ML19108A487

NRC Inspection Report 05000397/2018003 NRC Response to Disputed Non-Cited Violation

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

EA-18-173

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

TS 5.7.2.b.

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.

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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).

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ML19108A487

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