ML19108A487
| ML19108A487 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/16/2019 |
| From: | Scott(Ois) Morris Division of Nuclear Materials Safety IV |
| To: | Sawatzke B Energy Northwest |
| Gepford H | |
| References | |
| EA-18-173 IR 2018003 | |
| Download: ML19108A487 (6) | |
See also: IR 05000397/2018003
Text
April 16, 2019
Mr. Brad Sawatzke, Chief Executive Officer
Energy Northwest
MD 1023
P.O. Box 968
Richland, WA 99352
SUBJECT: COLUMBIA GENERATING STATION - NRC INSPECTION REPORT
05000397/2018003 NRC RESPONSE TO DISPUTED NON-CITED VIOLATION
Dear Mr. Sawatzke:
On October 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) issued the subject
inspection report and non-cited violation (NCV) (Agencywide Documents Access and
Management System (ADAMS) Accession No. ML18304A362).
On November 29, 2018, you provided a response (ADAMS Accession No. ML18333A389), in
which you contested the NCV 05000397/2018003-02 Failure to Control Workers in a High
Radiation Area (>1.0 rem per hour), that is described in the subject inspection report. On
December 27, 2018, the NRC acknowledged receipt of your response (ADAMS Accession
No. ML18361A865) and informed you that we would evaluate your response and provide you
the results of our evaluation.
We conducted a detailed review of your response and the applicable regulatory requirements, in
accordance with Part I, Section 2.2.7, of the NRC Enforcement Manual. The NRC staff who
performed the review were not involved with the original inspection effort. After careful
consideration of the basis for your contention, the NRC has concluded that the inspection report
correctly characterizes the performance deficiency. As such, the NRC is upholding the NCV.
The NRCs evaluation of your response to the NCV is contained in the enclosure to this letter.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public
B. Sawatzke 2
inspections, exemptions, requests for withholding," a copy of this letter and its enclosure will be
made available electronically for public inspection in the NRC's ADAMS, accessible from the
NRC Web site at https://www.nrc.gov/reading-rm/adams.html.
Sincerely,
/RA/
Scott A. Morris
Regional Administrator
Docket No. 50-397
License No. NPF-21
Enclosure:
NRC Evaluation of Licensee Response to
Non-Cited Violation
NRC EVALUATION OF LICENSEE RESPONSE TO NON-CITED VIOLATION
1. Green NCV 05000397/2018003-02
Restatement of the Non-Cited Violation (NCV)
Technical Specification (TS) 5.7.2, High Radiation Areas with Dose Rates Greater than 1.0 rem
per hour (at 30 cm from the radiation source), paragraph (b) requires, in part, that activities
shall be controlled by means of a radiation work permit (RWP) that includes specification of
appropriate radiation protection measures, and paragraph (e) requires, in part, that entry shall
be made only after dose rates in the area have been determined and entry personnel are
knowledgeable of them.
Contrary to the above, on June 20, 2017, during work in a high radiation area with dose rates
greater than 1.0 rem per hour, the licensee failed to control activities by means of a radiation
work permit that included specification of appropriate radiation protection measures, and entry
was made prior to dose rates in the area having been determined and entry personnel
knowledgeable of them. Specifically, two workers entered the reactor building truck bay (a
locked high radiation area) and were present as a filter vessel with a dose rate of 52.8 rem per
hour at 30 cm was being lowered into it. Prior to arrival of the health physics technician,
required by the RWP for continuous radiation protection coverage for work in whole body dose
rates greater than 800 millirem (mrem) per hour, one of the workers received a dose rate
alarm of 1.52 rem per hour. Because a health physics technician was not present to
determine the actual dose rates (in contrast to calculated dose rates that had been briefed) in
the area while the load was being lowered, the workers were uninformed of the radiological
conditions.
Summary of Licensee Response
Energy Northwest accepted that there was a performance deficiency associated with workers
entering a locked high radiation area while a filter vessel was present. However, the licensee
stated that the performance deficiency was a violation of TS 5.4.1 for the failure to follow the
RWP requirements. Specifically, Energy Northwest contended that TS 5.7.2.b was met
because a RWP was used that contained the expected dose rates in the area and included
appropriate radiation protection equipment and measures, which were sufficient to control
exposure if they had been followed. Energy Northwest also stated that the requirement
established for continuous health physics technician coverage when dose rates exceeded
800 mrem per hour was not related to TS 5.7.2 and that the riggers were being monitored by
telemetry.
Energy Northwest contended that TS 5.7.2.e was met because dose rates of the filter
vessel were determined by direct survey and calculations prior to it being moved, and
individuals were briefed on those conditions. The licensee also stated that there was not
an opportunity to perform a survey while the load was in transit, as it would not have been
in accordance with the as low as is reasonably achievable (ALARA) principle. Energy
Northwest also pointed out that the situation which led to the NCV in question was similar
to NCVs written at the Clinton Power Station and Byron Station, which were each issued
as a TS 5.4.1 procedure violation.
Energy Northwest stated that their Plant Procedures Manual (PPM) 11.2.7.3, High Radiation
Enclosure
Area, Locked High Radiation Area, and Very High Radiation Area Controls, requires health
physics technician (HPT) coverage before entering an area of 800 mrem per hour and
GEN-RPP-11, ALARA Program Description, requires compliance with an RWP. Contrary to
both of these requirements, a worker entered an area with greater than 800 mrem per hour
dose rates without HPT coverage.
Licensee Conclusion
Energy Northwest accepted that there was a performance deficiency, in that workers failed to
comply with RWP and procedural guidance. However, Energy Northwest believes that this
violation was a failure to comply with TS 5.4.1 vice TS 5.7.2.
NRC Evaluation
The NRC staff performed an independent review of the licensees position as described in
its response to NRC Inspection Report 05000397/2018003, dated November 29, 2018, by
reviewing applicable Columbia Generating Station technical specifications, procedures,
surveys, and corrective action documents as referenced below.
Technical Specification 5.7.2.b states, Access to, and activities in, each such area shall
be controlled by means of an RWP or equivalent that includes specification of radiation
dose rates in the immediate work area(s) and other appropriate radiation protection
equipment and measures.
Energy Northwest contended that activities were controlled by means of an RWP that
included specification of appropriate radiation protection measures. The issue, as
described in the Energy Northwest position, was not that the RWP was inadequate, but
rather that workers (riggers) did not follow the requirements set forth in the RWP. The
NRC staff noted that RWP 30001279 requires that continuous RP coverage is required
for working in whole body dose rates greater than or equal to 800 mrem per hour. The
NRC staff also noted that Action Request (AR) 00368480 describes that riggers were
briefed not to enter the truck bay on the 441 foot elevation while the filter vessel was being
lowered until a HPT was present. The NRC staff concluded that, if followed, the RWP
would have been sufficient to control the work appropriately. However, it was not
followed. Therefore, although an adequate RWP was used, Energy Northwest did not
provide adequate access control and did not control the work activities in accordance with
Technical Specification 5.7.2.e states in part, Except for individuals qualified in radiation
protection procedures, or personnel continuously escorted by such individuals, entry into such
areas shall be made only after dose rates in the area have been determined and entry
personnel are knowledgeable of them.
Energy Northwest contended that the riggers were knowledgeable of the dose rates in the area
prior to entering the truck bay. Prior to the lift, a survey was conducted on the filter vessel. It
was surveyed on June 10, 2017, while the container was resting on the floor on the 471 foot
elevation. Anticipated dose rates were calculated for various distances from the filter vessel
based upon the survey. These calculated dose rates were part of the information briefed to the
riggers during the pre-job brief. The riggers were told not to enter the truck bay while the vessel
was being lowered without continuous coverage by an HPT.
2
However, the NRC staff noted that while a pre-move radiation survey was completed, it did not
provide an accurate representation of potential dose rates for the riggers, because surveying
the filter vessel while it was resting on the floor indicated that the bottom of the filter vessel was
not surveyed. While it was being lowered into the room, dose rates in the area would primarily
be coming from the bottom of the vessel. Therefore, because conditions were uncertain and
constantly changing while the filter vessel was in motion, dose rates in the area the riggers were
working were unknown. The NRC concluded that only surveying the filter vessel prior to
movement, especially when failing to include the bottom of the vessel as part of that survey,
was not sufficient to determine the expected dose rates in the truck bay and/or while the filter
vessel was in transit. As a result, the workers were not knowledgeable of the dose rates in the
area, contrary to TS 5.7.2.e.
The NRC Region III staff also reviewed and compared the referenced TS 5.4.1 NCV issued at
the Clinton Power Station to the event at Columbia. Region III staff independently reviewed
NCV 05000397/2018003-02 Failure to Control Workers in a High Radiation Area (>1.0 rem
per hour) and stated that based on their review, it was a valid TS 5.7.2 violation. Region III
Staff also described several differences between the Columbia and Clinton scenarios.
The NRC also compared the Columbia NCV to the referenced TS 5.4.1 NCV issued at the
Byron Station in which an engineer violated an RWP by entering a high radiation area. In this
Byron NCV, the RWP did not require continuous HPT coverage, and the licensee provided clear
instructions to the engineer which were not followed.
NRC Conclusion
The NRC staff concludes that the NCV as documented in the October 31, 2018, inspection
report remains valid. The NRC agrees that a TS 5.4.1 violation could have been written
regarding the work evolution. However, the procedural violations led to the more significant
performance deficiency, which was the lack of access control and control of work activities
resulting in the presence of two workers in a locked high radiation area who were not authorized
to be there without HPT coverage, and who did not have knowledge of the dose rates in the
area. Therefore, the NRC is upholding NCV 05000397/2018003-02 Failure to Control Workers
in a High Radiation Area (>1.0 rem per hour).
3
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword: NRC-002
By: CCA Yes No Publicly Available Sensitive
OFFICE ACES TL:ACES RC BC:DRS/PSB2 DIR:DRS OE RA:RIV
NAME CAlldredge MVasquez DCylkowski HGepford RLantz ETorres SMorris
SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/
DATE 03/05/19 03/12/19 03/07/19 03/08/19 03/12/19 03/13/19 04/16/19