ML17289A336
| ML17289A336 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/13/2017 |
| From: | Kennedy K NRC Region 4 |
| To: | Reddemann M Energy Northwest |
| References | |
| EA-17-085 IR 2016009 | |
| Download: ML17289A336 (6) | |
See also: IR 05000397/2016009
Text
October 13, 2017
Mr. Mark E. Reddemann
Chief Executive Officer
Energy Northwest
P.O. Box 968 (Mail Drop 1023)
Richland, WA 99352-0968
SUBJECT:
COLUMBIA GENERATING STATION - WITHDRAWAL OF NON-CITED
VIOLATION IN NRC INSPECTION REPORT 05000397/2016009
Dear Mr. Reddemann:
On April 10, 2017, the U.S. Nuclear Regulatory Commission (NRC) issued Inspection
Report 05000397/2016009 (Agencywide Document Access and Management System (ADAMS)
Accession ML17100A499). In the inspection report, the NRC documented a preliminary White
finding, a Green finding, and several non-cited violations (NCVs). 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.
On May 9, 2017, Energy Northwest provided a response (ADAMS Accession ML17129A627)
that contested the Green finding and three of the NCVs documented in the April 10, 2017,
inspection report. In a letter dated May 22, 2017 (ADAMS Accession ML17142A219), the NRC
acknowledged receipt of the Energy Northwest letter and informed you that we would review the
basis for contesting the NCVs and finding, and provide the results of our evaluation by written
response.
In a letter dated July 31, 2017 (ADAMS Accession ML17212A914), the NRC documented that
two of the three contested NCVs and the contested Green finding were upheld. In the same
letter, the NRC indicated that the resolution of contested NCV 05000397/2016009-06, related to
the failure to update the Final Safety Analysis Report with changes to radioactive waste
processing and associated with Title 10 of the Code of Federal Regulations (10 CFR) 50.71(e),
was being held in abeyance pending further review.
During the week of September 11, 2017, the NRC conducted a detailed onsite review of the
May 9, 2017, response letter, the licensees radioactive waste processing system including
procedures and FSAR system description, and the regulatory requirements associated with
10 CFR 50.71(e). The review was conducted in accordance with Part I, Section 2.2.7, of the
NRC Enforcement Manual by NRC staff who were not involved with the original inspection effort.
After careful consideration of the bases for your contention, the NRC has concluded that the
NCV associated with 10 CFR 50.71(e) will be withdrawn. The details are documented in the
enclosure.
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 E. LAMAR BLVD.
ARLINGTON, TX 76011-4511
M. Reddemann
2
If you have any questions about this matter, please contact Heather Gepford, Chief, Plant Support
Branch 2, at 817-200-1156.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice and Procedure, a copy of
this letter and its enclosure will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs ADAMS, accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html.
Sincerely,
/RA/
Kriss M. Kennedy
Regional Administrator
Docket No. 50-397
License No. NPF-21
Enclosure:
NRC Evaluation of Contested
Non-Cited Violation
cc w/encl. Columbia dist.
M. Reddemann
3
COLUMBIA GENERATING STATION - WITHDRAWAL OF NON-CITED VIOLATION IN NRC
INSPECTION REPORT 05000397/2016009 DATED OCTOBER 13, 2017
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KKennedy, RA
BMaier, ORA
PHolahan, OE
SMorris, DRA
MHay, ORA
FPeduzzi, OE
AVegel, DRS
JKramer, ORA
DFurst, OE
JClark, DRS
CAlldredge, ORA
RCarpenter, OE
TPruett, DRP
KFuller, ORA
GGulla, OE
RLantz, DRP
JWeaver, ORA
GFigueroa, OE
MHaire, DRP
VDricks, ORA
NHilton, OE
GKolcum, DRP
HGepford, DRS
LCasey, NRR
LBrandt, DRP
R4_DRS_AA;
RArrighi, OE
MHerrera, DRMA
JWeil, CA
JPeralta, OE
TClark, OEDO
AMoreno, CA
RFretz, OE
JMartin, OGC
S:\\RAS\\ACES\\ENFORCEMENT\\_EA CASES - OPEN\\CGS_EA-17-085_Disputed _Vio\\DISPUTED_EA-17-
085_CGS_FSAR violation.docx
ADAMS ACCESSION NUMBER: ML17289A336
SUNSI Review:
ADAMS:
Non-Publicly Available Non-Sensitive
Keyword:
By: CCA
Yes No
Publicly Available
Sensitive
OFFICE
ES:ACES
TL:ACES
SHP:RGN-1
C:PSB2
RC
D:DRS
NAME
CCAldredge
MCHay
JTFuria
HJGepford
KSFuller
AVegel
SIGNATURE
/RA/
/RA/
/RA/E
/RA/
/RA/
/RA/
DATE
9/28/17
10/2/17
9/29/17
9/29/17
10/3/17
10/3/17
OFFICE
NAME
KMKennedy
SIGNATURE
/RA/
DATE
10/13/17
OFFICAL RECORD COPY
Enclosure
NRC Evaluation of Contested Non-Cited Violation
Summary Statement of Non-Cited Violation (NCV)05000397/2016009-06
The team identified a Severity Level IV non-cited violation of 10 CFR 50.71(e) for the failure of
the licensee to periodically provide the NRC a Final Safety Analysis Report (FSAR) update with
all changes made to the facility or procedures. Specifically, the licensee changed its radwaste
management strategy for the spent fuel pool (SFP) cooling and cleanup system and material
being stored in the SFP. However, the licensee had not changed its process control program or
updated the FSAR to reflect the impact on waste streams from processing items stored in the
SFP including activated metals, Tri-Nuclear (Tri-Nuke) filters, filter socks, and demineralizer
filter resins.
Summary of Energy Northwests Response
The licensee stated that it did not consider the SFP filter demineralizer waste stream a major
system producing waste, and that the FSAR adequately describes the current radioactive waste
practices of backwashing waste streams, such as from SFP filter demineralizers, floor drains,
and waste collector filter demineralizers. This process is also adequately described in plant
procedures. The licensee noted that the SFP filter demineralizer waste stream is not included
as an individual waste stream because, as stated in the FSAR, Section 11.4.2.4, this waste
stream is backwashed to the waste sludge phase separator tank together with other waste
streams. The licensee does not consider the SFP filter demineralizer waste stream a major
system producing waste, therefore it is not listed in the FSAR. The licensee contended that,
since it is not considered a major system producing waste, describing the SFP filter
demineralizer waste stream in the detail described in the NCV is beyond that which is required
to be in the FSAR.
The licensee stated that the FSAR adequately describes the current radioactive waste practices
of backwashing waste streams, such as from SFP filter demineralizers, floor drains, and waste
collector filter demineralizers. This process is also adequately described in plant procedures.
Therefore, it is the licensees position that the FSAR adequately reflects current processes.
Regarding the issue that the FSAR does not specifically mention Tri-Nuke or sock filters in the
dry active waste or dry solid waste system, the licensee contended that the FSAR
Section 11.4.2.7 description of dry active waste consisting of other similar materials is
inclusive of the Tri-Nuke and sock filters. Tri-Nuke filters are underwater filters and are similar
in design to air filtration media, which is specifically listed in FSAR Section 11.4.2.7.
The licensee noted that Nuclear Energy Institute 98-03, Guidelines for Updating Final Safety
Analysis Reports, Revision 1, June 1999, discusses simplifying the FSAR to improve focus,
clarity, and maintainability. Specifically, by not specifying brands of filters used in the SFP, the
FSAR maintains required detail for a description of the types of items used yet allows for brand
changes without a requirement to update the FSAR.
Licensee Conclusion
The licensee concluded that the failure to include the SFP system filter demineralizers as an
individual waste stream or to specify underwater filters as a type of dry active waste did not
impact safety or licensed activities. In addition, the licensee concluded that the lack of detail in
2
the FSAR is not required nor does it have an impact on how the licensee safely handles and
disposes of the radiological material or the radiological safety of the plant workers or the public.
NRC Evaluation of the Licensee Response:
The circumstances surrounding the proposed violation of 10 CFR 50.71(e) were reviewed and
are summarized as follows. Two main concerns were identified by the NCV:
(1)
The FSAR does not adequately describe the waste path from the SFP filter
demineralizers
(2)
The FSAR does not adequately describe the Tri-Nuclear underwater filtration
system, or its waste handling
Final Safety Analysis Report, Section 11.4.2.4, states that backwash resin wastes from the SFP
filter demineralizers, floor drain, and waste collector filter demineralizers are backwashed to the
waste sludge phase separator tank (FDR-TK-22). After each backwash batch is received by the
separator, it is allowed to settle for a period of time and the decantate is then transferred by
pumping to the floor drain collector tank.
Final Safety Analysis Report, Section 11.4.3.4, states that the wet wastes are characterized in
individual waste streams for reactor water cleanup resins, equipment drain radioactive (EDR)
and floor drain radioactive (FDR) powdered resins, EDR and FDR bead resins, and condensate
resins. The description of the floor drain system states that wastes from the turbine building,
reactor building, and radwaste building floor drain sumps are routinely monitored and collected
for processing in the floor drain collector tank. The floor drain filter and demineralizer sludges
are combined with equipment drain filters and sludges to form a mixture, which is sampled prior
to processing.
Procedure SWP-RMP-02 Radioactive Waste Process Control Program, Section 2.1.3, states
that resins from the EDR may be combined with SFP cooling and clean-up resins in
tank FDR-TK-22. Section 2.1.4 states that the FDR resins are also pumped to tank FDR-TK-22.
Tank FDR-TK-22 is the waste sludge phase separator tank, which is referenced in the FSAR,
Section 11.4.2.4.
When the FSAR sections above are read independently, it is difficult to discern the system
configuration. However, when read together, they describe a consistent flow path. Resins from
the SFP filter demineralizers, EDR system, and FDR system are all backwashed to the waste
sludge phase separator tank, also called tank FDR-TK-22. After a period of time, the sludge
and the water separate, and the water is sent to the floor drain collector tank. Tank FDR-TK-22
is sampled and characterization is based on the sample results. The FSAR could be enhanced
to allow easier understanding of how SFP filter demineralizer wastes are handled. Use of the
term individual waste streams in the FSAR, when several are blended streams, is also
confusing. However, this issue does not meet the threshold for a regulatory issue.
The second aspect of the NCV was that the team determined that there was not a formal
evaluation on whether the SFP filter demineralizer should be considered its own major waste
stream and the fact that waste stream characterizations had not been performed for SFP filter
media since at least 2011.
Whether the SFP demineralizers is a major or minor waste producing system, accurate
sampling prior to processing is critical to waste characterization. The onsite review determined
3
that wastes from the SFP demineralizer are sampled after blending with the EDR and FDR
resins, and prior to processing, via tank FDR-TK-22. This blended waste stream is sampled on
a biennial basis, in accordance with the Low-Level Waste Licensing Branch Technical Position
on Radioactive Waste Classification, dated May 11, 1983. Further, a review of the past 10
years of samples from this waste stream showed a consistent ratio of cobalt-60 to strontium-90,
nickel-63, iron-55 and plutonium-239, with sample to sample values falling within a factor of ten,
and the performance value provided in Section C of the 1983 Branch Technical Position. Based
upon this information, it was concluded that the licensee is following the guidance provided by
the NRC for this waste stream.
The onsite review also evaluated whether the FSAR adequately described the Tri-Nuclear
underwater filtration system, and the waste handling of Tri-Nuke and other filters, including
characterization.
The licensee contended that the FSAR is not required to specify name brands and that the
FSAR Section 11.4.2.7 description of dry active waste as including other similar materials was
inclusive of the Tri-Nuke and sock filters. The onsite review determined that the FSAR,
Section 11.4.2.7, Miscellaneous Dry Solid Waste System, states that dry active waste may
consist of air filtration media, miscellaneous paper, plastic, and rags from contaminated areas,
contaminated clothing, tools, and equipment parts which cannot be effectively decontaminated,
solid laboratory wastes, and other similar materials. The NRC agreed that it was not the intent
of the FSAR to specify brands of equipment used in the plant.
Licensee personnel indicated that because items typically stay in the SFP for years prior to
shipment, they do not characterize them until they are preparing a shipment. The NRC
determined this approach was acceptable for items stored in the SFP because the items are
characterized before leaving the site. During the onsite review, it was determined that
processing of the spent vacuum filters was previously performed using work orders, but has
subsequently been included in Procedure PPM 11.2.23.45, Management of Spent Fuel Pool
Filters, Irradiated, and Non-Irradiated Items to Support Packaging, Transportation, and Disposal
as Low-Level Waste. The licensee will be referencing this in the next revision of the process
control program (Action Request 370038-02).
Lastly, the onsite review by the NRC determined that the Tri-Nuke underwater vacuum system
was not a plant structure, system,or component as described under 10 CFR 50.34(b). Rather, it
is a vendor supplied temporary system, and as such is not required to be included in the
licensees FSAR. Additionally, with the exception of adding the vendor supplied Tri-Nuke
system, the licensee had not changed their radwaste management strategy for the spent fuel
pool (SFP) cooling and cleanup system since plant start-up. As a result, there would be no
changes dictating a requirement to update in the FSAR.
NRC Staff Conclusion
Based on further inspection of the issue, the NRC concludes that the finding documented in
NRC Inspection Report 05000397/2016009 as NCV 05000397/2016009-06, Failure to Update
the Final Safety Analysis Report with Changes to Radioactive Waste Processing, is withdrawn.