ML22067A184

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Enc 2 -NRC Regulatory Conference Presentation
ML22067A184
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 03/01/2022
From:
Division of Nuclear Materials Safety IV
To:
Greene N
Shared Package
ML22067A190 List:
References
EA-21-170
Download: ML22067A184 (26)
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Text

Nuclear Regulatory Commission Regulatory Conference Energy Northwest, Inc.

Columbia Generating Station USNRC Region IV Tuesday, March 1, 2021 To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Meeting Logistics

  • Operation of WebEx
  • Please MUTE cellular phones
  • Scheduled break (15-minute)
  • NRC caucus (Team Meetings)
  • Public Question Session (Press *1 on phone to raise hand, then await for the Moderator to acknowledge you)

To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

MEETING AGENDA Topic Participants NRC Opening Remarks and Introductions Scott Morris Energy Northwest (ENW) / Columbia Licensee Opening Remarks and Introductions Generating Station (CGS)

Regulatory Conference Process Mary Muessle Summary of the Event, White Finding, Violations Jonathan Evans Performance Deficiency and NRCs Agenda Natasha Greene, PhD Dispositioning Process Possible Outcomes and Licensee Appeal Rights Jeremy Groom Discussion of Apparent Violations Dominic Antonangeli Licensee Presentation ENW / CGS Staff Questions and Discussion NRC and ENW / CGS Participants Break and NRC Caucus (via Teams Meeting) NRC and ENW / CGS Participants Questions and Discussion NRC and ENW / CGS Participants Licensee Closing Remarks ENW / CGS Staff NRC Closing Remarks Scott Morris Public Question and Answer Session Public Attendees To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

NRC Principal Participants Scott Morris Mary Muessle Jeremy Groom RIV Administrator RIV DRSS Director RIV ACES Team Leader Jonathan Evans Natasha Greene, PhD Dominic Antonangeli DRSS/DIORB Acting Chief DRSS/DIORB Sr. HP DRSS/DIORB HP To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Energy Northwest Inc.

Opening Remarks / Introductions Grover Hettel Dave Brown Tony Hedges VP Nuclear Generation/CNO Site Vice President Chemistry/Radiological Services Manager (CRSM)

Sam Nappi Desiree Wolfgramm Asst. CRSM Regulatory Affairs Manager To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Purpose of Regulatory Conference

  • The NRC normally provides an opportunity for a licensee to address apparent violations before the NRC takes escalated enforcement action, or makes a final decision on the significance.

and gain their perspective on the apparent violations.

  • The significance assessment determines whether an escalated enforcement action will be considered (i.e., a Notice of Violation associated with a white, yellow, or red SDP finding). Licensee input during this conference is also considered in making a final decision.

To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Todays Meeting

  • No Final Decision on safety significance or enforcement action will be made today.
  • Our NRC Inspection Report provided our current understanding and perspective on the issue.
  • We Want Your Perspective
  • Any additional details NRC should consider
  • Whether findings/violations occurred
  • Perceived significance of the findings/violations
  • Corrective actions implemented and/or Planned Timeline To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Public Meeting Disclaimer

  • The public is invited to observe the meeting and will have one or more opportunities to communicate with the NRC after the business portion, but before the meeting is adjourned.

To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Summary Overview of the CGS Uptake Event

  • On Friday, May 28, 2021, while performing weld preparations and grinding on highly contaminated Reactor Water Clean Up (RWCU) system piping, a team of radworkers and pipefitters deviated from the approved engineering controls, resulting in an airborne radioactivity event that caused 22 positive whole-body counts, including two uptakes of radioactive material resulting in more than 700 millirem CEDE for the two pipefitters.
  • There was also an additional uptake of 14 mrem by a RP tech. The work was performed in the RWCU Heat Exchanger room, a posted locked high radiation area and contamination area.
  • The licensee contacted the NRC to discuss the event on May 29, 2021.

To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Columbia Generating Station Reactor Water Clean-up (RWCU) Heat Exchanger Radioactive Material Uptake Event May 28, 2021 NRC informed on May 29, 2021 NRC issued a Choice Letter to CGS on January 13, 2022 (ML21347A988; EA-21-170)

To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Performance Deficiency

  • Per our understanding, the licensee failed to implement and follow written procedures for radiation protection. Specifically, the licensee failed to implement and follow Sections 4.4, 5.1.1, and 5.2.2 of licensee instruction manual HPI-12.90, Contamination Control Containment Devices. These sections state, in part, that (Section 4.4) a TEDE ALARA evaluation is [to be] performed; (Section 5.1.1.) the licensee should specify the type of containment device to be used (i.e., glove bag with a 20 to 40 cfm filter) in the ALARA pre-job planning documents or in the RWP; and (Section 5.2.2) that glove bags with a negative ventilation should have a 20 to 40 CFM HEPA breather filter installed.
  • The licensee failed to specify this information in the ALARA planning documents or in the RWP 30004732 used for the job, which ultimately resulted in the selection of the wrong glove bag inlet filter, the subsequent collapse of the glove bag, the release of the airborne radioactive material, and not using respiratory protection to mitigate the consequences.

To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Reactor Oversight Process:

Significance Determination Process To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Dispositioning the Issue:

More than Minor

  • The inspectors determined the performance deficiency was more than minor because it adversely affected the Occupational Radiation Safety cornerstone objective to ensure adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation.

IMC 0609, Appendix C:

Occupational Radiation Safety Significance Determination Process Not an issue of ALARA Plans or Work Controls (based on estimated dose)

To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Substantial Potential for Overexposure

  • IMC 0609, App. C, defines it as: an event presents a substantial potential when it was fortuitous that the resulting exposure did not exceed the limits of 10 CFR Part 20. No credit is given for luck.
  • Concern is focused on whether the licensee provided adequate controls over the situation, as required, to ensure dose limits are not exceeded.
  • Consider if it is possible to construct a reasonable scenario in which a minor alteration of circumstances (as they actually happened) would have resulted in a violation of the 10 CFR Part 20 limits To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

NRCs Reasonable Scenario -

Fortuitous Intervention

  • The NRC considered the reasonable scenario to be the continuation of the work, including clean up, without intervention.
  • The NRC deems the intervention by the RP Tech Lead as fortuitous due to his view of the correct camera, his experience/knowledge to recognize the abnormal situation with the glove bag, and the short pathway to the RWCU HX room.
  • NRC derived air concentrations (DAC) calculations for airborne radiation levels at the time of the event, as confirmed by the licensees DAC calculations, showed that workers may have been overexposed (greater than 5 rem) within five additional minutes of working in the area. This was based on the best available data.

To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Possible Outcomes

  • The NRC determines there is no violation resulting in no enforcement action.
  • The NRC determines the apparent violations are of very low safety significance resulting in non-escalated enforcement (Green Non-Cited Violation).
  • The NRC determines the apparent violations are of low to moderate safety significance resulting in escalated enforcement (a White Finding and an associated Notice of Violation).

To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Licensee's Appeal Rights

  • A licensee has the right to challenge any NRC determination/action that may be presented.
  • Instructions for challenging a NRC enforcement action are included in our transmittal letter and the action itself.

To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Apparent Violation #1

  • Title 10 CFR 20.1701 requires, in part, that licensees shall use, to the extent practicable, process or other engineering controls to control the concentration of radioactive material in air.
  • Contrary to the above, on May 28, 2021, the licensee failed to use, to the extent practicable, process or other engineering controls to control the concentration of radiation material in air. Specifically, the licensee did not use appropriate engineering controls to ensure that grinding on the internals of highly contaminated piping would not result in airborne radioactive material 9because the glove bag was not sufficient to meet its intended purpose. As a result, an airborne contamination event caused two individuals to receive internal doses of greater than 700 millirem CEDE.

To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Apparent Violation #2

  • RWP 30004732, created to control activities in a Technical Specification 5.7.2.b high radiation area, required, in part, that continuous Health Physics job coverage is provided when personnel are entering and working in areas with dose rates greater than 0.8 rem/hour.
  • Contrary to the above, on May 28, 2021, the licensee failed to control, by means of an RWP, the activities in a high radiation area with dose rates of greater than 1.0 rem/hour at 30 centimeters from the radiation source.

Specifically, the licensee failed to ensure that there was continuous Health Physics job coverage in a posted high radiation area with dose rates of 1.3 rem/hour at 30 centimeters from the radiation source. An RP technician, scheduled and briefed to provide the continuous Health Physics job coverage, was unable to fit on the work area platform and left two pipefitters unattended in the area. A second RP technician subsequently replaced the original technician.

To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Apparent Violation #3

  • Title 10 CFR 20.1501(a)(2) requires, in part, that licensees shall make surveys of areas that are reasonable under the circumstances to evaluate the magnitude and extent of radiation levels; and concentrations or quantities of residual radioactivity.
  • Contrary to the above, on May 27, 2021, the licensee failed to make surveys of areas that were reasonable under the circumstances to evaluate the magnitude and extent of radiation levels; and concentrations or quantities of residual radioactivity.

Specifically, the licensee failed to adequately determine the work area radiation levels.

  • As a result, surveys completed prior to the event did not adequately identify work area dose rates and did not identify appropriate contamination levels, which may have increased the rigor of the jobs radiological and engineering controls.

To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Energy Northwest Presentation Agenda To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

NRC and Energy Northwest/CGS Staff Q&A Session To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

NRC Regulatory Conference with Energy Northwests Columbia Generating Station NRC Caucus in Session Returning Shortly To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Conference Closing Remarks

  • Energy Northwests Closing Remarks
  • NRCs Closing Remarks
  • Next Steps / Expectations
  • Conclusion of the business portion of todays Regulatory Conference
  • The platform is now OPEN to questions from our public attendees PLEASE press *1 on your phone and await the Moderator to announce you.

To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

Any Questions from the Public Attendees?

(Please press *1 on your phone to identify yourself and await the Moderator)

To hear the audio portion of this presentation, dial 1-800-857-5003 and enter participant code # 5204033.

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