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Category:Letter type:GO
MONTHYEARGO2-24-004, License Amendment Request to Revise Emergency Plan2024-01-30030 January 2024 License Amendment Request to Revise Emergency Plan GO2-24-003, Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing2024-01-29029 January 2024 Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing GO2-24-005, Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-1702024-01-0808 January 2024 Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-170 GO2-23-136, Guarantee of Payment of Deferred Premium2023-12-20020 December 2023 Guarantee of Payment of Deferred Premium GO2-23-135, Notice of Readiness for Supplemental Inspection2023-12-14014 December 2023 Notice of Readiness for Supplemental Inspection GO2-23-130, Reply to a Notice of Violation; EA-23-0542023-12-14014 December 2023 Reply to a Notice of Violation; EA-23-054 GO2-23-105, Licensing Basis Document Update and Biennial Commitment Change Report2023-12-12012 December 2023 Licensing Basis Document Update and Biennial Commitment Change Report GO2-23-107, Application to Revise Technical Specifications to Adopt TSTS-584, Eliminate Automatic RWCU System Isolation on SLC Initiation2023-12-0505 December 2023 Application to Revise Technical Specifications to Adopt TSTS-584, Eliminate Automatic RWCU System Isolation on SLC Initiation GO2-23-126, Docket No. 50-397 Voluntary Response to Regulatory Issue Summary 2023-012023-11-28028 November 2023 Docket No. 50-397 Voluntary Response to Regulatory Issue Summary 2023-01 GO2-23-121, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-27027 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation GO2-23-097, In-Service Inspection Summary Report for the Twenty-Sixth Refueling Outage (R26)2023-09-0606 September 2023 In-Service Inspection Summary Report for the Twenty-Sixth Refueling Outage (R26) GO2-23-100, Technical Specification Section 5.6.4 Post Accident Monitoring Instrumentation 14-Day Report for Inoperable Suppression Pool Level Indication2023-08-31031 August 2023 Technical Specification Section 5.6.4 Post Accident Monitoring Instrumentation 14-Day Report for Inoperable Suppression Pool Level Indication GO2-23-056, Application to Revise Technical Specifications to Adopt TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling2023-08-29029 August 2023 Application to Revise Technical Specifications to Adopt TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling GO2-23-093, Supplement to Reply to a Notice of Violation: EA-21-1702023-07-27027 July 2023 Supplement to Reply to a Notice of Violation: EA-21-170 GO2-23-068, Notification of Completion of Commitments Required Prior to Entry Into the Period of Extended Operation2023-07-19019 July 2023 Notification of Completion of Commitments Required Prior to Entry Into the Period of Extended Operation GO2-23-090, Reply to a Notice of Violation2023-07-12012 July 2023 Reply to a Notice of Violation GO2-23-073, Notification of NPDES Permit Issuance2023-06-26026 June 2023 Notification of NPDES Permit Issuance GO2-23-072, Cycle 27 Core Operating Limits Report2023-06-0505 June 2023 Cycle 27 Core Operating Limits Report GO2-23-055, Independent Spent Fuel Storage Installation, 2022 Annual Radiological Environmental Operating Report2023-05-15015 May 2023 Independent Spent Fuel Storage Installation, 2022 Annual Radiological Environmental Operating Report GO2-23-006, License Amendment Request to Clean-Up Operating License and Appendix a Technical Specifications2023-05-0101 May 2023 License Amendment Request to Clean-Up Operating License and Appendix a Technical Specifications GO2-23-053, 2022 Annual Environmental Operating Report2023-04-26026 April 2023 2022 Annual Environmental Operating Report GO2-23-057, 2022 Annual Radioactive Effluent Release Report2023-04-25025 April 2023 2022 Annual Radioactive Effluent Release Report GO2-23-012, Application to Revise Technical Specifications to Adopt Tstf-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position2023-03-27027 March 2023 Application to Revise Technical Specifications to Adopt Tstf-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position GO2-23-041, Generation Station - Level of Financial Protection - Annual Reporting Requirement2023-03-15015 March 2023 Generation Station - Level of Financial Protection - Annual Reporting Requirement GO2-23-038, Plant Decommissioning Fund Status Report2023-03-15015 March 2023 Plant Decommissioning Fund Status Report GO2-23-034, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.462023-03-13013 March 2023 Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.46 GO2-23-035, Supplement to License Amendment Request to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-03-0909 March 2023 Supplement to License Amendment Request to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling GO2-23-019, Emergency Plan - Summary of Changes and Analysis for Revision 68 of the EP-012023-02-0808 February 2023 Emergency Plan - Summary of Changes and Analysis for Revision 68 of the EP-01 GO2-22-131, Guarantee of Payment of Deferred Premium2022-12-19019 December 2022 Guarantee of Payment of Deferred Premium GO2-22-122, Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2022-11-28028 November 2022 Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b GO2-22-076, Status of License Renewal Commitments2022-10-31031 October 2022 Status of License Renewal Commitments GO2-22-110, Supplement to License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactor2022-10-17017 October 2022 Supplement to License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactor GO2-22-096, Supplement to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2022-10-0404 October 2022 Supplement to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b GO2-22-085, Docket No. 50-397, Evacuation Time Estimate Analysis2022-08-30030 August 2022 Docket No. 50-397, Evacuation Time Estimate Analysis GO2-22-075, Response to Request for Additional Information Related to Revised Pressure-Temperature Limit Curves2022-07-11011 July 2022 Response to Request for Additional Information Related to Revised Pressure-Temperature Limit Curves GO2-22-072, Summary of Changes and Analysis for Revision 57 of PPM 13.14.4 - Emergency Equipment Maintenance and Testing2022-07-11011 July 2022 Summary of Changes and Analysis for Revision 57 of PPM 13.14.4 - Emergency Equipment Maintenance and Testing GO2-22-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Colling Using the Consolidated Line Item Improvement Process2022-05-25025 May 2022 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Colling Using the Consolidated Line Item Improvement Process GO2-22-062, Registration of Spent Fuel Cask Use2022-05-19019 May 2022 Registration of Spent Fuel Cask Use GO2-22-049, Supplement to Licensing Amendment Request to Adopt 10CFR50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Rectors2022-05-10010 May 2022 Supplement to Licensing Amendment Request to Adopt 10CFR50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Rectors GO2-22-054, Independent Spent Fuel Storage Installation, 2021 Annual Radiological Environmental Operating Report2022-05-0909 May 2022 Independent Spent Fuel Storage Installation, 2021 Annual Radiological Environmental Operating Report GO2-22-056, Registration of Spent Fuel Cask Use2022-04-21021 April 2022 Registration of Spent Fuel Cask Use GO2-22-055, 2021 Annual Environmental Operating Report2022-04-20020 April 2022 2021 Annual Environmental Operating Report GO2-22-048, 2021 Annual Radioactive Effluent Release Report2022-04-15015 April 2022 2021 Annual Radioactive Effluent Release Report GO2-22-045, Registration of Spent Fuel Cask Use2022-04-0606 April 2022 Registration of Spent Fuel Cask Use GO2-22-044, Level of Financial Protection - Annual Reporting Requirement2022-03-21021 March 2022 Level of Financial Protection - Annual Reporting Requirement GO2-22-038, Docket No. 50-397, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.462022-03-0909 March 2022 Docket No. 50-397, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.46 GO2-22-031, Response to Audit Plan and Online Reference Portal Request2022-02-15015 February 2022 Response to Audit Plan and Online Reference Portal Request GO2-22-011, Docket No. 72-35; Independent Spent Fuel Storage Installation, 2021 Annual Effluent Release Report2022-02-0808 February 2022 Docket No. 72-35; Independent Spent Fuel Storage Installation, 2021 Annual Effluent Release Report GO2-22-001, License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2022-02-0303 February 2022 License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b GO2-22-012, Independent Spent Fuel Storage Installation - Biennial 50.59/72.48 Report2022-01-24024 January 2022 Independent Spent Fuel Storage Installation - Biennial 50.59/72.48 Report 2024-01-08
[Table view] Category:Licensee Response to Notice of Violation
MONTHYEARGO2-24-005, Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-1702024-01-0808 January 2024 Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-170 GO2-23-130, Reply to a Notice of Violation; EA-23-0542023-12-14014 December 2023 Reply to a Notice of Violation; EA-23-054 GO2-23-093, Supplement to Reply to a Notice of Violation: EA-21-1702023-07-27027 July 2023 Supplement to Reply to a Notice of Violation: EA-21-170 ML23206A2442023-07-25025 July 2023 Energy Northwest Columbia Generating Station, Response to Apparent Violation in NRC Inspection Report 05000397/2023092; EA-23-054 GO2-23-090, Reply to a Notice of Violation2023-07-12012 July 2023 Reply to a Notice of Violation GO2-18-146, Response to Inspection Report 05000397/20180032018-11-29029 November 2018 Response to Inspection Report 05000397/2018003 GO2-17-173, Revised Response to a Notice of Violation; EA-17-0282017-10-11011 October 2017 Revised Response to a Notice of Violation; EA-17-028 GO2-17-141, Reply to a Notice of Violation; EA-17-0282017-08-0303 August 2017 Reply to a Notice of Violation; EA-17-028 GO2-17-100, Response to Inspection Report 05000397/20160092017-05-0909 May 2017 Response to Inspection Report 05000397/2016009 GO2-15-179, Response to Inspection Report 05000397/20150032015-12-22022 December 2015 Response to Inspection Report 05000397/2015003 GO2-11-137, Supplemental Information Provided to Report 0500397/20100072011-08-11011 August 2011 Supplemental Information Provided to Report 0500397/2010007 GO2-08-107, Reply to Notice of Violation; EA-08-1832008-07-16016 July 2008 Reply to Notice of Violation; EA-08-183 GO2-08-099, Reply to a Notice of Violation, EA-04-1452008-07-0202 July 2008 Reply to a Notice of Violation, EA-04-145 GO2-05-142, Response to Inspection Report 05000397-05-0072005-08-15015 August 2005 Response to Inspection Report 05000397-05-007 GO2-05-065, Review of NRC Violation 50-397/04-05-022005-04-0404 April 2005 Review of NRC Violation 50-397/04-05-02 ML0411803842004-04-16016 April 2004 Reply to Non-Cited Violation from IR 05000397/03-007 GO2-02-134, Energy Northwest, Docket No. 50-397, NRC Inspection Report 50-397/02-05, Response to Notice of Violation2002-08-21021 August 2002 Energy Northwest, Docket No. 50-397, NRC Inspection Report 50-397/02-05, Response to Notice of Violation GO2-02-016, Operating License NPF-21 Reply to Final Significance Determination for a Yellow Finding and Notice of Violation (NRC IR 05000397/2001-008)2002-02-28028 February 2002 Operating License NPF-21 Reply to Final Significance Determination for a Yellow Finding and Notice of Violation (NRC IR 05000397/2001-008) IR 05000397/20010082002-02-20020 February 2002 Reply to Final Significance Determination for a Yellow Finding and Notice of Violation (NRC Inspection Report 50-397/01-008) 2024-01-08
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Dale K. Atkinson ENERGY Columbia Generating Station P.O. Box 968, PE08 NORTHWEST Richland, WA 99352-0968 Ph. 509.377.4302 I F. 509.377.4150 dkatkinson@energy-northwest.com July 16, 2008 G02-08-1,07 10 CFR 2.201 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NOS. 50-397,72-035 REPLY TO A NOTICE OF VIOLATION; EA-08-183
Reference:
Letter dated June 17, 2008, D. Blair Spitzberg (NRC) to JV Parrish (Energy Northwest): "Inspection Report Nos. 050-397/08-007; 072-035/08-001 and Notice of Violation"
Dear Sir or Madam:
Pursuant to 10 CFR 2.201, Energy Northwest hereby responds to the Notice of Violation transmitted via the reference above.
The attachment to this letter provides: (1) the reason for the violation; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken to avoid further violations; and (4) the date when full compliance will be achieved.
There are no new commitments being made. If you have any questions, please contact MC Humphreys, Licensing Supervisor at (509) 377-4025.
Respectfully, DK Atkinson Vice President, Nuclear Generation & Chief Nuclear Officer Attachment cc: EE Collins, Jr. - NRC RIV RN Sherman - BPA/1 399 CF Lyon - NRC NRR WA Horin - Winston & Strawn NRC Senior Resident Inspector/988C Director, Spent Fuel Project Office rH~boI
REPLY TO A NOTICE OF VIOLATION; EA-08-183 Attachment Page 1 of 4 NOTICE OF VIOLATION EA-08-183 10 CFR 72.210 provides, in part, a general license for the storage of spent fuel in an independent spent fuel storage installation (ISFSI) at power reactor sites, to persons authorized to operate nuclear power reactors under 10 CFR Part 50. This general license is limited to storage of spent fuel in casks approved under the provisions of 10 CFR Part 72.
Certificate of Compliance (CoC) 1014, for the HI-STORM Cask System wasissued in accordance with 10 CFR 72.238. The certificate states, in part, that it is conditional upon fulfilling the requirements of 10 CFR Part 72, as applicable, and the attached Appendix A (Technical Specification) and Appendix B (Approved Contents and Design Features).
Section 3.8 of CoC 1014, Appendix B, requires, in part, that during the Multi-Purpose Canister (MPC) lid-to-shell welding operations, combustible gas monitoring of the space under the MPC lid be performed to ensure that no combustible gas mixture is present in the welding area.
Contrary to the above, on April 8, 2008, and again on April 16, 2008 the licensee did not effectively monitor combustible gas concentrations under the MPC lid during the MPC lid-to-shell welding operations to ensure that no combustible gas mixture was present in the welding area. Specifically, on April 8, 2008, after the root pass of the lid-to-shell weld had been completed and work was being done on the next weld layer, the licensee elected to suspend combustible gas concentration monitoring; and on April 16, 2008, the position of the licensee's explosive gas monitor relative to the MPC vent port did not effectively detect combustible gas concentrations. Both of these situations resulted in hydrogen burn events.
RESPONSE
Energy Northwest accepts this violation and provides the following response:
- 1. Reason for the Violation The cause analysis has identified two corresponding root causes, described below, that were associated with the failure to effectively monitor combustible gases during lid-to-shell welding on April 8, 2008 and April 16, 2008. The failure to effectively monitor was self evident as hydrogen burns occurred during the lid-to-shell welding operations on both dates. Corrective actions were taken following each event.
Root Cause (April 8 Event): Vague implementation of CoC Appendix B, Section 3.8, and FSAR requirements in the procedure (PPM 6.6.7, MPC Processing) permitted no gas exhausting and/or monitoring to occur in the field after the root pass of the welding was complete. This represents a latent weakness in administrative barriers. Existing work instructions (procedures) were inadequate to control hydrogen gas accumulation, as described below.
REPLY TO A NOTICE OF VIOLATION; EA-08-183 Attachment Page 2 of 4
- a. Procedure PPM 6.6.7, MPC Processing,preceding revision 19 (up to the April 8, 2008 event), contains wording in a critical step that can easily be read two ways, depending on the reader perspective. Lid welding step 7.2.3.1, which follows completion of the root weld pass and was an explicit step to monitor combustible gas during the root weld pass, stated:
"As directed by the Cask Loading Supervisor, secure the continuous exhaust and monitor in the proximity of the MPC lid vent port."
To the author and procedure reviewers, the step directs to secure the exhauster and move the monitor from the proximity of the weld to the vent port to continue monitoring there. To the field workers and supervisors, the step directs to remove both the exhauster and the monitor (the monitor was monitoring the exhaust stream). Consequently, worker field practices for MPC processing during each campaign did not align with the intent of the author. The step quoted above should have been written as two separate steps to avoid ambiguity. With no monitoring, no intervention could take place in response to rising H2 levels.
Procedure SWP-PRO-03, ProcedureWriters' Manual, directs that the number of specific actions within an instructional step be limited to one unless the actions are functionally related and that the actions can be completed at the same time.
The two actions in step 7.2.3.1 of PPM 6.6.7 did not meet both conditions described in SWP-PRO-03. This latent condition has existed from the original revision of PPM 6.6.7 which was issued prior to the first dry cask loading campaign in 2002.
- b. While the FSAR and CoC required monitoring and recommended exhausting (or purging) until the welding was complete, PPM 6.6.7, MPC Processing,did not contain any instruction as to how the chosen exhausting methodology was to be performed. The procedure merely restated a requirement to exhaust.
Procedure SWP-PRO-03, Procedure Writers' Manual, directs that the level of detail in procedures be commensurate with the skills and knowledge of the intended user and that the instruction content should be written for the intended user (not the seasoned user, Inspector, Auditor, Trainer, etc.). Venting/
exhausting of the head space is a safety-related task that should not have been left to in-the-field determinations as to specifically how the task should be performed.
Root Cause (April 16 Event): Less than adequate review of immediate corrective actions. This represents a latent administrative barrier weakness in the corrective action program.
'-C.
REPLY TO A NOTICE OF VIOLATION; EA-08-183 Attachment Page 3 of 4 Following the first event on April 8, it was recognized that combustible gas monitoring needed to be continued after the root pass weld of the MPC lid.
Therefore, steps had been taken to reinstitute the method of combustible gas monitoring that was in effect prior to the root pass weld being complete. This method involved continuously exhausting the region under the MPC lid with a hose directed to a filter using the vent port on the MPC lid. However, once the root pass of the MPC lid to shell weld was fully in place, there was no means for fresh air to enter the area below the MPC lid other than through the MPC lid vent port, resulting in the inability to effectively monitor for combustible gases.
The immediate recovery plan following the first event failed to adequately evaluate the effectiveness of the proposed immediate corrective action to address the hydrogen burn problem. Although a problem was recognized, an incomplete problem definition focused the attention of the recovery team on fixing the procedure to comply with the CoC vs. explicitly defining how to prevent the hydrogen burn. It was assumed the former would take care of the latter. Although the procedure revision intended to incorporate the CoC requirement, it lacked sufficient detail to establish an effective means for avoiding a hydrogen burn.
- 2. Corrective Steps Taken and Results Achieved Corrective Steps Taken
- 1. Suspended MPC welding pending investigation ("stop work" imposed following the April 16 event). The stop work was subsequently lifted following completion of action #3 below.
- 2. Performed procedure EGM-1 -8, Technical Issues Resolution Process,to thoroughly analyze the events surrounding both hydrogen burn events and developed a recovery plan to address the ineffective monitoring.
- 3. Revised procedure PPM 6.6.7, MPC Processing,to require inert gas purge and continuous monitoring during welding, in accordance with the recovery plan outlined as a result of action #2 above.
Results Achieved Effective combustible gas monitoring was achieved as determined during actual performance.
- 3. Corrective Steps to be Taken to Avoid Further Violation
- 1. Revise procedure PPM 6.6.7, MPC Processing,as follows to ensure lessons learned are clearly conveyed to the next campaign currently scheduled for 2014:
- Add cautions to the body and attachment 9.2 regarding the concern for hydrogen gas ignition.
REPLY TO A NOTICE OF VIOLATION; EA-08-183 Attachment Page 4 of 4 0 Incorporate lessons learned from inert gas purge during welding. Include details regarding purge flow, action limits, and response actions (e.g.,
increase purge flow).
- Incorporate lessons learned regarding monitoring requirements during welding operations. This includes effective cask monitoring post root weld pass to ensure levels remain below the lower flammability limit (LFL).
- 2. Revise procedure SWP-IRP-03, Incident Review Boardto include more detailed instruction regarding immediate/compensatory corrective action development and implementation associated with events warranting investigation.
- 3. Issue a lesson learned bulletin to procedure writers using the PPM 6.6.7 example as an error prone condition to watch for.
- 4. Review and revise PPM 6.6.x series procedures for compliance with SWP-PRO-03, Procedure Writers Manual, requirements, e.g., one action per step, etc.
- 5. Perform a 100% review of HI-STORM FSAR and CoC requirements to PPM 6.6.x series procedure requirements.
- 6. Revise applicable procedures (e.g., PPM 6.6.7, MPC Processing,PPM 6.6.9, MPC Coo/down and Weld Removal System) to include purging and monitoring requirements for MPC cutting activities.
- 4. Date When Full Compliance Will be Achieved Full compliance was achieved on April 25, 2008 when revision 20 to procedure PPM 6.6.7, MPC Processing,was approved and made effective. This revision included effective guidance to ensure compliance with CoC 1014, Appendix B, and Section 3.8. This new guidance was used in the completion of loading the remaining MPCs for the current loading campaign.