ML17142A219: Difference between revisions

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| author name = Vegel A
| author name = Vegel A
| author affiliation = NRC/RGN-IV/DRS
| author affiliation = NRC/RGN-IV/DRS
| addressee name = Reddemann M E
| addressee name = Reddemann M
| addressee affiliation = Energy Northwest
| addressee affiliation = Energy Northwest
| docket = 05000397
| docket = 05000397
Line 15: Line 15:
| page count = 4
| page count = 4
}}
}}
See also: [[followed by::IR 05000397/2016009]]
See also: [[see also::IR 05000397/2016009]]


=Text=
=Text=
{{#Wiki_filter:May 22, 2017  
{{#Wiki_filter:UNITED STATES
 
                          NUCLEAR REGULATORY COMMISSION
EA-17-085  
                                              REGION IV
Mr. Mark E. Reddemann
                                          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)


Chief Executive Officer
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)


Energy Northwest
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
cc: Electronic Distribution


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:


   
  ML17142A219
This letter acknowledges your May 9, 2017, correspondence (ML17129A627) in response to NRC Inspection Report 05000397/2016009 (ML17100A499), dated April 10, 2017.  In the
  SUNSI Review         ADAMS:           Non-Publicly Available       Non-Sensitive Keyword:
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
  By: HGepford         Yes No       Publicly Available           Sensitive     NRC-002
requested you to respond in writing within 30 days if you contested any of the non-cited
OFFICE         C:PSB2       C:DRP/A       C:PSB2           D:DRS
violations or disagreed with the finding.
NAME           HGepford     MHaire       HGepford         AVegel
SIGNATURE     /RA/         /RA/         /RA/             /RA/ JAC for
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: 
DATE           5/17/17       5/17/17       5/17/17          5/   /17
(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) identif
ied 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) 
 
  UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD ARLINGTON, TX 76011-4511 
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 facility's 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 NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC's 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
 
cc:  Electronic Distribution 
 
  ML17142A219 SUNSI Review   ADAMS:   Non-Publicly Available Non-Sensitive Keyword: By: HGepford  Yes    No Publicly Available Sensitive NRC-002 OFFICE C:PSB2 C:DRP/A C:PSB2 D:DRS   NAME HGepford MHaire HGepford AVegel   SIGNATURE /RA/ /RA/ /RA/ /RA/ JAC for  
  DATE 5/17/17 5/17/17
5/17/175/     /17
}}
}}

Latest revision as of 03:57, 30 October 2019

Disputed Non-Cited Violations and Finding from NRC Inspection Report 05000397/2016009
ML17142A219
Person / Time
Site: Columbia Energy Northwest icon.png
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)
v • d • e


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

cc: Electronic Distribution

ML17142A219

SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: HGepford Yes No Publicly Available Sensitive NRC-002

OFFICE C:PSB2 C:DRP/A C:PSB2 D:DRS

NAME HGepford MHaire HGepford AVegel

SIGNATURE /RA/ /RA/ /RA/ /RA/ JAC for

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

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