GO2-23-090, Reply to a Notice of Violation
| ML23193B032 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/12/2023 |
| From: | David Brown Energy Northwest |
| To: | NRC Region 4, Document Control Desk |
| References | |
| GO2-23-090, IR 2023090 EA-21-170 | |
| Download: ML23193B032 (1) | |
Text
David P. Brown Site Vice President P.O. Box 968, PE23 Richland, WA 99352-0968 Ph. 509-377-8385 F. 509-377-4150 dpbrown@energy-northwest.com July 12, 2023 GO2-23-090 10 CFR 2.201 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 REPLY TO A NOTICE OF VIOLATION; EA-21-170
Reference:
Letter from R Lewis (NRC) to R Schuetz (Energy Northwest), Columbia Generating Station - Final Significance Determination of a White Finding, Notice of Violation and Follow-Up Assessment Letter; NRC Inspection Report 05000397/2023090, ML23111A237, dated June 1, 2023.
Dear Sir or Madam:
As required by 10 CFR 2.201, this letter provides Energy Northwests reply to Notice of Violation EA-21-170 cited in the Nuclear Regulatory Commission (NRC) inspection report (Reference). The response for the first violation, as described in the enclosure, includes the reason for the violation, the corrective steps that have been taken and the results achieved, the corrective steps that will be taken, and the date when full compliance was achieved.
Per telecon with the NRC Region IV on July 6, 2023, Energy Northwest will supplement this letter with information from a secondary Root Cause for the other two noted violations which is currently underway. The supplemental letter will be submitted on or before July 27, 2023.
ENERGY NORTHWEST
GO2-23-090 Page 2 of 2 There are no commitments being made to the NRC by this letter. Should you have any questions, please contact IR Bitner, Regulatory Compliance Supervisor, at (509) 377-4204.
Executed lhis lz-thday of Jul;
, 2023
- fully, David P. Brown Site Vice President
Enclosure:
Reply to EA-21-170 Notice of Violation cc:
NRC Director-Division of Operating Reactor Safety, Region IV NRC Region IV Administrator NRC NRR Project Manager NRC Resident lnspector/988C NRC Enforcement, Region IV CD Sonoda - BPA/1399 w/o enclosure
GO2-23-090 Enclosure Columbia Generating Station - Energy Northwest Reply to EA-21-170 Notice of Violation
GO2-23-090 Enclosure Page 2 of 6 Energy Northwest accepts these violations. Energy Northwest has taken prompt action to return to full compliance and has implemented comprehensive corrective actions for long-term sustained compliance related to the violation of 10 CFR 20.1701 and is currently conducting a Root Cause to better evaluate the violations of Technical Specification 5.7.2.b and 10 CFR 20.1501(a)(2). Energy Northwest will submit a supplement to this letter with information pertaining to these violations on or before July 27, 2023.
Nuclear Regulatory Commission (NRC) letter dated June 1, 2023, cited three violations of NRC requirements. Responses required by the letter are below.
A. Violation of 10 CFR 20.1701 Notice of Violation From NRC letter dated June 1, 2023:
10 CFR 20.1701 requires, in part, that the licensee shall use, to the extent practical, process or other engineering controls to control the concentration of radioactive material in air.
Contrary to the above, on May 28, 2021, the licensee failed to use, to the extent practical, process or other engineering controls to control the concentration of radiation material in air. Specifically, the licensee did not properly plan for the use of engineering controls with enough specificity in accordance with station procedures (i.e., procedure HPI-12.90, Contamination Control Containment Devices) to ensure proper control for installation and removal of the glove bag, which is used to prevent airborne contamination. The failure to ensure proper control of the glove bag resulted in an airborne contamination event that caused two individuals to receive internal doses of greater than 700 millirem committed effective dose equivalent.
Reason for Violation The root cause of the violation was determined to be that radiological risk for the work was evaluated by staff presupposing the successful use of engineering controls to mitigate radiological hazards and didnt evaluate or recognize the overall risk associated with the work being performed or potential consequences of engineering control failure or incorrect use. The direct cause was improper setup, use (without High-Efficiency Particulate Air [HEPA] vacuum), and removal of a glove bag (engineering control) while performing pipe preparation activities.
Contributing causes included the station procedure for glove bag use was not used and individuals working nightshift did not perform an effective mockup using the glove bag.
GO2-23-090 Enclosure Page 3 of 6 Corrective Steps and Results Achieved Immediate actions taken include:
- A formal stop work order was issued for the evolution, and the entire project team conducted a stand down to discuss the event (including immediate lessons learned).
- A prompt Human Performance event investigation was performed, and individuals involved in the event were interviewed.
- The Radiation Work Permit (RWP) was revised to require respirators to be worn during pipe preparations for the remaining two pipe weld preparations.
- The dayshift Radiation Protection Technicians were tasked to prepare, install, and remove the glove bags since they were more proficient with glove bag use.
- Prior to the restart of pipe preparations an implementation plan was developed to ensure the preparation of the remaining cut locations were prepared with proper, approved engineering controls in place and that the room be free from unrelated personnel during the work.
Additional actions taken include:
- The station Health Physics Instruction HPI-12.90, Contamination Control Containment Devices was updated to add a requirement for just-in-time-training via mockup, a formal written plan, and a verification that the correct breather filter is installed when using a glove bag as a containment device.
- The station Plant Procedure Manual 11.2.8.2, Radiation Work Permit Preparation and Use was revised to include a hold point when glove bags are used to control the spread of radioactivity to the air as well as require size and type of glove bag to be specified as part of the RWP.
- The station Plant Procedure Manual 11.2.2.12, Radiological Risk Assessment and Management was updated to determine initial risk assuming no elimination or mitigation actions, define risk mitigation and risk elimination actions, and only allow the risk categorization to credit an action that eliminates the risk.
- Gap training was performed for qualified individuals and Radiation Protection (RP) supervisors on the revised Radiological Risk Assessment and Management procedure.
GO2-23-090 Enclosure Page 4 of 6
- Form 26840, Radiological Risk Assessment Checklist was revised to to make abrasive work on highly contaminated surfaces (i.e., >100 mrad/hr/100 cm2) high radiological risk.
- The station Health Physics Instruction HPI-0.41, Expectations for Radiological Job Coverage was revised to include RP responsibilities for installation and removal of containment devices.
- Gap training for as low as reasonably achievable (ALARA) Planners was given to include key references (i.e., procedure numbers, forms, etc.) in the ALARA plan.
Corrective Steps that Will be Taken An effectiveness review of the actions taken is currently targeted for completion on August 25, 2023.
Date of Full Compliance Full compliance with 10 CFR 20.1701 was achieved upon completion of all actions, with the exception of the Effectiveness Review, under Condition Report 00428029 on December 28, 2022.
GO2-23-090 Enclosure Page 5 of 6 B. Violation of Technical Specification 5.7.2.b Notice of Violation From NRC letter dated June 1, 2023:
Technical Specification 5.7.2.b requires, in part, that access to, and activities in, each high radiation area with dose rates greater than 1.0 rem/hour at 30 centimeters from the radiation source shall be controlled by means of a radiation work permit.
Radiation work permit 30004732, created to control activities in a Technical Specification 5.7.2.b high radiation area, required, in part, that continuous Health Physics job coverage is provided when personnel are entering and working in areas with dose rates greater than 0.8 rem/hour.
Contrary to the above, on May 28, 2021, the licensee failed to control the activities in a high radiation area with dose rates greater than 1.0 rem/hour at 30 centimeters from the radiation source in accordance with radiation work permit 30004732. Specifically, the licensee failed to follow radiation work permit 30004732 and provide continuous Health Physics job coverage when personnel entered and worked in an area with dose rates greater than 0.8 rem/hour (i.e.,
1.3 rem/hour at 30 centimeters from the radiation source). A radiation protection technician, scheduled to provide the continuous Health Physics job coverage, was unable to physically fit on the work area platform and left the workers unattended in the area. A second radiation protection technician subsequently replaced the original technician as the workers were conducting job activities in the work area.
Reason for Violation Energy Northwest is currently performing a Root Cause to provide the requested information and will supplement this letter on or before July 27, 2023.
Corrective Steps and Results Achieved Energy Northwest is currently performing a Root Cause to provide the requested information and will supplement this letter on or before July 27, 2023.
Corrective Steps that Will be Taken Energy Northwest is currently performing a Root Cause to provide the requested information and will supplement this letter on or before July 27, 2023.
Date of Full Compliance Energy Northwest is currently performing a Root Cause to provide the requested information and will supplement this letter on or before July 27, 2023.
GO2-23-090 Enclosure Page 6 of 6 C. Violation of 10 CFR 20.1501(a)(2)
Notice of Violation From NRC letter dated June 1, 2023:
10 CFR 20.1501(a)(2) requires, in part, that licensees shall make surveys of areas that are reasonable under the circumstances to evaluate the magnitude and extent of radiation levels; and concentrations or quantities of residual radioactivity.
Contrary to the above, on May 27, 2021, the licensee failed to make surveys of areas that were reasonable under the circumstances to evaluate the magnitude and extent of radiation levels; and concentrations or quantities of residual radioactivity. Specifically, the licensee failed to adequately determine the work area radiation levels as documented in survey M-20210528-13, which stated, the survey was not an extensive search for the highest exposure rate. In addition, the licensee failed to adequately evaluate the extent of contamination levels on the piping prior to the work activity. The surveys completed prior to the event did not adequately identify work area dose rates and did not identify appropriate contamination levels, resulting in a lower risk rating to the job and less rigorous radiological controls for the activity.
Reason for Violation Energy Northwest is currently performing a Root Cause to provide the requested information and will supplement this letter on or before July 27, 2023.
Corrective Steps and Results Achieved Energy Northwest is currently performing a Root Cause to provide the requested information and will supplement this letter on or before July 27, 2023.
Corrective Steps that Will be Taken Energy Northwest is currently performing a Root Cause to provide the requested information and will supplement this letter on or before July 27, 2023.
Date of Full Compliance Energy Northwest is currently performing a Root Cause to provide the requested information and will supplement this letter on or before July 27, 2023.