GO2-17-173, Revised Response to a Notice of Violation; EA-17-028

Revised Response to a Notice of Violation; EA-17-028

ML17284A834
Person / Time
Site:	Columbia
Issue date:	10/11/2017
From:	Schuetz R Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation, NRC Region 4
References
EA-17-028, GO2-17-173, IR 2017009
Download: ML17284A834 (6)

Text

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.