ML081570429

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NRC Inspection Report 05000397/2008008, Investigation Report 4-2008-003, and Notice of Violation
ML081570429
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 06/05/2008
From: Caniano R
Division of Reactor Safety IV
To: Parrish J
Energy Northwest
References
4-2008-003, EA-08-145, FOIA/PA-2010-0245 IR-08-008
Download: ML081570429 (7)


See also: IR 05000397/2008008

Text

UNITED STATES

NUC LE AR RE G UL AT O RY C O M M I S S I O N

R E GI ON I V

612 EAST LAMAR BLVD , SU I TE 400

AR LI N GTON , TEXAS 76011-4125

June 5, 2008

EA-08-145

J. V. Parrish (Mail Drop 1023)

Chief Executive Officer

Energy Northwest

P.O. Box 968

Richland, WA 99352-0968

SUBJECT: COLUMBIA GENERATING STATION - NRC INSPECTION

REPORT 05000397/2008008, INVESTIGATION REPORT 4-2008-003,

AND NOTICE OF VIOLATION

Dear Mr. Parrish:

This refers to the subject investigation and in-office inspection which was completed on May 13,

2008. The investigation was conducted by the Nuclear Regulatory Commission's (NRC) Office

of Investigation, and an in-office inspection examined the events documented in your Condition

Report CR 2-07-06293 regarding the failure of a licensee employee to follow procedural

requirements at your Columbia Generating Station. The findings were discussed with

Mr. J. Frisco, Plant General Manager, and other members of your staff during a telephonic exit

meeting on May 13, 2008.

The NRC has determined that a violation of NRC requirements occurred. The violation was

evaluated in accordance with the NRC Enforcement Policy included on the NRCs website at

www.nrc.gov/about-nrc/regulatory/enforcement.html.

The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances

surrounding it are described in detail in this letter, which serves as the inspection report. The

violation involves a licensee employee who, while working on replacement of the high pressure

core spray pump, directed contract employees to reach across a contaminated area boundary

without radiation protection approval.

On September 26, 2007, the licensee informed the NRC of this matter. Based on the NRCs

subsequent investigation and inspection, the NRC concluded that the project managers failure

to follow procedural requirements was deliberate. Our conclusion was based on the fact that

the project manager was reminded by contract workers that they were not to reach across the

boundary without radiation protection approval. The project manager told them to do it anyway

and he would take responsibility for it. The project manager also admitted to having knowledge

and understanding of the procedural requirements.

Energy Northwest -2-

EA-08-145

Wilful violations are, by definition, of concern to the NRC because its regulatory program is

based on licensees and its employees acting with integrity. In this case, the project manager

directed others to reach across the contamination boundary even after the workers reminded

him that doing so was not in accordance with the procedure requirements. However, the NRC

recognizes the very low underlying safety significance of the violation, in that the contamination

levels were low and no contamination of personnel occurred. In addition, the NRC

acknowledges the disciplinary actions taken by your staff. Therefore, this violation has been

categorized at Severity Level IV in accordance with the NRC Enforcement Policy. In

accordance with Section VI.A.1 of the NRC Enforcement Policy, this violation is being cited in

the Notice because it involved the acts of a licensee official.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response, in part, to

determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response, if you choose to provide one, will be made available electronically

for public inspection in the NRC Public Document Room or from the NRCs document system

(ADAMS), accessible from the NRC website at www.nrc.gov/reading-rm/adams.html. To the

extent possible, your response should not include any personal privacy, proprietary, or safeguards

information so that it can be made available to the Public without redaction.

Sincerely,

/RA/

Roy Caniano, Director

Division of Reactor Safety

Docket: 50-397

License: NPF-21

Enclosure: Notice of Violation

cc w/enclosure:

Chairman

Energy Facility Site Evaluation Council

P.O. Box 43172

Olympia, WA 98504-3172

Energy Northwest -3-

EA-08-145

Gregory V. Cullen

Manager, Regulatory Programs

Energy Northwest

P.O. Box 968, Mail Drop PE20

Richland, WA 99352-0968

Chairman

Benton County Board of Commissioners

P.O. Box 190

Prosser, WA 99350-0190

William A. Horin, Esq.

Winston & Strawn

1700 K Street, NW

Washington, DC 20006-3817

Matt Steuerwalt

Executive Policy Division

Office of the Governor

P.O. Box 43113

Olympia, WA 98504-3113

Lynn Albin

Washington State Department of Health

P.O. Box 7827

Olympia, WA 98504-7827

Technical Services Branch Chief

FEMA Region X

130 228th Street S.W.

Bothell, WA 98201-9796

Ken Niles

Assistant Director

Nuclear Safety and Energy Siting Division

Oregon Department of Energy

625 Marion Street NE

Salem, OR 97301-3742

Special Hazards Program Manager

Washington Emergency Management Division

127 W. Clark Street

Pasco, WA 99301

Energy Northwest -4-

EA-08-145

Mike Hammond

Department of Homeland Security

FEMA/REP

130 228th Street S.W.

Bothell, WA 98201-9796

Energy Northwest -5-

EA-08-145

Electronic distribution by RIV:

DRS Deputy Director (Troy.Pruett@nrc.gov)

Senior Resident Inspector (Zachary.Dunham@nrc.gov)

Branch Chief, DRP/A (Claude.Johnson@nrc.gov)

Senior Project Engineer, DRP/A (Thomas.Farnholtz@nrc.gov)

Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)

J. Adams, OEDO RIV Coordinator (John.Adams@nrc.gov)

P. Lougheed, OEDO RIV Coordinator (Patricia.Lougheed@nrc.gov)

ROPreports

Columbia Site Secretary (Crystal.Myers@nrc.gov)

Electronic distribution by RIV:

RIDSOEMAILCENTER

RIDSNRROD

Regional Administrator (EEC) Nick.Hilton@nrc.gov Russ.Barnes@nrc.gov

DRP Director (DDC) R4ALLEGATION Karla.Fuller@nrc.gov

DRS Director (RJC1) David.Furst@nrc.gov Stewart.Magruder@nrc.gov

DRS STA (DAP) Bill.Maier@nrc.gov Douglas.Starkey@nrc.gov

Anton.Vegel@nrc.gov John.Wray@nrc.gov Christi.Maier@nrc.gov

Michael.Shannon@nrc.gov Micharel.Vasquez@nrc.gov Cynthia.Carpenter@nrc.gov

Crystal.Holland@nrc.gov Victor.Dricks@nrc.gov Alexander.Sapountzis@nrc.gov

Marissa.Herrera@nrc.gov MaryAnn.Ashley@nrc.gov

SUNSI Review Completed: ___MPS ADAMS: 7 Yes No Initials: __MPS____

7 Publicly Available Non-Publicly Available Sensitive 7 Non-Sensitive

HP:PSB C:PSB ACES C:PBA

DLStearns:lar MPShannon GMVasquez CEJohnson

/RA/ /RA/ /RA/ /RA/

5/19/08 5/20/08 5/30/08 6/2/08

OE D:DRS

NHilton RJCaniano

ASapountzis for /RA/

6/2/08 6/5/08

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

NOTICE OF VIOLATION

Energy Northwest Docket No. 50-397

Columbia Generating Station License No. NPF-21

EA-08-145

During an NRC investigation and subsequent in-office inspection completed on May 13, 2008, a

violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy,

the violation is listed below:

Technical Specification 5.4.1.a states, that written procedures shall be established,

implemented, and maintained covering the applicable procedures recommended in

Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33,

Appendix A, Section 7.e (1), specifies procedures for Access Control to Radiation Areas

Including a Radiation Work Permit System.

Columbia Generating Station Procedure GEN-RPP-04, Entry into, Conduct in, and Exit

from Radiologically Controlled Areas, Revision 14, states, in part, Do not reach over, or

cross contaminated area boundaries without RP approval.

Contrary to the above, during repair of the HPCS-P-1 flange on June 16, 2007, a project

manager instructed plant workers to reach across a contamination boundary without

radiation protection approval.

This is a Severity Level IV violation. (Supplement IV)

Pursuant to the provisions of 10 CFR 2.201, Energy Northwest is hereby required to submit a

written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document

Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator,

Region IV, and a copy to the NRC Resident Inspector at the facility that is the subject of this

Notice of Violation, within 30 days of the date of the letter transmitting this Notice. This reply

should be clearly marked as a "Reply to a Notice of Violation, EA-08-145," and should include:

(1) the reason for the violation, or, if contested, the basis for disputing the violation or severity

level, (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. Your response may reference or include previously docketed correspondence, if the

correspondence adequately addresses the required response. If an adequate reply is not

received within the time specified in this Notice, an Order or a Demand for Information may be

issued as to why the license should not be modified, suspended, or revoked, or why such other

action as may be proper should not be taken. Where good cause is shown, consideration will

be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

-1- Enclosure

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRCs document system (ADAMS), accessible from the

NRC website at www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not

include any personal privacy, proprietary, or safeguards information so that it can be made

available to the public without redaction. If personal privacy or proprietary information is

necessary to provide an acceptable response, then please provide a bracketed copy of your

response that identifies the information that should be protected and a redacted copy of your

response that deletes such information. If you request withholding of such material, you must

specifically identify the portions of your response that you seek to have withheld and provide in

detail the bases for your claim of withholding (e.g., explain why the disclosure of information will

create an unwarranted invasion of personal privacy or provide the information required by

10 CFR 2.390(b) to support a request for withholding confidential commercial or financial

information). If safeguards information is necessary to provide an acceptable response, please

provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you are required to post this Notice of Violation within two

working days.

Dated this 5th day of June 2008

-2- Enclosure