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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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ENERGY David P. Brown Site Vice President P.O. Box 968, PE23 NORTHWEST Richland, WA 99352-0968 Ph. 509-377-8385 F. 509-377-4150 dpbrown@energy-northwest.com July 27, 2023 GO2-23-093 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 SUPPLEMENT TO REPLY TO A NOTICE OF VIOLATION; EA-21-170
References:
(1) Letter from D Brown (Energy Northwest) to US Nuclear Regulatory Commission, "Reply to a Notice of Violation; EA-21-170,"
ML23193B032, GO2-23-090, dated July 12, 2023.
(2) Letter from R Lewis (NRC) to R Schuetz (Energy Northwest),
Columbia Generating Station - Final Significance Determination of a White Finding, Notice of Violation and Follow-Up Assessment Letter; NRC Inspection Report 05000397/2023090, ML23111A237, dated June 1, 2023.
Dear Sir or Madam:
Energy Northwest is hereby submitting this supplement to its July 12, 2023, letter (Reference 1) in accordance with the July 6, 2023, telecon with U.S. Nuclear Regulatory Commission (NRC) Region IV.
This response contains additional information not available at the time of the initial letter pertaining to the second and third violations noted in the NRC letter dated June 1, 2023 (Reference 2). The responses for the second and third violations, described in the enclosure, include 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.
There are no commitments being made to the NRC by this letter. Should you have any questions, please contact IR Bitner, Regulatory Compliance Supervisor, at (509) 377-4204.
GO2-23-090 Page 2 of 2 Executed this17t';).. day of J"\2\~ , 2023 David P. Brown Site Vice President
Enclosure:
Supplement to Reply to EA-21-170 Notice of Violation cc: NRC Director-Division of Operating Reactor Safety, Region IV NRC Region IV Administrator NRC NRR Project Manager NRC Resident lnspector/988C NRC Enforcement, Region IV CD Sonoda - BPA/1399 w/o enclosure
GO2-23-093 Enclosure Columbia Generating Station - Energy Northwest Supplement to Reply to EA-21-170 Notice of Violation
GO2-23-093 Enclosure Page 2 of 5 As noted in Energy Northwests July 12, 2023, letter to the U.S. Nuclear Regulatory Commission (NRC) (Reference 1), Energy Northwest accepts these violations, has taken prompt action to return to full compliance and has implemented comprehensive corrective actions for long-term sustained compliance related to the violation of 10 CFR 20.1701.
The root cause evaluation conducted to better evaluate the violations of Technical Specification 5.7.2.b and 10 CFR 20.1501(a)(2) was completed and required responses for these two violations are show below.
NRC letter dated June 1, 2023, (Reference 2) cited three violations of NRC requirements.
A. Violation of 10 CFR 20.1701 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 for this violation were submitted as part of the July 12, 2023, letter from Energy Northwest to the NRC (Reference 1) and therefore will not be duplicated as part of this supplement.
B. Violation of Technical Specification 5.7.2.b Notice of Violation Technical Specification 5.7.2.b requires, in part, that access to, and activities in, each high radiation area with dose rates greater than 1.0 rem/hour at 30 centimeters from the radiation source shall be controlled by means of a radiation work permit.
Radiation work permit 30004732, created to control activities in a Technical Specification 5.7.2.b high radiation area, required, in part, that continuous Health Physics job coverage is provided when personnel are entering and working in areas with dose rates greater than 0.8 rem/hour.
Contrary to the above, on May 28, 2021, the licensee failed to control the activities in a high radiation area with dose rates greater than 1.0 rem/hour at 30 centimeters from the radiation source in accordance with radiation work permit 30004732. Specifically, the licensee failed to follow radiation work permit 30004732 and provide continuous Health Physics job coverage when personnel entered and worked in an area with dose rates greater than 0.8 rem/hour (i.e.,
1.3 rem/hour at 30 centimeters from the radiation source). A radiation protection technician, scheduled to provide the continuous Health Physics job coverage, was unable to physically fit on the work area platform and left the workers unattended in the area. A second radiation protection technician subsequently
GO2-23-093 Enclosure Page 3 of 5 replaced the original technician as the workers were conducting job activities in the work area.
Reason for Violation The direct cause identified was inadequate adherence and implementation of station and department-level instructions, policies, and procedures which resulted in approval and implementation of plans that were not appropriate to support successful performances of infrequently performed activities, were insufficient to mitigate risk, or included error traps.
Additionally, disposition of adverse events by the Radiological Services group (by application of the station corrective action program) was not performed in a manner which facilitated identification and resolution of systemic level shortcomings in station radiological controls.
Radiological Services resources were challenged to ensure correct implementation of planned work in all cases.
Corrective Steps and Results Achieved Energy Northwest recently completed an additional root cause evaluation as noted in the original response (Reference 1). Additional corrective actions including those to prevent recurrence have been identified below.
Corrective Steps that Will be Taken Actions to be taken include:
- Develop and implement a required formal as low as reasonably achievable (ALARA) plan review tool for elevated and high radiological risk activities.
- Revise Corrective Action program procedures, instructions, and related guidance to preclude use of human error or culpability for root, apparent, and contributing causes and analytical products.
- Develop a job familiarization guide (JFG) with specific focus on management of Radiological Services outage resources.
Date of Full Compliance Full compliance was achieved on May 29, 2021, upon approval of return-to-work criteria.
GO2-23-093 Enclosure Page 4 of 5 C. Violation of 10 CFR 20.1501(a)(2)
Notice of Violation 10 CFR 20.1501(a)(2) requires, in part, that licensees shall make surveys of areas that are reasonable under the circumstances to evaluate the magnitude and extent of radiation levels; and concentrations or quantities of residual radioactivity.
Contrary to the above, on May 27, 2021, the licensee failed to make surveys of areas that were reasonable under the circumstances to evaluate the magnitude and extent of radiation levels; and concentrations or quantities of residual radioactivity. Specifically, the licensee failed to adequately determine the work area radiation levels as documented in survey M-20210528-13, which stated, the survey was not an extensive search for the highest exposure rate. In addition, the licensee failed to adequately evaluate the extent of contamination levels on the piping prior to the work activity. The surveys completed prior to the event did not adequately identify work area dose rates and did not identify appropriate contamination levels, resulting in a lower risk rating to the job and less rigorous radiological controls for the activity.
Reason for Violation The cause identified was ineffective enforcement of station/department standards, policies, and administrative controls, due to inadequate review and approval processes.
Additionally, disposition of adverse events by the Radiological Services group (by application of the station corrective action program) was not performed in a manner which facilitated identification and resolution of systemic level shortcomings in station radiological controls.
Radiological Services resources were challenged to ensure correct implementation of planned work in all cases.
Corrective Steps and Results Achieved Energy Northwest recently completed an additional root cause evaluation as noted in the original response (Reference 1). Additional corrective actions including those to prevent recurrence have been identified below.
GO2-23-093 Enclosure Page 5 of 5 Corrective Steps that Will be Taken Actions to be taken include:
- Develop and implement a formal survey review tool required to be completed for approving surveys. Completed reviews should be attached to surveys for periodic quality reviews.
- Revise Corrective Action program procedures, instructions, and related guidance to preclude use of human error or culpability for root, apparent, and contributing causes and analytical products.
- Develop a job familiarization guide (JFG) with specific focus on management of Radiological Services outage resources.
Date of Full Compliance Full compliance was achieved on May 29, 2021, upon approval of return-to-work criteria.