ML17142A219

Disputed Non-Cited Violations and Finding from NRC Inspection Report 05000397/2016009

ML17142A219
Person / Time
Site:	Columbia
Issue date:	05/22/2017
From:	Anton Vegel Division of Reactor Safety IV
To:	Reddemann M Energy Northwest
References
EA-17-085 IR 2016009
Download: ML17142A219 (4)

See also: IR 05000397/2016009

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD

ARLINGTON, TX 76011-4511

May 22, 2017

EA-17-085

Mr. Mark E. Reddemann

Chief Executive Officer

Energy Northwest

MD 1023

P.O. Box 968

Richland, WA 99352

SUBJECT: DISPUTED NON-CITED VIOLATIONS AND FINDING FROM NRC

INSPECTION REPORT 05000397/2016009

Dear Mr. Reddemann:

This letter acknowledges your May 9, 2017, correspondence (ML17129A627) in response to

NRC Inspection Report 05000397/2016009 (ML17100A499), dated April 10, 2017. In the

inspection report, the NRC documented a preliminary White finding, a Green finding, and

several non-cited violations. These findings and violations were identified during a special

inspection of an improperly packaged and manifested radwaste shipment sent by Columbia

Generating Station to US Ecology on November 9, 2016. The inspection report cover letter

requested you to respond in writing within 30 days if you contested any of the non-cited

violations or disagreed with the finding.

On May 9, 2017, the NRC received a letter from you contesting four of the findings in the

inspection report: one Green NRC-identified non-cited violation, one Green self-revealed

non-cited violation, one Green NRC-identified finding, and one SL-IV NRC-identified non-cited

violation. Specifically, Energy Northwest disagreed with the following findings:

(1) A Green NCV of 10 CFR 20.1904 identified in the report for the failure to ensure that

each container of licensed material in the spent fuel pool bore a label or had

documentation providing sufficient information to permit individuals handling the licensed

material to minimize exposure. (NCV 05000397/2016009-03)

(2) An SL-IV NCV of 10 CFR 50.71(e) identified in the report for the failure to periodically

provide the NRC a final safety analysis report update with all changes made in the facility

or procedures. Specifically, the licensee changed its radwaste management strategy for

the spent fuel pool cooling and cleanup system and material being stored in the spent

fuel pool. (NCV 05000397/2016009-06)

M. Reddemann 2

(3) A Green finding identified in the report for the failure to follow the requirements of

Procedure SWP-CAP-06, Condition Report Review, when determining the type of cause

evaluation required to assess the causes of the higher than expected dose rates on a

radwaste container. Specifically, Procedure SWP-CAP-06 required that if an event has

high risk and high uncertainty, the level of evaluation required is a root cause evaluation.

(FIN 05000397/2016009-07)

(4) A Green NCV of 10 CFR 61.56(b)(3) identified in the report for the failure to assure that

void spaces within waste packages were reduced to the extent practicable.

(NCV 05000397/2016009-09)

In addition, your letter requested that we consider combining four of the findings documented in

the report into one violation as discussed in the NRC Enforcement Manual. Specifically, you

requested the following findings be considered for treatment as a problem, as described in

Section 1.3.5 of the Enforcement Manual:

(1) A preliminary White finding and apparent violation of 49 CFR 173.427 identified in the

report for the failure to ensure that the radioactive contents in a radwaste liner did not

exceed the radiation level requirements for shipping. (AV 05000397/2016003-01)

(2) A Green NCV of 10 CFR 20.1501, with three examples, identified in the report for the

failure to conduct adequate surveys of the solid radwaste contents of a shipment that

was packaged and transported for ultimate disposal. (NCV 05000397/2016009-02)

(3) A Green NCV of 10 CFR 20.2006(b) identified in the report for the failure to ship

radwaste with an accurate shipping manifest. (NCV 05000397/2016009-04)

(4) A Green NCV of 10 CFR 30.41(b)(5) identified in the report for the failure to transfer

byproduct material to an authorized waste disposal facility in accordance with the terms

of the facilitys license. (NCV 05000397/2016009-08)

In summary, the NRC is currently reviewing your basis for contesting the three violations and

one finding. Additionally, we are evaluating your request to combine four of the issues into a

problem. In parallel, the NRC is evaluating the information you provided at the May 2, 2017,

Regulatory Conference regarding the preliminary White finding. Accordingly, we will provide the

results of our evaluations by written response.

In accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding,

of the NRCs Rules of Practice, a copy of this letter will be available electronically for public

inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)

M. Reddemann 3

component of the NRC's Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the

Public Electronic Reading Room).

Sincerely,

/RA Jeffrey Clark Acting for/

Anton Vegel, Director

Division of Reactor Safety

Docket No. 50-397

License No. NPF-21

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ML17142A219

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DATE 5/17/17 5/17/17 5/17/17 5/ /17