GO2-23-130, Reply to a Notice of Violation; EA-23-054

Reply to a Notice of Violation; EA-23-054

ML23348A359
Person / Time
Site:	Columbia
Issue date:	12/14/2023
From:	David Brown Energy Northwest
To:	Office of Nuclear Reactor Regulation, NRC Region 4, Document Control Desk
References
GO2-23-130, EA-23-054
Download: ML23348A359 (1)

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ENERGY David P. Brown Site Vice President NORTHWEST P.O. Box 968, PE23 Richland, WA 99352-0968 Ph. 509-377-8385 F. 509-377-4150 dpbrown@energy-northwest.com December 14, 2023 GO2-23-130 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 REPLY TO A NOTICE OF VIOLATION; EA-23-054

Reference:

Letter from J. Monninger (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 05000397/2023093, ML23276B477, dated November 1, 2023.

Dear Sir or Madam:

As required by 10 CFR 2.201, this letter provides Energy Northwests reply to Notice of Violation EA-23-054 cited in the Nuclear Regulatory Commission (NRC) inspection report (Reference). The response to the violation, 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 will be achieved.

Per telecon with the NRC Region IV on November 27, 2023, Energy Northwest received an extension for submittal of the response. This response will be submitted on or before December 15, 2023.

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.






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GO2-23-130 Page 2 of 2 Executed this ___ 

!day of ____________, 2023.

Respectfully, David P. Brown Site Vice President

Enclosure:

Reply to EA-23-054 Notice of Violation cc: NRC Director Division of Operating Reactor Safety, Region IV NRC Region IV Administrator NRC NRR Project Manager NRC Resident Inspector/988C NRC Enforcement, Region IV CD Sonoda - BPA/1399 w/o enclosure






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GO2-23-130 Enclosure Columbia Generating Station - Energy Northwest Reply to EA-23-054 Notice of Violation






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GO2-23-130 Enclosure Page 2 of 4 Energy Northwest accepts the violation documented in the Nuclear Regulatory Commission (NRC) Inspection Report 05000397/2023093 (Reference). Energy Northwest has recently conducted a root cause to better evaluate the failure to take suitable and timely measurements to determine internal exposure in accordance with 10 CFR 20.1204(a). Energy Northwest has taken prompt action towards return to full compliance and has determined a comprehensive corrective action plan for long-term sustained compliance related to the violation of 10 CFR 20.1204(a).

NRC letter dated November 1, 2023, (Reference) cited a violation of NRC requirements. Responses required by the letter are below.

Violation of 10 CFR 20.1204(a)

Notice of Violation From NRC letter dated November 1, 2023:

10 CFR 20.1204(a) requires, in part, that the licensee shall, when required under 10 CFR 20.1502, take suitable and timely measurements of: (1) concentrations of radioactive materials in air in work areas; or (2) quantities of radionuclides in the body; or (3) quantities of radionuclides excreted from the body; or (4) combinations of these measurements, to determine compliance with occupational dose equivalent limits.

10 CFR 20.1502(b)(1) requires, in part, that the licensee shall monitor the occupational intake of radioactive material by and assess the committed effective dose equivalent to adults likely to receive, in 1 year, an intake in excess of 10 percent of the annual limit on intake.

Contrary to the above, on May 28, 2021, when required under 10 CFR 20.1502, the licensee failed to take suitable and timely measurements of: (1) concentrations of radioactive materials in air in work areas; or (2) quantities of radionuclides in the body; or (3) quantities of radionuclides excreted from the body; or (4) combinations of these measurements, to determine compliance with occupational dose equivalent limits. Specifically, the licensee failed to: (1) take measurements of the concentrations of radioactive materials in the air at the work area and instead used a general area air sample point located approximately 15 feet away from the pipefitters receiving the intake of radioactive material; (2) properly evaluate alpha emitters, which would not be adequately detected using whole-body counts; (3) follow station procedures for in vitro monitoring by not conducting feces sampling or establishing elimination trends; or (4) use a combination of measurements from above to determine compliance with occupational dose equivalent limits.






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GO2-23-130 Enclosure Page 3 of 4 Reason for Violation The following were identified as the root causes of the violation:

Radiation Protection (RP) leaders were ineffective in shaping organizational behaviors and reinforcement of programmatic standards leading to inadequate demonstration of radiological command and controls.

Procedures following the radioactive material uptake were not easy to follow, required personnel with specialized experience to implement, and required exercising professional judgement to successfully determine the correct course of action.

The following as contributing causes:

x Radiation Services personnel did not demonstrate a prudent approach when making several decisions related to control of the job, which was an infrequently performed evolution and posed unplanned radiological risk.

x RP technicians, leads and supervisors did not uphold fundamental radiation safety standards related to positive RP command and control and adherence to relevant procedures.

Corrective Steps and Results Achieved Energy Northwest recently completed a root cause evaluation. The following actions from the root cause have recently been completed:

x As an Interim Action the Chemistry/Radiation Services Director will:

o communicate to all RP Technicians and Supervisors the expectation to immediately report all personnel contamination events (PCEs) and actual or potential internal radiological uptakes to the Chemistry/Radiation Services Director.

o assign himself or a direct report, depending on potential significance, to oversee the dose assessment actions with a focus on regulatory, Technical Specification, and procedure compliance.

o for internal radiological uptakes, hold challenge boards with a designated skeptic (a person who will not believe something is correct and complete unless they see the objective evidence) to validate actions planned and taken are adequate in ensuring compliance.

x Revision of site procedure(s) to reduce the level of professional judgment and more systematically assess and document dose based on quantities of radionuclides in the body.






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GO2-23-130 Enclosure Page 4 of 4 x Establish an in-house Radiation Protection (RP) leader, or hire a new RP leader, to be the point of contact for management and oversight of radiological contamination and exposures with responsibilities commensurate with significance. The leader reports to the RP Manager, and Station Senior Leadership team daily on the status of all significant exposures and internal occupational dose assessment actions taken and planned until resolution. The position will only be active when a radiological intake occurs.

Additional corrective actions yet to be completed have been identified below.

Corrective Steps that Will be Taken x Conduct an evaluated Dynamic Learning Activity (DLA) for Energy Northwest and Contract RP Technicians, RP Supervisors, Planners and Support Staff to include:

o Fundamental Radiation Safety Standards o Positive RP command and control of radiological work activities o Prudent over simply allowable approach to decisions related to control of radiological jobs.

x Establish initial and periodic evaluated DLAs and Oral Boards for EN and Contract RP Technicians, RP Supervisors, Planners and Support Staff on:

o Fundamental Radiation Safety Standards o Positive RP command and control of radiological work activities o Prudent over simply allowable approach to decisions related to control of radiological jobs.

Date of Full Compliance Full compliance with 10 CFR 20.1204(a) will be achieved upon completion of re-assessment of assigned internal dose for workers who received internal contamination during the Refueling Outage 25 Reactor Water Cleanup pipe weld contamination event.