IR 05000397/2017010

NRC Radiation Safety Inspection Report 05000397/2017010

ML17298C186
Person / Time
Site:	Columbia
Issue date:	10/25/2017
From:	Heather Gepford NRC/RGN-IV/DRS/PSB-2
To:	Reddemann M Energy Northwest
References
IR 2017010
Download: ML17298C186 (31)

Text

ber 25, 2017

SUBJECT:

COLUMBIA GENERATING STATION - NRC RADIATION SAFETY INSPECTION REPORT 05000397/2017010

Dear Mr. Reddemann:

On September 14, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Columbia Generating Station and 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 inspectors documented two findings of very low safety significance (Green) in this report. Both of these findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy. The inspectors did not document any licensee-identified violations.

If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Columbia Generating Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Columbia Generating Station. 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 05000397/2017010 w/ Attachments:

1. Supplemental Information 2. Information Request for the Public Radiation Safety Inspection

REGION IV==

Docket: 05000397 Report: 05000397/2017010 Facility: Columbia Generating Station Dates: September 11-14, 2017 Inspectors: N. Greene, Ph.D., Health Physicist J. Furia, NRC Region I, Sr. Health Physicist J. ODonnell, CHP, Health Physicist C. Alldredge, Health Physicist Approved By: Heather Gepford, Ph.D., CHP Chief, Plant Support Branch 2 Division of Reactor Safety Enclosure

SUMMARY

IR 05000397/2017010; 09/11/2017 - 09/14/2017; Columbia Generating Station;

Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation.

Cornerstone: Occupational Radiation Safety

Green.

The inspectors identified a non-cited violation of Technical Specification 5.7.2 for the failure to control a high radiation area with dose rates greater than 1000 millirem per hour at 30 centimeters. Specifically, equipment boxes placed adjacent to high radiation area barrier fencing in the reactor building 471 elevation, which created a natural ladder into the area, resulted in an uncontrolled entryway to a high radiation area with dose rates greater than 2500 millirem per hour. Once informed, the licensee immediately removed the equipment boxes from the barrier and added signage that restricted the placement of any items adjacent to the fencing forming the high radiation area barrier. This issue was documented in the licensees corrective action program as Action Request AR 00355646.

The failure to properly control and barricade an entryway to a locked high radiation area in the reactor building, 471' elevation, was a performance deficiency. The performance deficiency was more than minor because it was associated with the program and process (exposure control) attribute of the Occupational Radiation Safety Cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material. Using NRC Inspection Manual Chapter 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process, the inspectors determined that the finding had very low safety significance (Green) because the finding was not an as low as reasonably achievable planning or work control issue, there was no overexposure or potential for an overexposure, and the licensee's ability to assess dose was not compromised. The finding had a cross-cutting aspect in the area of Human Performance, Field Presence, because leaders were not commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations, resulting in a lack of oversight of work activities, to include contractors and supplemental personnel (H.2). (Section 4OA5)

Cornerstone: Public Radiation Safety

Green.

The inspectors reviewed a self-revealed non-cited violation of 10 CFR 30.41(b)(5)for the failure to transfer byproduct material to an authorized waste disposal facility in accordance with the terms of the facilitys license. Specifically, License Condition No. 21.C of the US Ecology license requires that all radwaste shall be packaged in such a manner that waste containers received at the facility do not show an increase in the external radiation levels as recorded on the manifest, within instrument tolerances. On July 20, 2017, Columbia Generating Station personnel transferred byproduct material to US Ecology for disposal (Shipment 17-51). The disposal facilitys surveys identified that the dose rate on contact with the waste liner was 1100 millirem per hour, whereas the manifest for this shipment recorded a dose rate of 12 millirem per hour. The licensees corrective actions included providing a corrected shipment manifest to US Ecology and proposed enhancements to the Columbia Generating Station procedures for shipping. This issue was documented in the licensees corrective action program as Action Request AR 00369215.

The failure to transfer byproduct material to a low-level radwaste disposal facility in accordance with the facilitys license was a performance deficiency. The performance deficiency was more than minor because it was associated with the program and process attribute of the Public Radiation Safety Cornerstone and adversely affected the associated cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Using NRC Inspection Manual Chapter 0609,

Appendix D, Public Radiation Safety Significance Determination Process, the inspectors determined that the finding had very low safety significance (Green) because it was a low-level burial ground nonconformance; however, it was not Class C waste or greater and the waste did conform to the waste characteristics of 10 CFR 61.56. The finding has a cross-cutting aspect in the area of Human Performance, Resources, because licensee leaders failed to ensure that personnel, equipment, procedures, and other resources were available and adequate to support nuclear safety (H.1). (Section 2RS8)

REPORT DETAILS

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

The inspectors evaluated the accuracy and operability of the radiation monitoring equipment used by the licensee to monitor areas, materials, and workers to ensure a radiologically safe work environment. This evaluation included equipment used to monitor radiological conditions related to normal plant operations, anticipated operational occurrences, and conditions resulting from postulated accidents. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance associated with radiation monitoring instrumentation, as described below:

• The inspectors performed walk downs and observations of selected plant radiation monitoring equipment and instrumentation, including portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors. The inspectors assessed material condition and operability, evaluated positioning of instruments relative to the radiation sources or areas they were intended to monitor, and verified performance of source checks and calibrations.

• The inspectors evaluated the calibration and testing program, including laboratory instrumentation, whole body counters, post-accident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, and continuous air monitors.

• The inspectors assessed problem identification and resolution for radiation monitoring instrumentation. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constitute completion of the three required samples of radiation monitoring instrumentation, as defined in Inspection Procedure 71124.05.

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

a. Inspection Scope

The inspectors evaluated whether the licensee maintained gaseous and liquid effluent processing systems and properly mitigated, monitored, and evaluated radiological discharges with respect to public exposure. The inspectors verified that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out-of-service, were controlled in accordance with the applicable regulatory requirements and licensee procedures. The inspectors verified that the licensees quality control program ensured radioactive effluent sampling and analysis adequately quantified and evaluated discharges of radioactive materials. The inspectors verified the adequacy of public dose projections resulting from radioactive effluent discharges. The inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:

• During walk downs and observations of selected portions of the radioactive gaseous and liquid effluent equipment, the inspectors evaluated routine processing and discharge of effluents, including sample collection and analysis. The inspectors observed equipment configuration and flow paths of selected gaseous and liquid discharge system components, effluent monitoring systems, filtered ventilation system material condition, and significant changes to effluent release points.

• Calibration and testing program for process and effluent monitors, including National Institute of Standards and Technology traceability of sources, primary and secondary calibration data, channel calibrations, set-point determination bases, and surveillance test results.

• Sampling and analysis controls used to ensure representative sampling and appropriate compensatory sampling. Reviews included results of the inter-laboratory comparison program,

• Instrumentation and equipment, including effluent flow measuring instruments, air cleaning systems, and post-accident effluent monitoring instruments.

• Dose calculations for effluent releases. The inspectors reviewed a selection of radioactive liquid and gaseous waste discharge permits and abnormal gaseous or liquid tank discharges, and verified the projected doses were accurate. The inspectors also reviewed 10 CFR Part 61 analyses and methods used to determine which isotopes were included in the source term. The inspectors reviewed land use census results, offsite dose calculation manual changes, and significant changes in reported dose values from previous years.

• Problem identification and resolution for radioactive gaseous and liquid effluent treatment. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constitute completion of the six required samples of radioactive gaseous and liquid effluent treatment program, as defined in Inspection Procedure 71124.06.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program

a. Inspection Scope

The inspectors evaluated whether the licensees radiological environmental monitoring program quantified the impact of radioactive effluent releases to the environment and sufficiently validated the integrity of the radioactive gaseous and liquid effluent release program. The inspectors also verified that the licensee continued to implement the voluntary Nuclear Energy Institute (NEI)/Industry Ground Water Protection Initiative.

The inspectors reviewed or observed the following items:

• The inspectors observed selected air sampling and dosimeter monitoring stations, sampler station modifications, and the collection and preparation of environmental samples. The inspectors reviewed calibration and maintenance records for selected air samplers, composite water samplers, and environmental sample radiation measurement instrumentation, and inter-laboratory comparison program results.

The inspectors reviewed selected events documented in the annual environmental monitoring report and significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census. The inspectors evaluated the operability, calibration, and maintenance of meteorological instruments and assessed the meteorological dispersion and deposition factors. The inspectors verified the licensee had implemented sampling and monitoring program sufficient to detect leakage from structures, systems, or components with credible mechanism for licensed material to reach ground water and reviewed changes to the licensees written program for identifying and controlling contaminated spills/leaks to groundwater.

• Groundwater protection initiative implementation, including assessment of groundwater monitoring results, identified leakage or spill events and entries made into 10 CFR 50.75

(g) records, licensee evaluations of the extent of the contamination and the radiological source term, and reports of events associated with spills, leaks, and groundwater monitoring results.

• Problem identification and resolution for the radiological environmental monitoring program. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constitute completion of the three required samples of radiological environmental monitoring program, as defined in Inspection Procedure 71124.07.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08)

a. Inspection Scope

The inspectors evaluated the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material. The inspectors interviewed licensee personnel and reviewed the following items:

• Radioactive material storage, including waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition.

• Radioactive waste system, including walk-downs of the accessible portions of the radioactive waste processing systems and handling equipment. The inspectors also reviewed or observed changes made to the radioactive waste processing systems, methods for dewatering and waste stabilization, waste stream mixing methodology, and waste processing equipment that was not operational or abandoned in place.

• Waste characterization and classification, including radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides, and processes for waste classification including use of scaling factors and 10 CFR Part 61 analyses.

• Shipment preparation, including packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifests.

• Shipping records for LSA I, II, III, SCOI, II, Type A, or Type B radioactive material or radioactive waste shipments.

• Problem identification and resolution for radioactive solid waste processing and radioactive material handling, storage, and transportation. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constitute completion of the six required samples of radioactive solid waste processing, and radioactive material handling, storage, and transportation program, as defined in Inspection Procedure 71124.08.

b. Findings

Introduction:

The inspectors reviewed a self-revealed Green non-cited violation of 10 CFR 30.41(b)(5) for the failure to transfer byproduct material to an authorized waste disposal facility in accordance with the terms of the facilitys license.

Description:

License Condition No. 21.C of the US Ecology license, WN-I019-2, requires that all radwaste shall be packaged in such a manner that waste containers received at the facility do not show an increase in the external radiation levels as recorded on the manifest, within instrument tolerances. On July 20, 2017, the licensee transferred byproduct material to US Ecology for disposal (shipment 17-51). The disposal facilitys surveys revealed that the dose rate on contact with the waste liner (#17-084-OT) was 1100 millirem per hour, whereas the manifest (NRC Form 541, Block 9) recorded a dose rate of 12 millirem per hour.

The licensee determined that a change made to the draft shipment manifest, which had previously been sent to US Ecology and indicated the correct liner contact dose rate, contained an error in Block 8 of NRC Form 541 (Waste and Container Weight). Upon correction of this item, a final manifest was generated and signed, without identifying that other data had changed on the shipping manifest, including the entry in Block 9 of NRC Form 541, Surface Radiation Level for the Disposal Container. The licensees measured waste container contact dose rate had changed from the correct value of 1350 millirem per hour to 12 millirem per hour on the shipment manifest sent with the liner to US Ecology. Review of the issue determined the licensees procedures did not require a full review of the revised shipment manifest prior to shipment, and neither the shipper, reviewer, or manager identified the error regarding the liner dose rate.

Analysis:

The failure to transfer byproduct material to a low-level radwaste disposal facility in accordance with the facilitys license was a performance deficiency within the licensees ability to foresee and correct. The performance deficiency was more than minor because it was associated with the program and process attribute of the Public Radiation Safety Cornerstone and adversely affected the associated cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Using NRC Inspection Manual Chapter (IMC) 0609, Appendix D, Public Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance (Green) because it was a low-level burial ground nonconformance; however, it was not Class C waste or greater and the waste did conform to the waste characteristics of 10 CFR 61.56. The finding has a cross-cutting aspect in the area of Human Performance, Resources, because licensee leaders failed to ensure that personnel, equipment, procedures, and other resources were available and adequate to support nuclear safety (H.1).

Enforcement:

Title 10 CFR 30.41(b)(5) states, in part, that any licensee may transfer byproduct material to any person authorized to receive such byproduct material under terms of a specific license or a general license or their equivalents issued by the Commission or an Agreement State. Contrary to the above, on July 20, 2017, the licensee transferred byproduct material to US Ecology (an Agreement State licensee)that was not in accordance with the terms of the US Ecologys license, WN-I019-2.

Specifically, US Ecologys license condition 21.C requires that all radioactive waste be packaged in such a manner that waste containers received at the facility do not show an increase in the external radiation levels as recorded on the manifest. However, the licensee shipped a waste container to the US Ecology disposal facility that showed external radiation levels as high as 1100 millirem per hour on contact with the waste container, whereas the highest external radiation level on contact with the liner recorded on the shipping manifest was 12 millirem per hour. Corrective actions include providing a corrected shipment manifest to US Ecology, and proposed enhancements to the Columbia Generating Station procedures for shipping.

Because this violation was determined to be of very low safety significance and was entered into the licensees corrective action program as Action Request AR 00369215, this violation is being treated as a non-cited violation consistent with the Enforcement Policy: NCV 05000397/2017010-01, Failure to Transfer Byproduct Material to a Disposal Facility in Accordance with the Terms of the Facilitys License.

4OA5 Other Activities

Introduction:

The inspectors identified a Green, non-cited violation of Technical Specification 5.7.2 for the failure to control and barricade an entryway to a high radiation area (HRA) with dose rates greater than 1.0 rem/hour (1000 millirem per hour) at 30 centimeters from the radiation sources.

Description:

On July 25, 2017, while walking down the reactor building 471 elevation, the inspectors noted a locked HRA barrier in place at a temporary chemical decontamination skid and equipment storage area (CDSESA). The barrier was constructed of chain link fencing secured to a scaffold frame. There was also a chain link fence-scaffold door built as an access point into the CDSESA. The barrier fencing was originally constructed to measure approximately eight feet in height. Measured dose rates inside the CDSESA were up to a nominal 2500 millirem per hour at 30 centimeters from the various sources of the radiation.

Dose rates varied with proximity to the various equipment, as documented in radiation survey 20170720-7.

Licensee Procedures 11.2.7.1, Area Posting, and 11.2.7.3, High Radiation Area, Locked High Radiation Area, and Very High Radiation Area, specify that all locked HRAs should be designed with barriers greater than six feet in height. The inspectors also noted that licensees are required to provide reasonable assurance that locked HRAs are secured against unauthorized access and that the physical controls cannot be easily circumvented.

The inspectors observed equipment boxes being stored directly adjacent to and outside of the locked HRA barrier fencing. This equipment, together with the chain link fence and scaffold barrier, created a natural ladder into the CDSESA and decreased the effective height of the barrier to below six feet, thereby resulting in an uncontrolled entryway. Once inside the CDSESA, personnel would have had unencumbered access to the elevated dose rates. The inspectors determined that the natural ladder created by the stored equipment and barrier scaffold frame could be easily circumvented by an individual who assumed, for whatever reason, that he or she was authorized to enter the area.

Once informed, the licensee immediately removed the equipment boxes from along the barrier fencing and added signage that restricted the placement of items adjacent to the HRA barrier fencing. Applicable radiation protection procedures were revised to include guidance related to storing equipment near barriers. This issue was documented in the licensees corrective action program as Action Request AR 00355646.

Analysis:

The failure to properly control and barricade entry into a locked high radiation area in the reactor building, 471' elevation, was a performance deficiency. The performance deficiency was more than minor because it was associated with the program and process (exposure control) attribute of the Occupational Radiation Safety Cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material. Specifically, the failure to properly barricade a locked HRA could result in unnecessary and unplanned radiation exposures to plant workers.

Using NRC Inspection Manual Chapter 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process, the inspectors determined that the finding had very low safety significance (Green) because the finding was not an ALARA planning or work control issue, there was no overexposure or potential for an overexposure, and the licensee's ability to assess dose was not compromised.

The finding has a cross-cutting aspect in the area of Human Performance, Field Presence, because leaders were not commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations, resulting in a lack of oversight of work activities, to include contractors and supplemental personnel (H.2). The lack of oversight resulted in a failure to recognize that stacking the equipment boxes against the fence compromised the adequacy of the HRA barrier.

Enforcement:

Technical Specification 5.7.2.a requires, in part, for high radiation areas with dose rates greater than 1.0 rem/hour, but less than 500 rads/hour, that each entryway to such an area shall be conspicuously posted as a high radiation area and shall be provided with a locked or continuously guarded door or gate that prevents unauthorized entry.

Contrary to the above, on July 25, 2017, the licensee failed to ensure, for a high radiation area with dose rates greater than 1.0 rem/hour, but less than 500 rads/hour, that each entryway to such an area was conspicuously posted as a high radiation area and was provided with a locked or continuously guarded door or gate that prevented unauthorized entry. Specifically, equipment boxes placed adjacent to high radiation area barrier fencing in the reactor building 471 elevation, which created a natural ladder into the area, resulted in an uncontrolled entryway to a high radiation area with dose rates greater than 2500 millirem per hour. This was corrected on July 27, 2017. Because this violation is of very low safety significance, and it was entered into the licensees corrective action program as AR 00369479, this violation is being treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy:

NCV 05000397/2017010-02, Failure to Control a High Radiation Area with Dose Rates Greater Than 1000 Millirem Per Hour at 30 Centimeters.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On September 14, 2017, the inspectors presented the radiation safety inspection results to Mr. M. Reddemann, Chief Executive Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

S. Beatty, Health Physics Supervisor, Radiation Protection

K. Clark, Environmental Scientist II, Radiation Protection

M. Davis, Manager, Chemistry and Radiological Services

K. Gillard, Analyst, Chemistry and Radiological Services

A. Hedges, Supervisor, Chemistry Radwaste Support

A. Jensen, Specialist, Chemistry

M. Kinmark, Staff Health Physicist, Radiation Protection

D. Mee, Environmental Scientist III, Radiation Protection

M. Nolan, Senior Radwaste Transportation Specialist, Chemistry

T. Parmelee, Compliance Engineer, Regulatory Affairs

M. Shobe, Specialist, Chemistry

J. Smith, Radiological Operations Supervisor, Radiation Protection

L. Stueder, Instrument Specialist, Radiation Protection

D. Wolfgramm, Supervisor, Regulatory Affairs

R. Wynegar, Compliance Engineer, Regulatory Affairs

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

05000397/2017010- NCV Failure to Transfer Byproduct Material to a Disposal Facility in Accordance with the Terms of the Facilitys License (Section 2RS8)

05000397/2017010- NCV Failure to Control a High Radiation Area with Dose Rates Greater Than 1000 Millirem Per Hour at 30 Centimeters (Section 4OA5)

Closed

None