IR 05000397/2024040
| ML25073A062 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/02/2025 |
| From: | Jeffrey Josey NRC/RGN-IV/DRSS/DIOR |
| To: | Schuetz R Energy Northwest |
| References | |
| EA-21-170, EA-23-054 IR 2024040 | |
| Download: ML25073A062 (1) | |
Text
April 02, 2025
SUBJECT:
COLUMBIA GENERATING STATION - 95001 SUPPLEMENTAL INSPECTION REPORT 05000397/2024040 AND FOLLOW-UP ASSESSMENT LETTER
Dear Robert Schuetz:
On February 25, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed a supplemental inspection using Inspection Procedure 95001, "Supplemental Inspection Response to Action Matrix Column 2 (Regulatory Response) Inputs, and discussed the results of this inspection with W.G. Hettel, Chief Nuclear Officer, and other members of your staff.
The NRC performed this inspection to review your stations actions in response to two White findings in the Occupational Radiation Safety cornerstone. The first White finding was documented and finalized in NRC Inspection Reports 05000397/2021090 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML21347A988) dated January 13, 2022, and 05000397/2023090 (ADAMS Accession No. ML23111A237) dated June 1, 2023. The second White finding was documented and finalized in NRC Inspection Reports 05003979/2023092 (ADAMS Accession No. ML23139A121) dated June 1, 2023, and 05000397/2023093 (ADAMS Accession No. ML23276B477) dated November 1, 2023.
On December 14, 2023, you informed the NRC that your station was ready for the supplemental inspection and the direct inspection was scheduled to begin March 4, 2024. The inspectors identified concerns regarding your readiness, and you were offered the opportunity to defer or reschedule the supplemental inspection on February 22, 2024. The inspection was subsequently deferred. On June 19, 2024, you again informed the NRC that your station was ready for the supplemental inspection. Subsequently, the NRC commenced the 95001 direct inspection activities on August 19, 2024.
The NRC determined that your staffs evaluation identified the cause of the White findings.
Specifically, the NRC determined that your staff identified three root causes. Those causes were: (1) Radiation Protection (RP) Leaders were ineffective in shaping organizational behaviors and reinforcement of programmatic standards leading to inadequate demonstration of radiological command and controls; (2) Procedures for bioassay were not adequate in that they 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; and (3) The ALARA planning process was inadequate in the determination of high-risk work as an entry point into a high level of ALARA planning, review, and oversight. Corrective actions to address the root causes included conducting evaluated dynamic learning activities to include fundamental radiation protection standards, positive radiation protection command and control, and updating multiple procedures.
Overall, the inspectors determined that the licensee's problem identification, causal analysis, and corrective actions sufficiently addressed the notices of violation that led to the two White findings after resolution of NRC identified significant weaknesses. The final revision of the root cause evaluation documented in condition report/action request (AR) 456014, dated October 7, 2024, and internal dose assessments, dated February 13, 2025, contains sufficient information such that all inspection objectives, as described in NRC Inspection Procedure 95001, were met.
The NRC determined that completed or planned corrective actions were sufficient to address the performance issues that led to the two White findings. Therefore, the performance issues will be closed and no longer considered as an Action Matrix input as of the date of the exit meeting (February 25, 2025). Based on the results of this inspection and our Action Matrix assessment, the NRC has determined that Columbia Generating Station will be in the Licensee Response Column of the Action Matrix, effective with the published date of this final 95001 supplemental inspection report.
No findings or violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Jeffrey E. Josey, Chief Decommissioning, ISFSI, Operating Reactor Branch Division of Radiological Safety and Security Docket No. 05000397 License No. NPF-21
Enclosure:
As stated
Inspection Report
Docket Number:
05000397
License Number:
Report Number:
Enterprise Identifier:
I-2024-040-0002
Licensee:
Energy Northwest
Facility:
Columbia Generating Station
Location:
Richland, Washington
Inspection Dates:
August 19, 2024, to February 25, 2025
Inspectors:
D. Antonangeli, Resident Inspector
J. Cassidy, Senior Health Physicist
Approved By:
Jeffrey E. Josey, Chief
Decommissioning, ISFSI & Operating Reactors Branch
Division of Radiological Safety & Security
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting a 95001 supplemental inspection at Columbia Generating Station, in
accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs
program for overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
95001 - Supplemental Inspection Response to Action Matrix Column 2 (Regulatory Response)
Inputs
On December 14, 2023, the NRC was informed the station was ready for the supplemental
inspection (ML23348A364) and the direct inspection was scheduled to begin March 4, 2024.
The inspectors identified concerns regarding the licensees readiness. In accordance with IMC 2515 Appendix B, the licensee was offered the opportunity to defer or reschedule the
supplemental inspection on February 22, 2024, as documented in an annual assessment letter
dated February 28, 2024 (ML24047A315). The inspection was subsequently deferred upon
licensee request. On June 19, 2024, the NRC was informed the station was ready for the
supplemental inspection (ML24171A019). The direct inspection commenced on August 19,
2024, and the inspectors identified three significant weaknesses, one general weakness, and
one minor weakness. All weaknesses are described in this report.
The inspection was suspended on August 22, 2024, when the licensee committed to resolve the
three significant weaknesses in a reasonable amount of time (about 2 months) to revise the root
cause evaluation and perform detailed surveys of the chemical decontamination unit used
during the reactor water cleanup heat exchanger replacement project in May 2021, to better
define the radionuclides in the work area at the time of event.
The revised root cause evaluation was provided on October 8, 2024. The detailed surveys of
the chemical decontamination unit were provided on November 20, 2024. On November 26,
2024, the inspectors and the licensee discussed the revised root cause evaluation, the results of
the detailed surveys, including the impact of those surveys on the internal dose assessments.
The inspectors determined the revised root cause evaluation was adequate to close two of the
significant weaknesses previously identified. The licensee informed the inspectors the new
surveys performed on the chemical decontamination unit did not represent radionuclides at
Columbia Generating Station. The licensee informed the inspectors the chemical
decontamination unit was previously used at another nuclear power plant and was received as
radioactive material.
The inspectors informed the licensee that the third significant weakness, restoring compliance
with 10 CFR 20.1204, Determination of internal exposure, could not yet be closed. Specifically,
the parameters used for the internal dose assessment calculations did not adequately bound
the radionuclides that could have been present in the work environment during the event. The
inspectors identified similar deficiencies in the subsequent internal dose assessment, dated
December 5, 2024. On February 13, 2025, the licensee provided revised internal dose
assessment calculations with bounding conditions, developed with external contractor support,
and proposed revision to the NRC Form-5, Occupational Dose Record for a Monitoring Period,
for the two pipefitters associated with the event. The inspectors determined this was adequate
to close the final significant weakness.
The inspectors reviewed aspects of the licensees problem identification, causal analysis, and
corrective actions in response to the failure to implement and follow written procedures,
associated Radiological Work Permit, and ALARA Plan instructions for job tasks associated with
the reactor water cleanup (RWCU) heat exchanger (HX) piping on May 28, 2021, as
documented in NRC Inspection Reports 05000397/2021090 (ML21347A988), dated January 13,
2022, and 05000397/2023090 (ML23111A237), dated June 1, 2023. This White input to the
NRC Action Matrix will be identified as The White Finding Related to Use of Radiation
Protection Engineering Controls, Radiation Work Permits, and Surveys in the remainder of this
report.
Additionally, the inspectors reviewed aspects of the licensees problem identification, causal
analysis, and corrective actions in response to the failure to take suitable and timely
combination of measurements, including radioactive material in air in work areas, and urine and
fecal samples to properly evaluate alpha emitters in the body contributing to the accrued internal
dose. These failures resulted in the inability of the licensee to properly assess the dose accrued
by the pipefitters following the RWCU HX contamination event on May 28, 2021, as
documented in in NRC Inspection Reports 05000397/2023092 (ML23139A121) dated June 1,
2023, and 05000397/2023093 (ML23276B477) dated November 1, 2023. This White input to
the Action Matrix will be identified as Compromised Ability to Assess Dose in the remainder of
this report.
Objective: Ensure that the root and contributing causes of individual and collective White
performance issues are understood.
The White Finding Related to Use of Radiation Protection Engineering Controls, Radiation
Work Permits, and Surveys
Under this objective, the inspectors reviewed the root cause evaluation(s) the licensee
conducted for the failure to implement and follow written procedures, associated
Radiological Work Permit, and ALARA Plan instructions for job tasks associated with the
RWCU HX piping on May 28, 2021, as documented in in NRC Inspection Reports
05000397/2021090 (ML21347A988) dated January 13, 2022, and 05000397/2023090
(ML23111A237) dated June 1, 2023. Their review consisted of an evaluation of the
following: the identification of the issue(s), when and how long the issue(s) existed, prior
opportunities for identification, documentation of significant consequences and compliance
concerns, use of systematic methodology to identify causes with a sufficient level of
supporting detail, consideration of prior occurrences, identification of extent of condition and
extent of cause, and identification of any potential programmatic weaknesses in
performance.
NRC Assessment: After resolution of an NRC identified significant weakness, the
inspectors concluded that this objective was Met. The inspectors determined that the
licensee's revised root cause evaluation (RCE) appropriately identified and documented the
root cause, extent of condition, and extent of cause of the White performance issue.
The significant weakness with the licensees RCE, dated June 20, 2024, was that
contributing cause #3 (CC3) should have been a root cause. The inspectors were able to
answer the 95001 screening questions in the affirmative for contributing cause #3 (CC3)
indicating that the application of rigorous job planning was a root cause and should have
been assigned corrective action(s) to prevent recurrence (CAPRs) and an extent of
condition/cause analysis should have been applied. The licensee changed CC3 to Root
Cause 3 (RC3), including modifying the cause words to align with a root cause, made the
CC3 Corrective Action into a Corrective Action to Preclude Repetition (CAPR), added an
effectiveness review for the new RC3, and performed an Extent of Cause Matrix for RC3.
This resulted with two new corrective actions. The inspectors determined the revision to the
RCE report, including Extent of Condition for (new) Root Cause #3, reasonably addressed
the stated concern.
a. Identification. The two pipefitters that performed the cut on the heat exchanger piping
alarmed the personnel contamination monitors when they exited the radiological controlled
area. This issue was characterized as an NRC identified violation due to the inspectors
identifying inadequacies in the licensees characterization and evaluation of the performance
deficiency.
b. Exposure Time. The RCE documented the performance issue started on October 23,
2020, during pre-outage planning when the ALARA plan for pipe weld preparation was
categorized as Elevated Risk (Medium Risk) instead of High Risk. The RCE also
documented the dates when compliance was restored for each of the performance issues
associated with the white finding related to use of radiation protection engineering controls,
radiation work permits, and surveys.
c. Identification Opportunities. The RCE included a Sequence of Events timeline that
identified missed opportunities to identify the conditions that led to the white finding related
to use of radiation protection engineering controls, radiation work permits, and surveys.
d. Methodology. The licensee's evaluation employed systematic evidence based causal
analysis to reliably and scrutinizingly determine the root and contributing causes of the
White performance issue including Comparative Timeline, Change Analysis, Barrier
Analysis, Organizational and Programmatic Evaluation, and Event and Causal Factor
Charting.
e. Level of Detail. The inspectors determined that the RCE was conducted and
documented in sufficient detail commensurate with the significance and complexity of the
issue and regulatory requirements.
f. Operating Experience. For the RCE, the licensee conducted reviews of internal and
external operating experience. The reviews looked for occurrences of same or similar
performance issues where knowledge gained could be used to improve the evaluation. The
inspectors determined that the operating experience was appropriately considered to
identify and prevent similar occurrences.
g. Extent of Condition and Cause. The licensee's extent of condition evaluated whether
the identified condition exists within other work activities with high radiological risk where
actual conditions exist or may exist which could result in a loss of RP command and control.
The licensee did not identify any additional actual conditions. The licensee's extent of cause
evaluated whether the identified causes that created the condition exists in other areas at
Columbia Generating Station. The licensee identified that the extent of cause and potential
risk is mostly objective in the extent of equipment related causes, but somewhat subjective
in the extent of human performance, process, and organizational causes. The licensee has
created actions to address similar issues including: (1) the conduct of dynamic learning
activities to evaluate RP technicians and supervisors to include fundamental radiation
standards; positive RP command and control of radiological work activities; decisions related
to control of radiological jobs are prudent over simply allowable approach; and (2) update
plant Procedure PPM 11.2.2.12, Radiological Risk Assessment and Management, to
define risk mitigation and risk elimination actions; determine initial risk assuming no
elimination or mitigation actions; and to only allow the risk categorization to credit the
elimination of risk.
Compromised Ability to Assess Dose
Under this objective, the inspectors reviewed the RCEs the licensee conducted for the
failure to take suitable and timely measurements to adequately assess the internal dose of
the two pipefitters and compliance with occupational dose equivalent limits associated with
the RWCU HX contamination event on May 28, 2021, as documented in NRC Inspection
Reports 05000397/2023092 (ML23139A121), dated June 1, 2023, and 05000397/2023093
(ML23276B477), dated November 1, 2023. Their review consisted of an evaluation of the
following: the identification of the issue(s), when and how long the issue(s) existed, prior
opportunities for identification, documentation of significant consequences and compliance
concerns, use of systematic methodology to identify causes with a sufficient level of
supporting detail, consideration of prior occurrences, identification of extent of condition and
extent of cause, and identification of any potential programmatic weaknesses in
performance.
NRC Assessment: After resolution of an NRC identified significant weakness, the
inspectors concluded that this objective was Met. The inspectors determined that the
licensee's revised RCE appropriately identified and documented the root cause, extent of
condition, and extent of cause of the White performance issue.
The significant weakness with the licensees RCE dated June 20, 2024, was that it did not
provide an adequate description, or results, of the extent of cause for root cause #2 (RC2) in
that it focused too narrowly on health physics support services and did not ensure other RP
disciplines or other departments had procedures that were difficult to follow, required
personnel with specialized experience to implement, or required exercising professional
judgement to successfully determine the correct course. The licensee clarified and
expanded the documented scope of the Extent of Cause for RC2. This included adding an
Extent of Cause Matrix for RC2. The inspectors determined the revision to the RCE report,
including Extent of Cause for RC2, reasonably addressed the stated concern.
The licensee's casual analysis determined the failure to take suitable and timely
measurements to adequately assess the internal dose of the two pipefitters and compliance
with occupational dose equivalent limits associated with the RWCU HX contamination event
on May 28, 2021, had one root cause. The root cause (RC2) was the procedure for
bioassay was not adequate in that they were not easy to follow, required personnel with
specialized experience to implement, and required professional judgement to successfully
determine the correct course of actions.
Two contributing causes were identified: (1) 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;
(2) RP technicians, RP Leads, and RP Supervisors did not uphold fundamental radiation
safety standards related to positive RP command and control and adherence
to relevant procedures.
a. Identification.
The NRC identified the licensees failure to take suitable and timely measurement to
adequately assess internal dose of two pipefitters during their review of the May 28, 2021
uptake event.
b. Exposure Time. The RCE documented the performance issue started on May 28, 2021,
when an insufficient post event survey was taken to establish radiological conditions. The
RCE also documented the dates when compliance was restored for each of the
performance issues associated with the compromised ability to assess dose.
c. Identification Opportunities. The RCE included a Sequence of Events timeline that
identified missed opportunities to identify the conditions that led to the compromised ability
to assess dose.
d. Methodology. The licensee's evaluation employed systematic evidence based causal
analysis to reliably and scrutinizingly determine the root and contributing causes of the
White performance issue including Comparative Timeline, Change Analysis, Barrier
Analysis, Organizational and Programmatic Evaluation, and Event and Causal Factor
Charting.
e. Level of Detail. The inspectors determined that the RCE was conducted and
documented in sufficient detail commensurate with the significance and complexity of the
issue and regulatory requirements.
f. Operating Experience. For the RCE, the licensee conducted reviews of internal and
external operating experience. The reviews looked for occurrences of same or similar
performance issues where knowledge gained could be used to improve the evaluation. The
inspectors determined that the operating experience was appropriately considered to
identify and prevent similar occurrences.
g. Extent of Condition and Cause. The licensee's extent of condition evaluated internal
dose assessments following a radiological uptake lacked suitable or timely measurements to
appropriately assess total dose for impacted workers, resulting in ineffective or inadequate
actions to fully address the dose assigned to individuals. The licensee did not identify any
additional actual conditions.
The licensee's revised extent of cause evaluated whether the identified condition exists
within other procedures requiring personnel with specialized experience to implement and
requiring professional judgment to successfully determine the correct course of actions. This
review covered complex, infrequently performed activities requiring specialized experience
in the areas of RP and bioassays, Operations/Emergency Preparedness and Radiological
Releases, Environmental and Regulatory Programs and Environmental Releases,
Operations/Training and NRC Exam Creation, Reactor Engineering and Control Rod
Depletion Measurements / Replacement, Maintenance and Heavy/Controlled Lifts,
Emergency Preparedness and Emergency Response Procedures, Construction Project
Management and Concrete Cutting and Drilling, Industrial Safety and Asbestos and Lead
Exposures, Operations and Plant Startup/Reactivity Manipulations, and Work Control and
Outage Scope Change Request (OSCR) / Decision Making Matrix (DMM).
It should be noted the licensees RCE, dated June 20, 2024, did not provide an adequate
description, or results, of the extent of cause for RC2 because it too narrowly focused on
health physics support services and did not ensure other RP disciplines or other
departments had procedures that were not easy to follow, required personnel with
specialized experience to implement, and required exercising professional judgement to
successfully determine the correct course of actions. Consequently, the inspectors
characterized this deficiency as a Significant Weakness.
The licensee, in accordance with Corrective Action Program processes, clarified and
expanded the documented scope of the Extent of Cause for RC2. This included adding an
Extent of Cause Matrix for RC2.
The inspectors determined the revision to the RCE report, including Extent of Cause for
RC2, reasonably addressed the stated concern.
Common Cause
The licensee determined RC1 was common for both white findings. Specifically, RP Leaders
were ineffective in shaping organizational behaviors and reinforcement of programmatic
standards leading to inadequate demonstration of radiological command and controls.
Objective: Ensure that completed corrective actions to address and preclude repetition of White
performance issues are timely and effective.
The White Finding Related to Use of Radiation Protection Engineering Controls, Radiation
Work Permits, and Surveys
Under this objective, the inspectors assessed the appropriateness and timeliness of the
licensee's corrective actions.
NRC Assessment: The inspectors concluded that this objective was Met. The inspectors
determined that the corrective actions reviewed under this section were implemented
appropriately and in a timely manner as discussed in detail below.
Root Cause 1: RP Leaders were ineffective in shaping organizational behaviors and
reinforcement of programmatic standards leading to inadequate demonstration of
radiological command and controls.
Root Cause 3: The ALARA planning process was inadequate in the determination of high-
risk work as an entry point into a high level of ALARA planning, review, and oversight.
Corrective actions are documented and tracked in the licensee's corrective action program
under condition report AR 456014456014
a. Completed Corrective Actions to Prevent Recurrence
(1) CAPR1.1 (456014-03) Establish initial and periodic evaluated dynamic learning activities
(DLAs), for Energy Northwest and Contractor RP Technicians, RP Supervisors, and case
studies/tabletop for ALARA Planners and Support Staff to include:
- Fundamental Radiation Safety Standards
- Positive RP command and control of radiological work activities
- Prudent over simply allowable approach to decisions related to control of
radiological jobs.
(2) CAPR3.1 (456014-15) Update PPM 11.2.2.12, Radiological Risk Assessment and
Management, with the following:
- Define risk mitigation and risk elimination actions.
- Determine initial risk assuming no elimination or mitigation actions.
- Only allow the risk categorization to credit the elimination of risk.
Compromised Ability to Assess Dose
Under this objective, the inspectors assessed the appropriateness and timeliness of the
licensee's corrective actions.
NRC Assessment: After resolution of an NRC identified significant weakness, the
inspectors concluded that this objective was Met. The inspectors determined that the
licensee's revised dose assessment and the assumed bounding conditions were adequate
to restore compliance to 10 CFR 20.1204 identified in the second White performance issue.
The significant weakness was that the licensees December 2023 internal dose assessment
of the March 2021 event was inadequate. Specifically, for the second White finding
(ML23139A121 and ML23276B477), the NRC identified that the licensee incorrectly relied
on survey information that did not properly characterize the alpha component in the dose
assessment. In addition, the licensees calculation did not include the entire set of
radionuclides that could have been present in the work environment during the work activity.
The compromised ability to assess dose characterized in the second finding could not be
restored without a calculation that bounded these conditions. Furthermore, the licensee had
an error in their calculation when assigning the Pu-238 dose component and they used the
inadequate survey information to eliminate possible alpha contributors to the internal
exposure. Due to these errors, the inspectors determined the dose assessment performed
in December 2023 did not adequately address the pipefitters internal exposure or correctly
identify the critical organ associated with the exposure. The inspection was put on pause
again during the on-site week due to this significant weakness until the licensee took
corrective action.
The licensee developed corrective actions to gather additional radiological information about
the conditions that could have been present during the event. They performed radiological
surveys from the chemical decontamination skid since it was used to clean the RWCU heat
exchanger removed from the plant in May 2021. However, the licensee concluded the
survey results were not representative of the stations radiological condition because the
decontamination skid had been previously used at another nuclear power plant and was
received as radioactive material.
In January 2025, the licensee, with contracted support, performed a bounding internal dose
assessment of the March 2021 event with the best information available. This information
was a smear sample collected during similar work activities a few days prior to the event,
24-hour urine sample collected after the event, a report of scaling factors for difficult to
measure radionuclides in the reactor water cleanup system revised in April 2021, and
whole-body count results for the affected workers performed after the event for the
radionuclides.
The inspectors reviewed the methodology used to calculate the internal exposures for the
two pipefitters most effected by the event. The inspectors scrutinized the characterization of
radionuclides that are difficult to measure but were likely present in the work area, and thus,
were likely contributors to internal exposures of the pipefitters. The inspectors determined
the licensees approach was adequate to bound the conditions and restore compliance with
10 CFR 20.1204 Determination of internal exposure. Overall, the final revised internal dose
evaluation increased the dose for both pipefitters which required the licensee to calculate
the dose to the maximum exposed organ, in this case, the bone surfaces. The revised
bounding dose exposures represent approximately 39% of the whole-body exposure limit (5
rem) and 21% of the total organ dose limit (50 rem). Thus, the final bounded dose values
were within the applicable 10 CFR Part 20 dose limits. The associated NRC Form 5 records
have been updated.
Additionally, the inspectors identified a General Weakness, and a Minor Weakness,
associated with the compromised ability to assess dose, as detailed below.
General Weakness - The inspectors identified a weakness in the planned effectiveness
review for CAPR 1.1 as it applies to the subgroup called radiation protection support staff.
The effectiveness reviews for CAPR 1.1 are adequate for the remainder of the radiation
protection staff. The licensee established three methods, with corresponding success
measures, to review the effectiveness of the corrective actions for the Root Cause 1.
However, due to the infrequent occurrence of unplanned internal exposure at any licensee
facility, there is a high chance there will not be any inputs to evaluate during the planned
review period. Consequently, the tabletop and scenarios modified by AR 461387461387may be the
only input for the licensee to assess the effectiveness of CAPR 1.1 related to White finding
number 2. As a result, the quantitative and qualitative criteria were not adequate for this
subgroup of workers This weakness will inform future NRC periodic assessments of the
licensees problem identification and resolution program.
Minor Weakness - Implementation of changes to PPM 11.2.4.6, Bioassay Sampling and
Analysis, reduced level of detail in instructions to workers. RC2 concluded that certain
procedures relevant to completing bioassays required specialized experience and
professional judgement. CAPR 2.1 (CAPR for RC2) required revision of the procedures. The
inspectors determined that the revision for PPM 11.2.4.6 increased the level of specialized
experience and professional judgement by removing the instructions to conduct in vitro
sampling to support trending being useful in dose assessment.
Root Cause 2: Procedure for bioassay was not adequate in that they were not easy to
follow, requiring personnel with specialized experience to implement, and requiring
exercising professional judgement to successfully determine the correct course of
action.
a. Completed Corrective Actions to Prevent Recurrence
(1) CAPR1.1 (456014-03) - Establish initial and periodic evaluated DLAs, for EN and
Contractor RP Technicians, RP Supervisors, and case studies/tabletop for ALARA
Planners and Support Staff to include:
- Fundamental Radiation Safety Standards
- Positive RP command and control of radiological work activities
- Prudent over simply allowable approach to decisions related to control of
radiological jobs.
(2) CAPR 2.1 (456014-05) - Revise PPMs 11.2.4.5, Whole Body Counting and Daily
Checks Using the Renaissance Fastscan, and 11.2.4.6, Bioassay Sampling and Analysis,
to reduce the level of professional judgment and more systematically assess and document
dose based on quantities of radionuclides in the body. Specifically -
- Close the specific gaps in occupational dose assessment that resulted in the May 28,
2021, dose assessment problems and May 17, 2023, dose assessment problems.
- Results of documented benchmarking of other stations with robust dose assessment
processes identifying gaps and recommendations for CGS process controls, with a focus
on regulatory and technical specification requirements, and ease of use to ensure
consistent performance.
- Incorporation of the results of a review of the benchmarking identified gaps and
recommendations into the procedure(s) based on the recommendations with the highest
value in preventing same or similar occupational dose assessment problems.
- The process should include a flow chart and documentation tool defining the specific
steps and decisions to be made in dose assessments with reference to standards for the
documentation of the basis for decisions. The overall goal is to reduce the level of
professional judgement in occupational does assessments.
- This action also includes the updating of related procedures.
Objective: Ensure that pending corrective action plans direct prompt and effective actions to
address and preclude repetition of White performance issues.
Under this objective, the inspectors assessed the appropriateness and timeliness of the
licensee's planned corrective actions.
NRC Assessment: The team concluded that this objective was Met. The pending corrective
actions are limited to those actions that were identified as a result of the on-site inspection.
All have due dates to indicate the actions should be completed before the inspection report
is published. However, most of the actions have not been inspected.
The White Finding Related to Use of Radiation Protection Engineering Controls, Radiation
Work Permits, and Surveys
a. Planned Corrective Actions to Prevent Recurrence
All corrective actions to prevent recurrence have been completed for this White
performance issue.
b. Other Planned Corrective Actions
1.
(456014-33 was completed on December 10, 2024, after the inspection was
suspended, and should be considered for follow up as a baseline Problem
Identification and Resolution sample) Update PPM 1.3.76, Integrated Risk
Management, with the following:
a.
Define risk mitigation and risk elimination actions.
b.
Determine initial risk assuming no elimination or mitigation actions.
c.
Only allow the risk categorization to credit the elimination of risk.
2. (456014-33 was completed on December 10, 2024, after the inspection was
suspended, and should be considered for follow up as a baseline Problem
Identification and Resolution sample) Update PPM 1.3.76, Integrated Risk
Management, to add an ALARA Risk Assessment Worksheet to provide the station
more visibility of ALARA elevated and high-risk work.
Compromised Ability to Assess Dose
a. Planned Corrective Actions to Prevent Recurrence
All corrective actions to prevent recurrence have been completed for this White
performance issue.
b. Other Planned Corrective Actions
1.
Plant Procedure PPM 11.2.4.6, Bioassay Sampling and Analysis, major revision
007, step 5.2.4 provides guidance for sampling following an acute intake (greater
than or equal to 50 mrem CEDE). Guidance should include Action Level I criteria
provided for Alpha Level II and III as recommended in Table 1 of Attachment 8.1
(461260-01 was completed on October 10, 2024, after the inspection was
suspended, and should be considered for follow up as a baseline Problem
Identification and Resolution sample).
2.
PPM 11.2.4.6, Bioassay Sampling and Analysis, major revision 007, does not
provide specific guidance for how long urinalysis sampling should be performed
following an intake. Guidance like that provided in PPM 11.2.4.6, major revision 003,
to "Continue excreta sampling collection until elimination rates are well established"
should be added to the procedure. (461293-01 was completed on October 10, 2024,
after the inspection was suspended, and should be considered for follow up as a
baseline Problem Identification and Resolution sample)
3.
Perform Isotopic Characterization of RWCU filters in the skid from the 2021 RWCU
heat exchanger replacement project. Evaluate the internal dose assessments
associated with AR 420829420829and perform revisions if required (461257-01 was
completed on November 14, 2024. Internal dose assessments with bounding
conditions were finalized on February 13, 2025.)
a.
This was inspected to resolve the significant weakness identified in Objective
3. The licensee determined the information did not represent the
contamination present during the May 28, 2021, uptake event.
Conclusion
Overall, the inspectors determined that the licensee's problem identification, casual analysis,
and corrective actions sufficiently addressed the notices of violation that led to the two White
findings. The final revision of the RCE documented in condition report AR 456014456014 dated
October 7, 2024, and the calculations for internal dose assessment revised in January 2025,
and finalized with bounding conditions on February 13, 2025, contain sufficient information
such that all inspection objectives, as described in NRC Inspection Procedure 95001, were
met. The NRC determined that completed or planned corrective actions were sufficient to
address the performance issue that led to the two White findings. Therefore, the
performance issue will be closed and no longer considered as an Action Matrix input as of
the date of the exit meeting. Based on the results of this inspection and our Action Matrix
assessment, the NRC has determined that Columbia Generating Station will be in the
Licensee Response Column of the Action Matrix, effective with the published date of the
final supplemental inspection report.
INSPECTION RESULTS
No findings were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors confirmed that proprietary information was controlled to protect from public
disclosure.
On August 22, 2024, the inspectors presented a technical debrief of the supplemental
inspection status to W.G. Hettel, Chief Nuclear Officer, and other members of the
licensee staff.
On February 25, 2025, the branch chief held the regulatory performance meeting with
W.G. Hettel, Chief Nuclear Officer, and other members of the licensee staff.
On February 25, 2025, the inspectors presented the supplemental inspection results to
W.G. Hettel, Chief Nuclear Officer, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculation No
24-01
Alpha Internal Dose
Assessment Methodology -
Response to White Finding II
Related to Assessment of
Internal Dose from 2021
Reactor Water Clean Up Intake
Event
Calculation No
24-01
Alpha Internal Dose
Assessment Methodology -
Response to White Finding II
Related to Assessment of
Internal Dose from 2021
Reactor Water Clean Up Intake
Event
Calculation No
24-01
Alpha Internal Dose
Assessment Methodology -
Response to White Finding II
Related to Assessment of
Internal Dose from 2021
Reactor Water Clean Up Intake
Event
Technical
Support
Document No.25-006
Energy NW Bounding Internal
Dose Calculation for the
5/28/2021 Radioactive Material
Intake Event
Calculations
Technical
Support
Document No.25-006
Energy NW Bounding Internal
Dose Calculation for the
5/28/2021 Radioactive Material
Intake Event
456014
NRC Radiological Controls and
Project in R25
06/20/2024
456014
Revised - NRC Radiological
Controls and Uptakes during
10/07/2024
Corrective
Action
Documents
458068
Ambiguous guidance in PPM
11.2.4.6 regarding calculation
reference
10/26/2024
461257
Obtain physical sample from
the filter media used for the
Reactor Water Clean Up Heat
Exchanger to characterize the
radiological source term
08/20/2024
95001
Corrective
Action
Documents
Resulting from
Inspection
461260
2024 RWCU 95001 (NRC)' -
PPM 11.2.4.6 step 5.2.4
excludes some sampling types
10/26/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
461293
2024 RWCU 95001 (NRC) -
PPM 11.2.4.6, Provide
guidance for urinalysis duration
10/31/2024
461295
2024 RWCU 95001 (NRC)' -
Evaluate PPM 11.2.4.6 step
5.1.2
09/12/2024
461387
(NRC) 2024 RWCU 95001
inspection General Weakness
11/21/2024
Internal Dose Assessment
Methodology in response to
NRC White Finding - Failure to
make suitable and timely
measurements required to
assess internal dose.
Energy Northwest - Columbia
Generating Station RWCU
Smear Comparison - GEL Lab
and WMG Reports from 2021
and 2024
Chem Sample
- 21-1241
Bead Resin Sample Analysis
from RWCU Chemical Decon
06/09/2021
Employee ID
C8515V
Energy Northwest Bioassay
Worksheet
12/28/2023
Form 27025
Bioassay Request Form
08/21/2024
Form 27295
Contaminated Individual
Release Form
08/20/2024
Form 27297
Bioassay Worksheet
08/21/2024
HP002238
Tabletop evaluator guidance -
radiological support tabletop
evaluator
08/22/2024
Mock
Inspection
Table
Columbia - RCE 456014 R0-
001, NRC Radiological
Controls and Uptakes during
Date of Issue: 04-18-2024
05/29/2024
Lesson Plan
PQD Code
HP002242
RP Support Staff Scenario 3
Qual Code
HP002242
RP Support Staff Scenario 3 -
Training Attendance Record
11/20/2024
Sample ID 24-
2112
RCU Decon Filter Smear #4
Sample Report
10/10/2024
GEL Laboratories Analysis
10/22/2024
Miscellaneous
Work Order:
546212
GEL Laboratories Analysis
06/18/2021
Procedures
11.2.4.6
Bioassay Sampling and
Analysis
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
11.2.4.6
Bioassay Sampling and
Analysis
HPI-0.41
Expectations for Radiological
Job Coverage
HPI-0.41
Expectations for Radiological
Job Coverage
HPI-12.42
Use of the MSA Lapel Air
Sampler
HPI-12.52
Managing Large Scale
Contamination Events
HPI-12.90
Contamination Control
Containment Devices
HPI-12.90
Contamination Control
Containment Devices
HPI-12.90
Contamination Control
Containment Devices
HPI-5.9
Evaluation of In-Vivo Bioassay
Results Following a Potential
Intake
11.2.13.1
Radiation and Contamination
Surveys
11.2.2.11
Exposure Evaluations for
11.2.2.12
Radiological Risk Assessment
and Management
11.2.2.12
Radiological Risk Assessment
and Management
11.2.2.12
Radiological Risk Assessment
and Management
11.2.2.14
Radiological Planning and
Reviews
11.2.2.14
Radiological Planning and
Reviews
11.2.2.14
Radiological Planning and
Reviews
PPM 11.2.4.5
Whole Body Counts and Daily
Checks Using the Renaissance
Fastscan
PPM 11.2.8.2
Radiation Work Permit
Preparation and Use
Radiation
Surveys
Survey
VSDS_Prod-
M-20241010-2
RX 548 RWCU CHEM DECON
Title: FILTER HOUSING
10/16/2024