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EA-01-236 - Columbia Generating Station
(Energy Northwest)
December 28, 2001
EA-01-236
Mr. J. V. Parrish
Chief Executive Officer
Energy Northwest
P. O. Box 968; MD 1023
Richland, Washington 99352-0968
| SUBJECT: |
FINAL SIGNIFICANCE DETERMINATION FOR A YELLOW FINDING
AND NOTICE OF VIOLATION (NRC Inspection Report No. 50-397/01-008) |
Dear Mr. Parrish:
The purpose of this letter is to provide you with the final results of
our significance determination of the preliminary Yellow finding identified
in the subject inspection report. Our preliminary findings were discussed
with your staff during an exit briefing conducted on September 24, 2001.
The inspection findings were assessed using the significance determination
process and were preliminarily characterized as Yellow (i.e., an issue
with substantial importance to safety that will result in additional NRC
inspection and potentially other NRC action). This Yellow finding involved
the apparent failure to meet the requirements of 10 CFR 50.54(q) in that
Columbia Generating Station (CGS) did not follow and maintain emergency
plans and procedures which met the emergency planning standards in 10
CFR 50.47(b)(10). Specifically, the finding involved a failure to provide
a range of protective actions for certain members of the public, i.e.,
employees of companies that leased buildings within the CGS exclusion
area boundary.
At your request, a Regulatory Conference was held on November 26, 2001,
to further discuss your views on this issue. During the conference, your
staff described your assessment of the significance of the findings, your
evaluation of each of the inspection report concerns, and your position
on whether a violation of NRC requirements occurred. Specifically, your
position was that you had not violated 10 CFR 50.54(q) and 10 CFR 50.47(b)(10)
in that Energy Northwest: had plans and procedures that described a process
for notifying the lessees via telephone and sirens; had the ability to
implement protective actions for the lessees; and had provisions for radiological
monitoring of these lessees. Energy Northwest also stated its belief that
a violation of NRC requirements had occurred, although not described in
the NRC's inspection report. Specifically, Energy Northwest indicated
that initial notification of essentially 100 percent of personnel during
off-hours may not have been completed within 15 minutes as required by
the CGS Emergency Plan. Energy Northwest stated its belief that this violation
would have very low safety significance (green), if evaluated under the
NRC's significance determination process. Energy Northwest also identified
two weaknesses: (1) CGS had not confirmed that the lessees provided emergency
response information to their employees, and (2) CGS had not provided
these lessee employees additional written information in advance on evacuation
routes and assembly areas, a factor which could have delayed evacuation.
During the regulatory conference, Energy Northwest also introduced certain
information which had not been previously discussed with the NRC and was
not documented in the NRC's inspection report, but which is pertinent
to the NRC's final significance determination. This included the following
information: (1) The Crossroads Siren was inoperable between January 1997
and March 1998; (2) Some of the emergency response actions that Energy
Northwest described at the conference were contained in the WNP-1 Construction
Site Emergency Evacuation and Response Plan and the Site Wide Instructions.
However, this information was not contained or referenced in the CGS Emergency
Plan nor its emergency plan implementing procedures and thus was not subject
to periodic reviews, routine exercises, and submittal to the NRC for review;
and (3) The WNP-1 Designated Site Authority maintained a call list which
would have been used to notify lessees in an emergency.
After considering the information developed during the inspection, and
the information you provided at the conference, the NRC has concluded
that the inspection finding is appropriately characterized as Yellow.
The NRC acknowledges that you had established some measures to provide
for protective actions for members of the public who were employed by
lessees within the exclusion area boundary of CGS. However, our conclusion
is that these measures were not sufficiently comprehensive and were not
sufficiently planned or established to meet the standard of providing
a range of protective actions for these members of the public who were
routinely working in your exclusion area boundary. Therefore, we have
concluded that CGS violated 10 CFR 50.54(q) and emergency planning standard
10 CFR 50.47(b)(10). The bases for our conclusions are as follows:
| (1) |
Regarding the establishment of a means and time required
to warn or advise lessees of an emergency, you stated that notification
to lessees of an exclusion area evacuation was accomplished by multiple
parallel processes, including sirens, other notification processes
(Gaitronics, plant paging system, and Energy Northwest radio systems),
systems sweeps by CGS security personnel, telephone notification (via
call-trees initiated by the WNP-1 Designated Site Authority), and
a sign posted on the access road. You also stated that the exclusion
area sirens were reliable as demonstrated by successful periodic and
annual siren tests.
In reviewing the process you described, we note the following:
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- Your siren test data indicated that the notification sirens
could not be reliably heard indoors at some lessee locations;
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- The primary siren (the Crossroads Siren) was inoperable between
January 1997 and March 1998, and some lessee employees were working
in the exclusion area boundary during several months of this period;
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- The other notification processes (Gaitronics, plant paging system,
and Energy Northwest radio systems) did not apply to lessees;
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- The evacuation sign on the access road entering the site was
ineffective because several of the lessee employees interviewed
by the NRC were unfamiliar with the response to the siren;
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- The Designated Site Authority call-tree system was not proceduralized
and was flawed because it relied on someone answering a specific
telephone in the lessee's office; and
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- The security sweeps were unreliable because the specific details
of how the sweeps would be conducted (e.g., look for cars, knock
on doors) was not proceduralized, the specific locations of occupied
spaces were not identified, there was little to no training on
the process and the effectiveness of the security sweeps had not
been tested by drills or other means.
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Therefore, the NRC has concluded that you had not developed an adequate
means and time required to warn or advise these members of the public
of an emergency.
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| (2) |
Regarding the establishment of evacuation routes and transportation
to some suitable offsite location for lessee employees, you stated
that all lessee company officials were provided the WNP-1 Construction
Site Emergency Evacuation and Response Plan and that site evacuation
routes were established in the CGS Emergency Plan. You also stated
that although these routes were not communicated to lessees in advance,
a situation-specific route would be selected by the Emergency Director
and communicated to evacuees, as required, via security officers who
would be assigned to establish a roadblock.
In reviewing the process you described, we note the following:
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- Lessees were not provided the CGS Emergency Plan;
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- Neither lessee company officials nor Energy Northwest personnel
trained many of the lessee employees on the WNP-1 Construction
Site Emergency Evacuation and Response Plan or the CGS Emergency
Plan;
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- At least one lessee manager believed that the WNP-1 Construction
Site Emergency Evacuation and Response Plan was no longer in effect;
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- Energy Northwest employees and contractors were provided site
training which included evacuation route information while lessee
employees were not;
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- CGS personnel designated to act as Emergency Directors were
not trained about the presence of lessees in the exclusion area
and therefore could have been unaware of a need to ensure their
evacuation (at least one Emergency Director was unaware of their
presence);
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- There were circumstances under which a roadblock by site security
personnel would not be established on plant access roads, such
as a radiological release in that direction;
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- A reliance on communicating evacuation route and assembly information
at a single roadblock could create a significant impediment to
the timely evacuation of the overall exclusion area.
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We conclude that CGS had not sufficiently communicated information
about expected evacuation routes and transportation to lessee employees
in advance of an emergency (to at least the level of information provided
to residents living within the emergency planning zone), and that
CGS lacked reliable methods to ensure timely notification to lessee
employees of situation-specific evacuation information. Therefore,
the NRC has concluded that you had not made adequate provisions for
evacuation routes and transportation to some suitable offsite location
for these members of the public.
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| (3) |
Regarding the provision of radiological monitoring of people evacuated
from the site and a decontamination capability at the monitoring location,
you stated that the WNP-1 Construction Site Emergency Evacuation and
Response Plan did not distinguish between those actions taken for
Energy Northwest personnel and those for lessees, and that lessees
would be monitored (and if necessary decontaminated) at the Energy
Northwest Office Complex in Richland. The CGS Emergency Plan, Revision
28, stated that during an exclusion area evacuation, non-essential
personnel would be evacuated to the Energy Northwest Office Complex
and personnel assigned emergency functions would proceed to their
assigned emergency center(s).
In reviewing the process you described, we note the following:
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- Energy Northwest employees and contractors were provided site
training which included the location and function of offsite assembly
areas, but comparable training was not provided to lessee employees;
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- Lessee employees who were interviewed did not understand that
Energy Northwest was responsible for radiological monitoring and
were not aware of the location or function of the Energy Northwest
Office Complex;
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- The WNP-1 Construction Site Emergency Evacuation and Response
Plan did not address radiological monitoring for any exclusion
area evacuees; and
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- The CGS emergency response organization was not trained about
the presence of lessees in the exclusion area and therefore could
have been unaware of a need to direct them to the Energy Northwest
Office Complex for monitoring, and to monitor and decontaminate
them once they arrived at the assembly location.
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Therefore, the NRC has concluded that you had not developed provisions
for the radiological monitoring and decontamination of these members
of the public.
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You have 10 business days from the date of this letter to appeal the
staff's determination of significance for the identified Yellow finding.
Such appeals will be considered to have merit if they meet the criteria
given in NRC Inspection Manual Chapter 0609, Attachment 2.
The violation of the requirements of 10 CFR 50.54(q) and emergency planning
standard 10 CFR 50.47(b)(10) is cited in the attached Notice of Violation
(Notice). In accordance with the NRC Enforcement Policy, the Notice is
considered escalated enforcement action because it is associated with
a Yellow finding.
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.
Because plant performance for this issue has been determined to be in
the degraded cornerstone column, we will use the NRC Action Matrix to
determine the most appropriate NRC response for this finding. We will
notify you by separate correspondence of that determination.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy
of this letter and its enclosures will be available electronically for
public inspection in the NRC Public Document Room or from the Publicly
Available Records (PARS) component of NRC's document system (ADAMS). ADAMS
is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
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Sincerely,
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/Thomas P. Gwynne for/
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Ellis W. Merschoff
Regional Administrator |
Docket: 50-397
License: NPF-21
Enclosure: As stated
cc (w/enclosure):
Chairman
Energy Facility Site Evaluation Council
P.O. Box 43172
Olympia, Washington 98504-3172
Rodney L. Webring (Mail Drop PE08)
Vice President, Operations Support/PIO
Energy Northwest
P.O. Box 968
Richland, Washington 99352-0968
Greg O. Smith (Mail Drop 927M)
Vice President, Generation
Energy Northwest
P.O. Box 968
Richland, Washington 99352-0968
D. W. Coleman (Mail Drop PE20)
Manager, Regulatory Affairs
Energy Northwest
P.O. Box 968
Richland, Washington 99352-0968
Albert E. Mouncer (Mail Drop 1396)
General Counsel
Energy Northwest
P.O. Box 968
Richland, Washington 99352-0968
Paul Inserra (Mail Drop PE20)
Manager, Licensing
Energy NorthwestL
P.O. Box 968
Richland, Washington 99352-0968
Thomas C. Poindexter, Esq.
Winston & Strawn
1400 L Street, N.W.
Washington, D.C. 20005-3502
Bob Nichols
State Liaison Officer
Executive Policy Division
Office of the Governor
P.O. Box 43113
Olympia, Washington 98504-3113
Lynn Albin
Washington State Department of Health
P.O. Box 7827
Olympia, WA 98504-7827
NOTICE OF VIOLATION
Energy Northwest
Columbia Generating Station |
Docket No. 50-397
License No. NPF-21
EA-01-236 |
During an NRC inspection conducted on July 23-27, 2001, a violation of
NRC requirements was identified. In accordance with the "General Statement
of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the
violation is listed below:
10 CFR 50.54(q) states, in part, that a licensee authorized
to possess and operate a nuclear power reactor shall follow and maintain
in effect emergency plans which meet the standards in 50.47(b). 10 CFR
50.47(b)(10) requires that the onsite emergency response plans for nuclear
power reactors must meet the following standard, which states, in part:
"A range of protective actions have been developed for the plume exposure
pathway emergency planning zone for emergency workers and the public.
Guidelines for the choice of protective actions during an emergency, consistent
with Federal guidance, are developed and in place."
The Federal guidance is contained in NUREG-0654, FEMA-REP-1, "Criteria
for Preparation and Evaluation of Radiological Emergency Response Plans
and Preparedness in Support of Nuclear Power Plants." Section J provides
the evaluation criteria for this planning standard. Section J.1 states,
in part, that the licensee shall establish the means and time required
to warn or advise onsite individuals and individuals who may be in areas
controlled by the operator. Section J.2 states, in part, that the licensee
shall make provisions for evacuation routes and transportation for onsite
individuals to some suitable offsite location, including alternatives
for inclement weather and specific radiological conditions. Section J.3
states, in part, that each licensee shall provide for radiological monitoring
of people evacuated from the site. Section J.4 states, in part, that each
licensee shall provide a decontamination capability at or near the monitoring
point specified in Section J.3.
Contrary to the above, from October 14, 1997, to July 23, 2001, a range
of protective actions for certain members of the public within Columbia
Generating Station's plume exposure pathway emergency planning zone had
not been developed. Specifically, the licensee had not developed a range
of protective actions for employees of private businesses leasing space
within the licensee's exclusion area which were consistent with Federal
guidance, as described below.
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- The licensee had not adequately developed the means and time
required to warn or advise lessee employees by activation of a
reliable notification system. Specifically, the licensee's sirens
could not be heard indoors at some lessee sites, and the crossroads
siren (the primary siren for that area) was unavailable between
October 1997 and March 1998 while lessee employees were onsite.
In addition, other licensee notification processes did not apply
to lessees, an evacuation sign was not effective based on the
fact that several lessee employees were unfamiliar with the response
to the siren, the telephone notification would not be fully effective
during off-hours because it relied on someone being near the phone
that was called, and mobile patrol security sweeps would not be
fully effective during off-hours because of the lack of training
and procedures.
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- The licensee had not adequately developed the means for evacuation
routes and transportation to some suitable offsite location. Specifically,
many lessee employees had not been trained on the WNP-1 Construction
Site Emergency Evacuation and Response Plan or the evacuation
routes established in the CGS Emergency Plan, CGS personnel designated
to act as the Emergency Directors were not trained about the presence
of the lessee employees in the exclusion area boundary, and the
licensee's dependence on security officers, who would be assigned
to a roadblock, would not be fully effective in informing lessee
employees of situation-specific evacuation routes because roadblocks
would not be established if a radiological release affected the
plant access roads.
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- The licensee had not adequately developed the means for radiological
monitoring of people evacuated from the site and a decontamination
capability at the monitoring location. Specifically, lessee employees
had not been trained on the CGS Emergency Plan and were unaware
of the location and function of offsite assembly areas, including
radiological monitoring and decontamination capabilities. Many
lessee employees who were interviewed did not understand that
Energy Northwest was responsible for radiological monitoring.
The WNP-1 Construction Site Emergency Evacuation and Response
Plan did not address radiological monitoring for lessee evacuees,
and the CGS emergency response organization was not trained about
the presence of lessee employees in the exclusion area boundary.
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This violation is associated with a Yellow Significance Determination
Process finding. |
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
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,
within 30 days of the date of the letter transmitting this Notice of Violation
(Notice). This reply should be clearly marked as a "Reply to a Notice
of Violation" 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 previous 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.
Because your response will be made available electronically for public
inspection in the NRC Public Document Room or from the Publicly Available
Records (PARS) component of NRC's document system (ADAMS), 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. ADAMS is accessible from the NRC Web site at the Public
Electronic Reading Room, http://www.nrc.gov/reading-rm/adams.html .
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 2.790(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.
Dated this 28th day of December 2001
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