications to Adopt Tstf-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position2023-03-27027 March 2023 Application to Revise Technical Specifications to Adopt Tstf-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position GO2-23-041, Generation Station - Level of Financial Protection - Annual Reporting Requirement2023-03-15015 March 2023 Generation Station - Level of Financial Protection - Annual Reporting Requirement GO2-23-038, Plant Decommissioning Fund Status Report2023-03-15015 March 2023 Plant Decommissioning Fund Status Report GO2-23-034, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.462023-03-13013 March 2023 Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.46 GO2-23-035, Supplement to License Amendment Request to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-03-0909 March 2023 Supplement to License Amendment Request to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling GO2-23-019, Emergency Plan - Summary of Changes and Analysis for Revision 68 of the EP-012023-02-0808 February 2023 Emergency Plan - Summary of Changes and Analysis for Revision 68 of the EP-01 GO2-22-131, Guarantee of Payment of Deferred Premium2022-12-19019 December 2022 Guarantee of Payment of Deferred Premium GO2-22-122, Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2022-11-28028 November 2022 Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b GO2-22-076, Status of License Renewal Commitments2022-10-31031 October 2022 Status of License Renewal Commitments GO2-22-110, Supplement to License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactor2022-10-17017 October 2022 Supplement to License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactor GO2-22-096, Supplement to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2022-10-0404 October 2022 Supplement to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b GO2-22-085, Docket No. 50-397, Evacuation Time Estimate Analysis2022-08-30030 August 2022 Docket No. 50-397, Evacuation Time Estimate Analysis GO2-22-075, Response to Request for Additional Information Related to Revised Pressure-Temperature Limit Curves2022-07-11011 July 2022 Response to Request for Additional Information Related to Revised Pressure-Temperature Limit Curves GO2-22-072, Summary of Changes and Analysis for Revision 57 of PPM 13.14.4 - Emergency Equipment Maintenance and Testing2022-07-11011 July 2022 Summary of Changes and Analysis for Revision 57 of PPM 13.14.4 - Emergency Equipment Maintenance and Testing GO2-22-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Colling Using the Consolidated Line Item Improvement Process2022-05-25025 May 2022 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Colling Using the Consolidated Line Item Improvement Process GO2-22-062, Registration of Spent Fuel Cask Use2022-05-19019 May 2022 Registration of Spent Fuel Cask Use GO2-22-049, Supplement to Licensing Amendment Request to Adopt 10CFR50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Rectors2022-05-10010 May 2022 Supplement to Licensing Amendment Request to Adopt 10CFR50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Rectors GO2-22-054, Independent Spent Fuel Storage Installation, 2021 Annual Radiological Environmental Operating Report2022-05-0909 May 2022 Independent Spent Fuel Storage Installation, 2021 Annual Radiological Environmental Operating Report GO2-22-056, Registration of Spent Fuel Cask Use2022-04-21021 April 2022 Registration of Spent Fuel Cask Use GO2-22-055, 2021 Annual Environmental Operating Report2022-04-20020 April 2022 2021 Annual Environmental Operating Report GO2-22-048, 2021 Annual Radioactive Effluent Release Report2022-04-15015 April 2022 2021 Annual Radioactive Effluent Release Report GO2-22-045, Registration of Spent Fuel Cask Use2022-04-0606 April 2022 Registration of Spent Fuel Cask Use GO2-22-044, Level of Financial Protection - Annual Reporting Requirement2022-03-21021 March 2022 Level of Financial Protection - Annual Reporting Requirement GO2-22-038, Docket No. 50-397, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.462022-03-0909 March 2022 Docket No. 50-397, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.46 GO2-22-031, Response to Audit Plan and Online Reference Portal Request2022-02-15015 February 2022 Response to Audit Plan and Online Reference Portal Request GO2-22-011, Docket No. 72-35; Independent Spent Fuel Storage Installation, 2021 Annual Effluent Release Report2022-02-0808 February 2022 Docket No. 72-35; Independent Spent Fuel Storage Installation, 2021 Annual Effluent Release Report GO2-22-001, License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2022-02-0303 February 2022 License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b GO2-22-012, Independent Spent Fuel Storage Installation - Biennial 50.59/72.48 Report2022-01-24024 January 2022 Independent Spent Fuel Storage Installation - Biennial 50.59/72.48 Report 2024-01-08
[Table view] Category:Licensee Response to Notice of Violation
MONTHYEARGO2-24-005, Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-1702024-01-0808 January 2024 Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-170 GO2-23-130, Reply to a Notice of Violation; EA-23-0542023-12-14014 December 2023 Reply to a Notice of Violation; EA-23-054 GO2-23-093, Supplement to Reply to a Notice of Violation: EA-21-1702023-07-27027 July 2023 Supplement to Reply to a Notice of Violation: EA-21-170 ML23206A2442023-07-25025 July 2023 Energy Northwest Columbia Generating Station, Response to Apparent Violation in NRC Inspection Report 05000397/2023092; EA-23-054 GO2-23-090, Reply to a Notice of Violation2023-07-12012 July 2023 Reply to a Notice of Violation GO2-18-146, Response to Inspection Report 05000397/20180032018-11-29029 November 2018 Response to Inspection Report 05000397/2018003 GO2-17-173, Revised Response to a Notice of Violation; EA-17-0282017-10-11011 October 2017 Revised Response to a Notice of Violation; EA-17-028 GO2-17-141, Reply to a Notice of Violation; EA-17-0282017-08-0303 August 2017 Reply to a Notice of Violation; EA-17-028 GO2-17-100, Response to Inspection Report 05000397/20160092017-05-0909 May 2017 Response to Inspection Report 05000397/2016009 GO2-15-179, Response to Inspection Report 05000397/20150032015-12-22022 December 2015 Response to Inspection Report 05000397/2015003 GO2-11-137, Supplemental Information Provided to Report 0500397/20100072011-08-11011 August 2011 Supplemental Information Provided to Report 0500397/2010007 GO2-08-107, Reply to Notice of Violation; EA-08-1832008-07-16016 July 2008 Reply to Notice of Violation; EA-08-183 GO2-08-099, Reply to a Notice of Violation, EA-04-1452008-07-0202 July 2008 Reply to a Notice of Violation, EA-04-145 GO2-05-142, Response to Inspection Report 05000397-05-0072005-08-15015 August 2005 Response to Inspection Report 05000397-05-007 GO2-05-065, Review of NRC Violation 50-397/04-05-022005-04-0404 April 2005 Review of NRC Violation 50-397/04-05-02 ML0411803842004-04-16016 April 2004 Reply to Non-Cited Violation from IR 05000397/03-007 GO2-02-134, Energy Northwest, Docket No. 50-397, NRC Inspection Report 50-397/02-05, Response to Notice of Violation2002-08-21021 August 2002 Energy Northwest, Docket No. 50-397, NRC Inspection Report 50-397/02-05, Response to Notice of Violation GO2-02-016, Operating License NPF-21 Reply to Final Significance Determination for a Yellow Finding and Notice of Violation (NRC IR 05000397/2001-008)2002-02-28028 February 2002 Operating License NPF-21 Reply to Final Significance Determination for a Yellow Finding and Notice of Violation (NRC IR 05000397/2001-008) IR 05000397/20010082002-02-20020 February 2002 Reply to Final Significance Determination for a Yellow Finding and Notice of Violation (NRC Inspection Report 50-397/01-008) 2024-01-08
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Robert E. Schuetz Vice President, Operations P.O. Box 968, Mail Drop PE23 Richland, WA 99352-0968 Ph. 509-377-2425 F. 509-377-4674 reschuetz@energy-northwest.com October 11, 2017 GO2-17-173 10 CFR 2.201 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 REVISED RESPONSE TO A NOTICE OF VIOLATION; EA-17-028
References:
- 1) Letter EA-17-028 from K Kennedy (NRC) to ME Reddemann (Energy Northwest), Columbia Generating Station - Final Significance Determination of a White Finding, Notice of Violation, Follow-Up Assessment Letter and NRC Inspection Report 05000397/2017009, dated July 6, 2017.
- 2) Letter from WG Hettel (Energy Northwest) to NRC, Reply to a Notice of Violation, dated August 3, 2017.
Dear Sir or Madam:
As required by 10 CFR 2.201, Reference 2 provides Energy Northwests reply to Notice of Violation EA-17-028. The initial cause analysis has since been re-evaluated for thoroughness, and the root cause revised. This letter provides the revised response, which, as described in the enclosure, includes the reason for the violation, the corrective steps that have been taken and the results achieved, the corrective steps that will be taken, and the date when full compliance was achieved.
G02-17-173 Page 2 of 2 There are no commitments being made to the Nuclear Regulatory Commission by this letter. Should you have any questions, please contact DM Wolfgramm, Regulatory Compliance Supervisor, at (509) 377-4792.
Executed this _I l_ day of _O_c.....
_~_0_b _e.r_, 2017 Respectfully,
~~
R. E. Schuetz Vice President, Ope~ tio s
Enclosure:
Revised Response to EA-17-028 Notice of Violation cc:
NRC Director-Division of Reactor Safety, Region IV NRC Region IV Administrator NRC NRR Project Manager NRC Sr. Resident lnspector/988C CD Sonoda - BPA/1399 w/o enclosure WA Horin - Winston & Strawn w/o enclosure
GO2-17-173 Enclosure Cover Page Columbia Generating Station Revised Response to EA-17-028 Notice of Violation
GO2-17-173 Enclosure Page 1 of 3 Notice of Violation NRC letter EA-17-028 dated July 6, 2017, cited the violation as stated below.
10 CFR 71.5(a) requires, in part, that each licensee who transports licensed material outside the site of usage, as specified in the NRC license, or where transport is on public highways, shall comply with the applicable requirements of the Department of Transportation regulations in 49 CFR Parts 171 through 180.
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 10 mSv/hr (1 rem/hr) at 3 meters (10 feet) from the unshielded material.
Contrary to the above, on November 9, 2016, the licensee failed to transport low specific activity material in accordance with the condition that the external dose rate may not exceed an external radiation level of 10 mSv/hr (1 rem/hr) at 3 meters (10 feet) from the unshielded material. Specifically, the licensee transported a package as low specific activity material with an external radiation level of 2.1 rem/hr at a distance of 3 meters from the unshielded material.
Energy Northwest accepts this violation, has taken prompt action to return to full compliance, and has implemented comprehensive corrective actions for long-term sustained compliance.
Reason for Violation The root cause of the violation was determined to be that Energy Northwest Management did not have the organizational alignment in place that will ensure proper Decision Making, Effective Supervisor Oversight, and Programmatic Validation to assure execution of critical radiological waste packaging and shipping activities in accordance with regulations. The contributing cause was that Chemistry Management did not implement effective corrective actions to address precursor Organizational and Programmatic issues within the Radiological Waste Shipping Program that were identified by the stations performance improvement and oversight programs.
Corrective Steps and Results Achieved Upon notification of the non-conforming condition immediate action was taken to return the shipment to Columbia which arrived onsite at 1545 PST on November 9, 2016 restoring compliance.
GO2-17-173 Enclosure Page 2 of 3 The following are corrective actions that have been taken:
- The station has developed and issued a detailed procedure for spent fuel pool clean-up activities integrated with associated Radioactive Waste Shipping and Handling procedures and ensures all roles and responsibilities for all affected departments are clearly defined, including who has decision-making authority;
- Prior to the detailed procedure implementation, radioactive waste shipments were reviewed and approved by the Radiation Protection Manager prior to transport;
- A peer self-assessment was performed of the Radioactive Waste Shipping and Handling Program with an industry peer and expert to identify performance vulnerabilities in the current program and to identify where gaps existed between Columbia radioactive waste shipping practices and industry standard practices. Recommendations have been evaluated and actioned appropriately;
- Filters located in the spent fuel pool were inventoried for proper tracking and disposal;
- Past radioactive waste shipments were reviewed for evidence of any incorrect characterizations, problems with documentation or violations that were not adequately addressed or that would warrant additional actions. Several minor documentation issues were identified and for one shipment a corrected manifest was provided to US Ecology;
- A Shipping Office has been established and will be the sole location for all shipping files. Additionally, all preparations, reviews and approvals for shipments will take place in the Shipping Office;
- An expectation has been established to validate the dose rates documented on shipping manifests prior to shipping material, either via direct surveys or by utilizing shielding calculations;
- Senior Management Challenge meetings are required and will occur for every shipment until corrective actions to preclude repetition are implemented.
Since the event which led to the notice of violation, there have been no events in which radioactive waste was transported with external dose rates contrary to 49 CFR Part 173.427(a)(1).
GO2-17-173 Enclosure Page 3 of 3 Corrective Steps That Will be Taken The following corrective actions will be taken:
- Energy Northwest will realign the Chemistry and Radiological Safety department to contain oversight positions knowledgeable in radioactive shipments;
- Energy Northwest will proceduralize the requirement to validate the dose rates documented on shipping manifests prior to shipping material, either via direct surveys or by utilizing shielding calculations;
- Energy Northwest will use this event as a case study for Manager/Supervisor training;
- Energy Northwest will conduct a workshop to align Chemistry Management on how to implement proper corrective actions to address Organizational and Programmatic issues;
- Energy Northwest will revise performance appraisals for Chemistry Management to include criteria for increasing their proficiency in implementing corrective actions.
Date of Full Compliance Full compliance with 10 CFR 71.5(a) and 49 CFR 173.427(a)(1) was achieved on November 9, 2016 at 1545 PST when the container in question was received at Columbia following notification of the non-conforming condition.