ML18032A754
| ML18032A754 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/30/2018 |
| From: | Heather Gepford NRC/RGN-IV/DRS/PSB-2 |
| To: | Reddemann M Energy Northwest |
| References | |
| EA-17-028 IR 2017011 | |
| Download: ML18032A754 (19) | |
See also: IR 05000397/2017011
Text
January 30, 2018
Mr. Mark E. Reddemann
Chief Executive Officer
Energy Northwest
P.O. Box 968 (Mail Drop 1023)
Richland, WA 99352-0968
SUBJECT: COLUMBIA GENERATING STATION - NRC SUPPLEMENTAL INSPECTION
REPORT AND ASSESSMENT FOLLOW-UP LETTER; 05000397/2017011
Dear Mr. Reddemann:
On December 1, 2017, the United States Nuclear Regulatory Commission (NRC) completed a
supplemental inspection using NRC Inspection Procedure 95001, Supplemental Inspection
Response to Action Matrix Column 2 Inputs. On December 19, 2017, the NRC inspection team
discussed the results of this inspection with you and other members of your staff. The results of
this inspection are documented in the enclosed report.
The NRC performed this inspection to review your stations actions in response to a White
finding in the Public Radiation Safety cornerstone which was documented in NRC Inspection
Report 05000397/2016009, dated April 10, 2017, (Agencywide Documents Access and
Management System (ADAMS) Accession No. ML17100A499), and finalized in a Notice of
Violation letter to you from Kriss Kennedy, Regional Administrator, dated July 16, 2017
(ADAMS Accession No. ML17187A364). On September 26, 2017, Mr. W. G. Hettel,
Vice President, Operations, informed the NRC that Columbia Generating Station was ready for
the supplemental inspection.
The NRC performed this supplemental inspection to determine if (1) the root and contributing
causes for the significant issues were understood, (2) the extent of condition and extent of
cause for the identified issues were understood, and (3) your completed or planned corrective
actions were sufficient to address and preclude repetition of the root and contributing causes.
The NRC determined that the root, contributing, and apparent cause evaluations were
conducted to a level of detail commensurate with the significance of the problems and, taken as
a whole, reached reasonable conclusions as to the root, contributing, and apparent causes of
the event. The NRC also concluded that you identified reasonable and appropriate corrective
actions for each root, contributing, and apparent cause and that the corrective actions appeared
to be prioritized commensurate with the safety-significance of the issues.
After reviewing Columbia Generating Stations performance in addressing the White finding, the
NRC concluded that your actions met the objectives of Inspection Procedure 95001,
Supplemental Inspection Response to Action Matrix Column 2 Inputs.
M. Reddemann 2
Therefore, in accordance with the guidance in Inspection Manual Chapter 0305, Operating
Reactor Assessment Program, the White finding will only be considered in assessing plant
performance for a total of four quarters. Further, the White finding and associated violation will
be closed effective January 1, 2018.
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 10 CFR 2.390, Public Inspections, Exemptions, Requests for
Withholding.
Sincerely,
/RA/
Heather J. Gepford, Ph.D., CHP
Chief, Plant Support Branch 2
Division of Reactor Safety
Docket No. 50-397
License No. NPF-21
Enclosure:
Inspection Report 05000397/2017011
w/Attachment: Supplemental Information
cc: Electronic Distribution
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: HGepford Yes No Publicly Available Sensitive NRC-002
OFFICE HP:DRS/PSB2 HP:DNMS BC:PBA BC:DRS/PSB2
NAME JODonnell PHernandez MHaire HGepford
SIGNATURE /RA/ /RA/ /RA/ /RA/
DATE 1/29/18 1/29/18 1/29/18 1/30/18
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 05000397
License: NPF-21
Report: 05000397/2017011
Licensee: Energy Northwest
Facility: Columbia Generating Station
Location: North Power Plant Loop
Richland, WA 99354
Dates: November 28 through December 19, 2017
Inspectors: P. Hernandez, Health Physicist
J. ODonnell, CHP, Health Physicist
Approved Heather Gepford, Ph.D., CHP
By: Chief, Plant Support Branch 2
Division of Reactor Safety
Enclosure
SUMMARY
Inspection Report (IR) 05000397/2017011; 11/28/2017 - 12/19/2017; Columbia Generating
Station; Supplemental Inspection - Inspection Procedure 95001
This report covers a one-week announced supplemental inspection of a White finding in the
Public Radiation Safety Cornerstone. The inspection was conducted by two health physics
inspectors from the NRC Region IV office. The NRC's program for overseeing the safe
operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor
Oversight Process.
The NRC staff performed the supplemental inspection in accordance with Inspection
Procedure 95001, Supplemental Inspection Response to Action Matrix Column 2 Inputs,
to assess the licensees evaluation associated with the failure to ensure that the contents of a
radioactive waste container did not exceed the radiation level requirements for shipping. The
NRC staff previously characterized this issue as having low to moderate safety significance
(White), as documented in NRC IR 05000397/2017009.
During this supplemental inspection, the inspectors determined that, taken as a whole, the
licensee performed an adequate evaluation of the causes of the self-revealed failure to comply
with the external radiation limits for shipping radioactive materials, which occurred for a
shipment of radioactive waste to the US Ecology waste disposal facility. The licensee identified
the primary root cause of the issue to be that Columbia Generating Station management did not
have the organizational alignment in place that would ensure proper decision-making, effective
supervisor oversight, and programmatic validation to assure execution of critical radioactive
waste packaging and shipping activities in accordance with regulations. The licensee has taken
corrective actions to address the organizational alignment to ensure proper decision-making,
effective supervisor oversight, and programmatic validation of radwaste packaging and shipping
activities.
Given the licensees acceptable performance in evaluating the cause of a package exceeding
the radiation levels for shipping low specific activity material, the White finding associated with
this issue will only be considered in assessing plant performance for a total of four quarters in
accordance with the guidance in Inspection Manual Chapter 0305, Operating Reactor
Assessment Program. Inspectors will review the licensees implementation of corrective
actions during a future inspection.
No findings were identified.
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REPORT DETAILS
4. OTHER ACTIVITIES
Cornerstone: Public Radiation Safety
4OA4 Supplemental Inspection (95001)
.01 Inspection Scope
The NRC staff performed this supplemental inspection in accordance with Inspection
Procedure 95001, Supplemental Inspection Response to Action Matrix Column 2
Inputs, to assess the licensees evaluation of one White finding in the Public Radiation
Safety Cornerstone. The inspection objectives were to:
- Provide assurance that the root and contributing causes of significant performance
issues were understood.
- Provide assurance that the extent of condition and extent of cause of significant
performance issues were identified.
- Provide assurance that corrective actions taken to address and preclude repetition of
significant performance issues were prompt and effective.
- Provide assurance that corrective plans directed prompt actions to effectively
address and preclude repetition of significant performance issues.
Columbia Generating Station entered the Regulatory Response Column (Column 2)
of the NRCs Action Matrix in the first quarter of 2017 as a result of a White
(low-to-moderate safety significance) finding in the Public Radiation Safety Cornerstone.
The finding was associated with the November 9, 2016, shipment of radioactive material
as low specific activity (LSA) material that exceeded the LSA external dose rate limit of
1.0 rem/hr at 3 meters from the unshielded material. Specifically, the licensee
transported a package as LSA material with an external radiation level of 2.1 rem/hr at a
distance of 3 meters from the unshielded material. The finding was characterized as
having low to moderate safety significance (White) using the NRC Inspection Manual
Chapter 0609, Appendix M, Significance Determination Process Using Qualitative
Criteria. This issue was documented in NRC Inspection Reports 05000397/2016009
and 05000397/2017009.
The licensee staff informed the NRC by letter on September 26, 2017, of their readiness
for the supplemental inspection. In preparation for this inspection, the licensee
performed a root cause evaluation documented in Action Request (AR) 360236,
Radwaste Liner Dose Rate Exceeds 1 rem/hr at 3 meters, to identify weaknesses that
existed in various organizations and processes. The licensee indicated that the final
version, Revision 7, dated November 16, 2017, documented their conclusions.
The inspectors reviewed several revisions of the root cause evaluation, an apparent
cause evaluation (AR 357593), related self-assessments, and supplemental information
that the licensee provided. The inspectors reviewed corrective actions that were taken
or planned to address the identified causes. The inspectors conducted interviews and
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had discussions with licensee personnel to determine if the root cause and contributing
causes of the issue were understood, and that corrective actions taken or planned were
appropriate to address the causes and preclude repetition. The inspectors also
reviewed related issues that had been identified in the past where the corrective actions
were not implemented correctly to understand process failures and assure that the
proposed corrective actions would be effective.
.02 Evaluation of the Inspection Requirements
02.01 Problem Identification
a. Determine that the licensees evaluation documents who identified the issue and the
conditions under which the issue was identified.
The root cause evaluation documented that the failure to transport LSA material with
external dose rates not exceeding an external radiation level of 10 mSv/hr (1 rem/hr) at
3 meters (10 feet) from the unshielded material was self-revealed on November 9, 2016,
as a result of US Ecology, the low-level radwaste disposal facility, validating the
manifested dose rates during package receipt. US Ecology personnel removed the liner
containing the radioactive material from the shipping cask to conduct radiation survey
measurements. US Ecology personnel measured contact dose rates of 30 rem/hr and
90 rem/hr on opposite sides of the liner, in contrast to the documented dose rate of
11.8 rem/hr. The shipment was rejected and returned to Columbia Generating
Station (CGS) the same day. The licensee performed radiation surveys at 3 meters
from the unshielded material on January 13, 2017, and recorded dose rates of up to
2.1 rem/hr.
The inspectors determined that the self-revealed nature, as well as the conditions under
which the issue was identified, were documented in the licensees evaluation.
b. Determine that the evaluation documents how long the issue existed and prior
opportunities for identification.
The problem statement for the root cause evaluation was defined as the licensees
transport of a radioactive waste container that exceeded the external radiation dose rate
limit required by the Department of Transportation. Based on this problem statement,
the licensee concluded that the issue existed only during the time that the shipment was
in transit on public roads from CGS to US Ecology and back to CGS on November 9,
2016. The inspectors concluded that the licensees determination accurately
documented the duration of the violation of regulatory requirements.
The root cause evaluation discussed prior opportunities for the licensee to correct or
prevent the violation. Examples of these include:
- On October 20, 2016, the dose rates measured on the outside of the shipping
cask were significantly higher than the regulatory limits for shipping.
- On November 5, 2016, after removing some items, external dose rates on the
cask were still above the limit to ship as an open transport, so a decision was
made to build a cage around the cask to prevent access to the elevated dose
rates.
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- On November 8, 2016, Radiation Protection was uneasy with the shipment, but
the decision to proceed was based on the high confidence that the shipping
specialist had in the shipment meeting all the requirements.
- On November 8, 2016, the vendor shipping summary calculated dose rate of
11.8 rem/hr for the liner was not validated. The shipment left site on
November 9, 2016, without a direct survey of the liner.
The inspectors determined that the licensee documented how long the issue existed and
prior opportunities to identify it.
c. Determine that the evaluation documents the plant-specific risk consequences, as
applicable, and compliance concerns associated with the issue.
The inspectors determined that this incident had no impact on the core damage
frequency or large early release frequency. Therefore, the documentation of the
plant-specific risk consequences was not applicable.
The causal evaluation discussed how the noncompliance with regulations led to the
White violation (low to moderate safety significance) issued by the NRC for exceeding
the radiation limit for this shipment type and categorized the issue as a significant
condition adverse to quality. In addition to the NRC violation, the licensee received
two violations for noncompliance with the Washington Administrative Code for this
shipment. The immediate consequence of these violations was the suspension of the
licensees permit to dispose low-level radioactive waste at the disposal site operated by
US Ecology. Additional consequences described were increased radiation exposure risk
to the public and decreased NRC and public confidence in the licensees ability to safely
control its radioactive material.
The inspectors concluded that the licensee appropriately documented the risk
consequences and compliance concerns associated with the issue.
d. Findings
No findings were identified.
02.02 Root Cause, Extent of Condition, and Extent of Cause Evaluation
a. Determine that the issue was evaluated using a systematic methodology to identify the
root and contributing causes.
The licensee used the following systematic methods and tools to complete the root
cause analysis AR 360236, Revision 7:
- Event and Causal Factors Chart
- Comparative Timeline
- Human Performance Evaluation Worksheet
- Nuclear Safety Culture Evaluation Worksheet
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Predecessor causal evaluations, as reviewed by inspectors, used a variety of systematic
methodologies to complete their analyses, including some of the above and the following
methods and tools:
- Event Timeline
- Barrier Analysis
- Change Analysis
- WHY Staircase
The inspectors determined that the licensee evaluated the issue using systematic
methodologies to identify root and contributing causes.
b. Determine that the root cause evaluation was conducted to a level of detail
commensurate with the significance of the issue.
The licensees final root cause evaluation included a timeline of events and an event and
causal factor chart. The licensees root cause evaluation documented the root cause of
the issue to be the stations management did not have the organizational alignment in
place to ensure proper decision-making, effective supervisor oversight, and
programmatic validation to assure execution of critical rad waste packaging and shipping
activities in accordance with regulations. The licensee determined the contributing
cause to be that chemistry management did not implement effective corrective actions to
address precursor organizational and programmatic issues within the radwaste shipping
program that were identified by the stations performance improvement and oversight
programs.
The licensee conducted other causal evaluations prior to the final version, Revision 7.
These included an apparent cause evaluation (AR 357593, Radioactive Waste Disposal
Container has Higher Dose Rates than Anticipated, Revision 00, dated December 12,
2016) and a prior version of the root cause evaluation (AR 360236, Incorrect Container
for Radioactive Waste Shipment 16-40, Revision 3a, dated April 17, 2017), both of
which had problem statements that were different from the final version. The inspectors
concluded that the evolution of the problem statement was linked to changes in the
licensees understanding of the issue, beginning with the occurrence of the event and
followed by issuance of the special inspection report with the apparent violation and the
subsequent issuance of the Notice of Violation. The inspectors noted that the revisions
of AR 360236 preceding 3a and 7, respectively, were not substantively different from the
revisions reviewed and discussed.
In addition to these causal evaluations, the licensee conducted self-assessments
focused on the radioactive waste program and the sites readiness for this inspection.
Through these various assessments, causal evaluations, and other corrective action
processes, the licensee identified a number of issues with their radioactive waste
program, as a whole, and several that led to or contributed to the White violation. These
issues included insufficient procedures to implement spent fuel pool cleanup (SFPCU)
activities, flawed waste characterization based on inaccurate survey documentation, and
lack of formal SFP filter management.
6
The licensee found that the circumstances that led to the incident were more complex
than could be addressed by a single, concise statement or single cause evaluation.
The inspectors determined that when these cause evaluations and assessments were
considered as an all-inclusive product, a more complete understanding of the causes
leading to the incident was achieved.
Based on the extensive work performed for this root cause evaluation and associated
with this root cause evaluation, the inspectors concluded that the root cause evaluation
was conducted to a level of detail commensurate with the significance of the problem.
c. Determine that the root cause evaluation included a consideration of prior occurrences
of the issue and knowledge of operating experience.
The final root cause evaluation included a brief review of external operating experience.
The review of operating experience focused on the key words high dose rates,
shipment, and shipping; four events were identified. The licensee determined that these
events were not related to poor organizational alignment, therefore were not applicable.
The inspectors concluded that the licensee had determined the root cause and then
performed the operating experience evaluation, which was contrary to the expectation
that the operating experience inform the root cause determination.
The final root cause evaluation stated that applicable internal operating experience was
included in the analysis and listed in the references section. There was not a discussion
of internal operating experience in the report or attachments, so the inspectors used the
references and operating experience information provided in Revision 3a of AR 360236
which included an evaluation of internal as well as external operating experience.
In Revision 3a of AR 360236, the licensee stated that the review of internal operating
experience identified a range of weaknesses related to radwaste shipping, handling, and
documentation that had been identified in self-assessments and internal audits over the
prior 2-year period. The licensee recognized that corrective actions taken to address
these issues had not been effective, as evidenced by the continued declining
performance culminating in the shipping violation. These radwaste shipping and
handling issues represented missed opportunities for the station to restore the program
to satisfactory performance. The inspectors noted that some of these items included
previous shipments that had been rejected by US Ecology.
The licensee determined that the external operating experience that applied represented
missed opportunities due to the similarity of the CGS event. The operating experience
referenced a resin shipment that was not fully characterized or surveyed prior to
shipment. The review for this operating experience performed by the licensee stated
that Columbia had procedures in place that required every waste stream going into a
liner to be sampled and used in the characterization and that liners to be shipped are
rigorously surveyed prior to shipment. The gap was identified in this situation because
the SFPCU waste was previously surveyed and could not be sampled, the waste
characterization was performed off-site, and it was an infrequent evolution not performed
by or under the oversight of Radiation Protection.
Based on the licensees detailed evaluation and conclusions, the inspectors determined
that the licensees root cause evaluation included consideration of prior occurrences of
the problem and knowledge of operating experience.
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d. Determine that the root cause evaluation addressed the extent of condition and the
extent of cause of the issue.
The licensees evaluation considered the extent of condition associated with an offsite
shipment of LSA radioactive material that exceeded the external radiation and dose rate
limits for a Type A container required by Department of Transportation (DOT)
regulations in 49 CFR 173.427(a)(1). The licensee determined that the underlying issue
was not limited to LSA material. Similar activities that could be vulnerable to the same
defect included waste shipments where transport limits could be exceeded, waste
shipments where other regulations could be challenged, hazardous material shipments,
and other non-waste radioactive material shipments. Therefore, the licensee expanded
the extent of condition to include all radioactive shipments. The licensee determined
that non-radioactive hazardous material shipments should not be included in the extent
of condition because hazardous material was transferred to another party onsite who
was then responsible for its removal. The licensee concluded that the corrective actions
implemented for the violation would effectively address similar shipping errors for all
radioactive material shipments.
The licensees evaluation also considered the extent of cause associated with the
organizational alignment to ensure proper decision-making, effective supervisor
oversight, and programmatic validation. The licensee stated that they looked at each
piece individually and in combination to determine other areas that could result in a
future consequential event. The licensee focused on was areas with organizational
alignment in which a specialized position lacked knowledgeable supervision or faced
other programmatic challenges to their decision-making. The licensee reviewed
departments including Operations, Engineering, Maintenance, Emergency
Preparedness, Quality, and Training. The extent of cause contacted nearly every
department to identify circumstances for the vulnerability. Most either did not have the
vulnerability or had identified it previously and were addressing it. The one department
that had the same potential that had not been addressed was Technical Services
Engineering. This has been entered into the corrective action program.
The inspectors concluded that the licensees root cause evaluation addressed the extent
of condition and the extent of cause of the issue.
e. Determine that the root cause, extent of condition, and extent of cause evaluations
appropriately considered safety culture traits.
The licensee demonstrated the complexity of the issue through their evaluation of the
safety culture traits associated with the event. The safety culture assessment performed
for the final root cause evaluation identified four attributes that contributed to the event.
Those attributes were:
- Leadership Safety Values and Actions attribute of Resources (LA.1): This
related to the failure to select a supervisor with the appropriate skill set to
oversee the radwaste shipping activities.
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- Decision-Making attribute of Conservative Bias (DM.2): This related to the
failures in decision-making to 1) not use a Type B cask, 2) construct a fence
around the shipment, and 3) not survey the liner or cask prior to shipment.
- Personal Accountability attribute of Standards (PA.1): This related to the failures
of 1) management to ensure organizational alignment for radwaste activities,
2) the chemistry supervisor to meet expectations to monitor and enforce
standards of behavior, and 3) the radwaste transportation specialist to be trained,
monitored, or coached to the expected behaviors.
- Problem Identification and Resolution attribute of Resolution (PI.3): This related
to the failure to take effective and timely corrective actions to correct
organizational weaknesses that were identified prior to the event.
The first three safety culture aspects were addressed by the Revision 7 root cause and
corrective action to prevent recurrence actions. The fourth safety culture aspect was
addressed by the contributing cause and its associated corrective actions.
(See Section 02.03a.)
The inspectors determined that the licensees root cause, extent of condition, and extent
of cause evaluations appropriately considered safety culture traits.
f. Findings
No findings were identified.
02.03 Corrective Actions Taken and Planned
a. Determine that appropriate corrective actions are specified for each root and contributing
cause.
In the final version of the root cause evaluation, the licensee identified the following root
cause: Station management did not have the organizational alignment in place that will
ensure proper decision-making, effective supervisor oversight, and programmatic
validation to assure execution of critical radwaste packaging and shipping activities in
accordance with regulations.
As corrective actions, the licensee realigned the Chemistry/Radiation Protection
organization to include oversight positions knowledgeable in radioactive shipments.
Specifically, for both the Radiation Protection Manager and the individual responsible for
oversight of the Radioactive Waste Transportation Specialist, the requirement for
knowledgeable oversight was added to Procedure SWP-RPP-01, Radiation Protection
Program. Position descriptions were modified to include the required knowledge.
Procedural requirements to validate dose rates documented on shipping manifests via
either direct surveys or shielding calculations were added to applicable procedures.
Finally, the lessons learned from this event were added to Manager/Supervisor
SOER 10-2 training.
9
The licensee also identified a contributing cause: Chemistry management did not
implement effective corrective actions to address precursor organizational and
programmatic issues within the radwaste shipping program.
As a corrective action, the licensee updated performance appraisals for
Chemistry/Radiation Protection management and supervision to focus on increasing
proficiency in implementing corrective actions. The licensee will also conduct a
workshop to align Chemistry/Radiation Protection management on how to implement
proper corrective action to address organizational and programmatic issues.
In Revision 3a of the root cause evaluation (AR 360236), the licensee identified the
following root cause: Station procedures to implement SFPCU activities and the
associated radioactive waste surveys, processing, and shipping activities are not
sufficient to ensure compliance with all requirements. The contributing causes were
identified to be: (1) Some key decisions made during the SFPCU project lacked rigorous
challenge and vetting and were not conservative, and (2) Lack of adequate
management/supervisor oversight for SFPCU project and RadWaste processing and
shipping program.
As corrective actions, the licensee inventoried and mapped the remaining Tri Nuclear
filters in the spent fuel pool, conducted a self-assessment of the radwaste shipping and
handling program, began having the Radiation Protection Manager review all radwaste
shipments to validate the surveys and characterization, and developed a procedure for
spent fuel pool clean-up activities integrated with radwaste shipping and handling
In the apparent cause evaluation (AR 357593), the licensee identified the following
apparent cause: Survey documentation was inaccurately recorded and communicated
to the characterization vendor which led to errors in the calculated dose rates on the
characterization used to ship the radioactive waste disposal container. The contributing
causes were identified to be: (1) A formalized process and plan specific to Tri Nuclear
filter management, tracking, and disposal was not developed, (2) Radiological conditions
on the disposal container were not verified and validated prior to shipment, and
(3) Characterization results provided by the vendor based on CGS data were not verified
or validated.
As corrective actions following the event and apparent cause evaluation, the licensee
suspended radwaste shipping activities, conducted an event investigation, benchmarked
another station on Tri Nuclear filter handling and tracking in the spent fuel pool, created
a new procedure for spent fuel pool clean-up container loading, revised the procedure
for processing of irradiated nonfuel material to include Tri Nuclear filters, labeled filter
cans in the spent fuel pool, and evaluated performance gaps for culpability.
The inspectors questioned whether the apparent, root, and contributing causes identified
in the various revisions of the cause evaluations were going to continue to be addressed
and corrected. The licensee stated that all issues identified in this process would be
corrected and that the corrective actions for each of the cause evaluations were being
tracked to completion.
The inspectors determined that the corrective actions were appropriate and addressed
the root and contributing causes identified in each of the licensees causal evaluations.
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b. Determine that corrective actions have been prioritized with consideration of risk
significance and regulatory compliance.
The licensee categorized AR 360236 as a Severity Level A (high risk) action request,
which requires a root cause evaluation. In accordance with Procedure SWP-CAP-01,
Corrective Action Program, Revision 37, the AR received a significant condition
adverse to quality (SCAQ) priority. This priority requires the issue to be addressed by a
higher level of corrective actions (i.e., corrective actions to preclude repetition known as
CAPRs). The procedure stated that CAPRs should be completed within 180 days.
The inspectors determined that the corrective actions were prioritized with the
appropriate consideration of significance and regulatory compliance.
c. Determine that corrective actions taken to address and preclude repetition of significant
performance issues are prompt and effective.
The licensee promptly initiated corrective actions as issues were identified throughout
the performance of the cause evaluations. The licensee also initiated corrective actions
that were identified in the apparent cause evaluation and early root cause evaluation
revisions prior to completing the final evaluation and as they identified related issues
throughout the process.
The inspectors determined that the corrective actions taken to address and preclude
repetition of the performance issues were prompt and should be effective.
d. Determine that a corrective action plan and schedule has been established for
implementing and completing the corrective actions.
The inspectors discussed the corrective action plan with the licensee. Some of the due
dates were captured in the final root cause evaluation revision; however, many of the
due dates for corrective actions not directly mentioned in the evaluation were spread
across other performance improvement tools. Specifically, the licensee used a
performance improvement database to track corrective actions. The many facets of the
causal evaluation, including previous revisions, assessments, work orders, and actions,
are being tracked with the AR 360236 identifier with cross-references to other
associated action requests. The licensees database tracks all the associated actions,
due dates, responsible parties, and effectiveness reviews to be performed.
The inspectors determined that a schedule had been established for implementing and
completing the corrective actions.
e. Determine that quantitative or qualitative measures of success have been developed for
determining the effectiveness of the corrective actions to preclude repetition.
As documented in the final root cause evaluation, the licensee established measures for
determining the effectiveness of the corrective actions. These measures included the
following:
- The trained and knowledgeable Radiation Protection Manager will review
shipment manifests and paperwork to identify deficiencies. Success is defined
as the documents containing less than 5 percent deficiencies.
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- A self-assessment of the radwaste shipping and handling program corrective
actions will be performed after an acceptable implementation period with a due
date of April 30, 2018. Areas of focus include compliance with burial site
requirements (i.e., no loss of burial site privileges) and zero regulatory
noncompliance issues related to radwaste shipments.
The effectiveness reviews have been added into the corrective action program as
corrective action items to ensure they are performed.
The inspectors determined that quantitative and qualitative measures of success had
been developed for determining the effectiveness of the corrective actions to preclude
repetition.
f. Determine that the corrective actions planned or taken adequately address a Notice of
Violation (NOV) that was the basis for the supplemental inspection.
During this inspection, the inspectors determined that the corrective actions taken and
planned to correct the identified causes adequately addressed the NOV.
g. Findings
No findings were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On December 1, 2017, the inspectors conducted a technical debrief for Mr. M. Reddemann,
Chief Executive Officer, and other members of the licensee staff. The licensee confirmed that
any proprietary information reviewed by the inspectors had been returned or destroyed.
On December 19, 2017, the inspectors presented the inspection results to Mr. M. Reddemann,
Chief Executive Officer, and other members of the licensee staff. The licensee acknowledged
the issues presented.
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SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
S. Brush, Health Physics Planner, Chemistry/Radiation Protection
M. Davis, Manager, Chemistry/Radiation Protection
K. Gillard, Analyst, Chemistry/Radiation Protection
D. Gregoire, Manager, Regulatory Affairs
T. Hedges, Chemistry/Radiation Support Supervisor, Chemistry/Radiation Protection
G. Hettel, Vice President, Operations
J. Houston, Radwaste Transportation Specialist, Chemistry/Radiation Protection
T. McNabb, Health Physics Planner, Chemistry/Radiation Protection
S. Nappi, Assistant to the Vice President, Operations
M. Nolan, Senior Radwaste Transportation Specialist, Chemistry/Radiation Protection
T. Parmalee, Compliance Engineer, Licensing and Regulatory Affairs
M. Reddeman, Chief Executive Officer
R. Sanker, Radiological Support Supervisor, Chemistry/Radiation Protection
M. Shobe, Chemistry Specialist IV, Chemistry/Radiation Protection
J. C. Smith, Radiological Operations Supervisor, Chemistry/Radiation Protection
C. Smoot, Supervisor, Human Performance/Industrial Safety
D. Wolfgramm, Supervisor, Regulatory Compliance
NRC Personnel
G. Kolcum, Senior Resident Inspector
L. Brandt, Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Closed
05000397/2016009-01 VIO Shipment of a Type B Quantity of Radioactive Material in a
Type A Package (Section 4OA4)
Attachment
LIST OF DOCUMENTS REVIEWED
Section 4OA4: Supplemental Inspection (95001)
Procedures
Number Title Revisions
SWP-RMP-01 Radioactive Waste Management Program 4
PPM 1.11.15 Control of Radioactive Material 11, 12, 13
PPM 6.1.1 Spent Fuel Pool Inventory 9, 10
PPM 11.2.2.12 Radiological Risk Assessment and Management 8
PPM 11.2.13.1 Radiation and Contamination Surveys 36, 37
PPM 11.2.23.1 Shipping Radioactive Materials and Waste 18, 19
PPM 11.2.23.1 Shipping Radioactive Materials and Waste 19
PPM 11.2.23.2 Computerized Radioactive Waste and Material 20, 21
Characterization
PPM 11.2.23.9 Packaging, Transportation and Disposal of 0, 1
Radioactive Waste at the US Ecology, Richland
Radioactive Waste Disposal Facility
PPM 11.2.23.45 Management of Spent Fuel Pool Filters, Irradiated, 0
and Non-Irradiated Items to Support Packaging,
Transportation, and Disposal as Low-Level
Radwaste
CDM-01 Cause Determination Manual 16
SWP-CAP-01 Corrective Action Program 36, 37
GBP-HR-48 Knowledge Retention 0
Audits and Self-Assessments
Number Title Date
361427 Peer Self-Assessment Report February 2, 2017
Radioactive Waste Program
AU-RP-RW-15 Quality Services Audit Report - Radiation November 5, 2015
Protection and Process Controls Program
AR-SA 305111 Focused Self-Assessment Report - Radioactive June 19, 2015
Solid Waste Processing, Radioactive Material
Handling, Storage, and Transportation
AR-SA 337267 Snapshot Self-Assessment Report - Radioactive June 28, 2017
Waste Management and Transportation
A-2
Audits and Self-Assessments
Number Title Date
AR-SA 369058 Focused Self-Assessment Report - Rad-waste September 11, 2017
Shipping 95001 Preparatory Assessment
AR-SA 361427 Peer Self-Assessment Report - Radioactive Waste February 2, 2017
Program
SR-17-12 Radwaste Program Assessment Report April 27, 2017
SR-17-09 Radwaste Processing and Shipping August 23, 2017
Root Cause Evaluations
AR Number Title Revision
Date
360326 RadWaste Liner dose rate exceeds 1 Rem/hr at Rev. 7
3 meters November 16, 2017
360326 RadWaste Liner dose rate exceeds 1 Rem/hr at Rev. 6
3 meters October 30, 2017
360326 Incorrect Container for Radioactive Shipment 16-40 Rev. 3a
April 26, 2017
Apparent Cause Evaluations
AR Number Title Revision
Date
353427 Trend: Radioactive Waste Packing/Shipping Issues Rev. 1
October 20, 2016
352217 RW Box Sent to Disposal Site with Greater than September 12, 2016
15% Voids
357593 Radioactive Waste Disposal Container has Higher December 12, 2016
Dose Rates than Anticipated
369215 Liner 17-084-OT Shipped for Disposal with Incorrect August 29, 2017
Manifest
Action Requests (AR)
338421 352217 357593 360148
360572 369215 370193 371583
Work Orders (WOs)
Number Title Date
02070690 Spent Fuel Pool Clean Up Project Plan February 15, 2016
A-3
Work Orders (WOs)
Number Title Date
02104894 Move SFPCU Liner from Reactor Building Truck December 29, 2016
Bay to Radwaste
02070690 Perform Spent Fuel Pool Cleanup in FY16 February 9, 2016
02095196 Perform Spent Fuel Pool Cleanup in FY17 September 28, 2016
Miscellaneous Documents
Number Title Date
RCE 360326 Roadmap November 30, 2017
Chemistry/Radiation Protection Organization Chart November 28, 2017
WAC 246-249-090 Transfer for Disposal and Manifests November 9, 2017
Excellence Model Handbook 2016
A-4