UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

November 16, 2016

EA-16-173

EN 52090

Mr. Mike Annacone

Vice President, Columbia Fuel Operations

Westinghouse Electric Company

5801 Bluff Road

Hopkins, SC 29061

SUBJECT: NUCLEAR REGULATORY COMMISSION CONFIRMATORY ACTION LETTER 

INSPECTION REPORT NO. 70-1151/2016-008

Dear Mr. Annacone:

On October 19, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed inspections of 

those commitments required for restart of specified equipment, made by Westinghouse Electric 

Company, Columbia Fuel Fabrication Facility (CFFF) in a letter from David J. Precht dated

August 9, 2016 (ML16223A003). This letter was written in response to the uranium buildup 

reported to the NRC in July 2016 (EN 52090). The inspections were conducted to ensure that 

the causes of the uranium buildup had been adequately identified and evaluated, and that 

appropriate corrective actions had been implemented prior to restart of conversion area 

equipment and the S-1030 scrubber. The enclosed report (Enclosure 1) documents the 

inspection results which were discussed with you and other members of your staff during an exit 

meeting on October 19, 2016.

On July 14, 2016, Westinghouse reported to the NRC that it had exceeded the uranium mass 

limit for the S-1030 scrubber transition section determined in the criticality safety evaluation. 

The uranium was discovered in the scrubber transition section during a required annual 

cleanout in May 2016. On July 31, 2016, Westinghouse updated their report to the NRC 

indicating that the S-1030 scrubber packing section had also exceeded the uranium mass limit. 

On July 28, 2016, the NRC charted an augmented inspection team (AIT) to review the facts and 

circumstances surrounding the uranium buildup. The AIT completed its inspection on 

September 2, 2016, and the results are documented in inspection report 70-1151/2016-007 (ML 

16211A001).

On August 11, 2016, the NRC issued a Confirmatory Action Letter (CAL) (ML16224B082) to 

confirm commitments by Westinghouse to take certain actions prior to restart of the S-1030 

scrubber system and conversion process equipment at the CFFF. In addition, the CAL 

identified other long term corrective actions not necessary for a safe restart. The actions 

documented in the CAL were intended to ensure that the root causes of the event which 

occurred in May 2016 were adequately evaluated, and that appropriate corrective actions were 

implemented before resumption of operations. 
M. Annacone 2

The objective of the CAL restart inspections was to verify that those CAL commitments required 

prior to restart of the S-1030 scrubber system and conversion process equipment were 

completed, and ensure the actions taken by Westinghouse provided reasonable assurance of 

Westinghouse’s ability to safely operate the CFFF. From September 7 to October 19, 2016, the 

NRC conducted inspections of those CAL items designated as actions required prior to restart. 

Additional NRC inspections will continue until all remaining CAL items are completed. The 

enclosure to the CAL which contains those commitments is contained in Enclosure 2 of this 

report.

By letter dated October 19, 2016 (ML16293A175), Westinghouse requested to restart 

conversion area process equipment and the S-1030 scrubber system. In that letter, 

Westinghouse stated that CAL items (1) through (4) were completed, that all specified restart 

activities had been completed, and that any compensatory measures instituted as part of those 

CAL items were to remain in place until the required permanent corrective actions are 

completed. Pursuant to the terms of the CAL, Westinghouse was given written consent 

(ML16294A296) for restart of conversion process equipment and the S-1030 scrubber system. 

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice and Procedure," 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).

If you have any questions on this matter, please contact Tom Vukovinsky, Projects Branch 2, at 

404-997-4622.

Sincerely,

/RA/

Eric C. Michel, Chief

Projects Branch 2

Division of Fuel Facility Inspection

Docket No. 70-1151

License No. SNM-1107

Enclosures: 

1. NRC Inspection Report 70-1151/2016-008

 w/Supplemental Information

2. Westinghouse Electric Company Commitments

cc: (See page 3)
M. Annacone 2

The objective of the CAL restart inspections was to verify that those CAL commitments required 

prior to restart of the S-1030 scrubber system and conversion process equipment were 

completed, and ensure the actions taken by Westinghouse provided reasonable assurance of 

Westinghouse’s ability to safely operate the CFFF. From September 7 to October 19, 2016, the 

NRC conducted inspections of those CAL items designated as actions required prior to restart. 

Additional NRC inspections will continue until all remaining CAL items are completed. The CAL 

is contained in Enclosure 2.

By letter dated October 19, 2016 (ML16293A175), Westinghouse requested to restart 

conversion area process equipment and the S-1030 scrubber system. In that letter, 

Westinghouse stated that CAL items (1) through (4) were completed, that all specified restart 

activities had been completed, and that any compensatory measures instituted as part of those 

CAL items were to remain in place until the required permanent corrective actions are 

completed. Pursuant to the terms of the CAL, Westinghouse was given written consent 

(ML16294A296) for restart of conversion process equipment and the S-1030 scrubber system. 

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice and Procedure," 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).

If you have any questions on this matter, please contact Tom Vukovinsky, Projects Branch 2, at 

404-997-4622.

Sincerely,

/RA/

Eric C. Michel, Chief

Projects Branch 2

Division of Fuel Facility Inspection

Docket No. 70-1151

License No. SNM-1107

Enclosure: 

1. NRC Inspection Report 70-1151/2016-008

 w/Supplemental Information

2. Westinghouse CAL restart commitments

cc: (See page 3)

PUBLICLY AVAILABLE NON-PUBLICLY AVAILABLE SENSITIVE NON-SENSITIVE

ADAMS: Yes ACCESSION NUMBER: ML16323A011 SUNSI REVIEW COMPLETE FORM 665 ATTACHED

OFFICE RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

NAME TVukovinsky JMunson BAdkins LPitts DMorgan KKirchbaum

DATE 11/16/2016 11/15/2016 11/15/2016 11/15/2016 11/15/2016 11/15/2016

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO

OFFICIAL RECORD COPY DOCUMENT NAME: G:\DFFI\REPORTS\FINAL 

REPORTS\WESTINGHOUSE\2016\IR 2016008.DOCX
M. Annacone 3

cc: 

John Howell

Manager

Environment, Health and Safety

Electronic Mail Distribution

Nancy Parr

Manager

Licensing

Electronic Mail Distribution

Christine Kneece

Manager

Industrial Safety

Electronic Mail Distribution

Susan E. Jenkins

Assistant Director, Division of Waste Management

Bureau of Land and Waste Management

Department of Health and Environmental Control

Electronic Mail Distribution
Letter to Mr. Mike Annacone from Eric C. Michel dated November 16, 2016

SUBJECT: NUCLEAR REGULATORY COMMISSION CONFIRMATORY ACTION LETTER 

INSPECTION REPORT NO. 70-1151/2016-008

DISTRIBUTION:

M. Lesser, RII

E. Michel, RII

T. Vukovinsky, RII

P. Startz, RII

M. Kotzolas, NMSS

R. Johnson, NMSS

C. Ryder, NMSS

M. Baker, NMSS 

PUBLIC
U. S. NUCLEAR REGULATORY COMMISSION

REGION II

CONFIRMATORY ACTION LETTER RESTART INSPECTIONS

Docket No.: 70-1151

License No.: SNM-1107

Report No.: 70-1151/2016-008

Licensee: Westinghouse Electric Company

Facility: Columbia Fuel Fabrication Facility 

Location: Hopkins, SC 29061

Dates: September 7 through October 19, 2016

Inspectors: B. Adkins – Senior Fuel Facility Inspector

L. Pitts – Senior Fuel Facility Inspector

T. Vukovinsky – Senior Fuel Facility Inspector

K. Kirchbaum – Fuel Facility Inspector

D. Morgan – Fuel Facility Inspector

J. Munson – Fuel Facility Inspector

Approved by: Eric C. Michel, Chief

Projects Branch 2

Division of Fuel Facility Insection

Enclosure 1
EXECUTIVE SUMMARY

Westinghouse Electric Company - Columbia Fuel Fabrication Facility

Nuclear Regulatory Commission Inspection Report 70-1151/2016-008

September 7 through October 19, 2016

The objective of the Confirmatory Action Letter (CAL) restart inspections was to verify the 

commitments made in the CAL required prior to restarting the S-1030 scrubber system and 

conversion process equipment were completed, and ensure the actions taken provided

reasonable assurance of Westinghouse’s ability to safely operate the Columbia Fuel Fabrication 

Facility (CFFF). 

CAL Restart Commitments

No violations of significance were identified during the CAL restart inspections. The Nuclear 

Regulatory Commission (NRC) concluded that the corrective actions implemented to date by 

Westinghouse are reasonable and have sufficient likelihood of being effective to support a 

determination that the conversion process equipment and S-1030 scrubber can be operated 

safely in accordance with the facility license. (Paragraph A)

Attachment:

Key Points of Contact

List of Items Opened, Closed, and Discussed 

Inspection Procedures Used

Documents Reviewed
REPORT DETAILS

The Westinghouse facility is located near Columbia, South Carolina, and is situated on a 1,151 

(approximate) acre site in Richland County, approximately eight miles southeast of the 

Columbia city limits, along State Highway 48 (Bluff Road). The facility fabricates fuel 

assemblies for pressurized water reactors and boiling water reactors using low enriched 

uranium (LEU). The facility uses a wet-chemical ammonium diuranate (ADU) process to

convert uranium hexafluoride (UF6) gas into uranium dioxide (UO2) powder. The process 

consists of hydrolyzing vaporized UF6 gas (which separates most of the fluorides from the 

uranium), and then precipitating the solution with ammonia followed by separation of liquid and 

solid phases. The solid phase (ADU) is then calcined and reduced to remove the ammonia and 

produce UO2 powder. The powder is then pressed into pellets and sintered. These processes 

are followed by fuel rod loading and sealing, and fuel assembly fabrication. Westinghouse also 

performs recovery/disposal operations of scrap fuel produced during the fabrication process. 

Recovery operations can process a variety of fuel forms from this process. 

Background:

On May 28 - 29, 2016, Westinghouse conducted a planned annual inspection and cleanout of 

the main conversion area scrubber (S-1030) and associated ventilation ductwork. The function 

of this scrubber is to remove gases and particulates from various exhaust streams associated 

with the uranium conversion process. During the cleanout, personnel noticed an abnormal 

amount of material buildup in the inlet transition region and associated ductwork (specifically an

elbow). Over the course of the two day maintenance evolution approximately 197 kilograms of 

material were removed from these two sections. These sections are not a favorable geometry 

from a nuclear criticality safety (NCS) perspective. Since the facility personnel were under the 

assumption that this material had a low uranium concentration, operators attempted to break up 

and wash away the material to facilitate its removal. The facility personnel did not sample the 

material to confirm the uranium concentration before conducting these activities. After the 

material was removed, grab samples of the material were taken and analyzed for uranium 

concentration. The grab sample results indicated that the uranium concentrations ranged from 

34wt% – 55wt%, which corresponded to approximately 87 kilograms of uranium. As such, the 

criticality safety evaluation mass limit of 29 kilograms was exceeded by a factor of 3.

After the cleanout activities were completed, the scrubber was restarted. The scrubber 

was in operation for a period of six weeks when the facility shutdown the scrubber to 

perform another cleanout of the inlet transition region and elbow. Facility personnel 

removed 24 kilograms of material which corresponded to approximately 5 kilograms of 

uranium. The scrubber was restarted again following the cleanout. Approximately one

week later, while discussing the extent of condition, the licensee decided to shut down the 

scrubber again, and thoroughly inspect the entire scrubber to ensure that it was free of 

uranium accumulation. An additional 184 kilograms of material was removed from the 

scrubber body, and about 71 kilograms of material was removed from the packing 

material. 

In this incident, the mass limit was exceeded by a factor of 3; moderation was available 

from the scrubber spray nozzles and the clean out process; and the scrubber packing, 

elbow, and transition region sections are all unfavorable geometries. As a result, the 
2

safety margin available to preclude an inadvertent criticality was significantly 

degraded. The scrubber was shut down and the licensee commenced extent of 

condition and root cause evaluations. There were no actual health consequences

to the public, workers, or the environment.

In response to this event, the NRC sent an augmented inspection team (AIT) to inspect and 

assess the facts and circumstances surrounding the uranium accumulation. The results of that 

inspection were documented in inspection report 70-1151/2016-007, and included four 

unresolved items: (1) failure to ensure criticality accident sequences remain highly unlikely, 

(2) failure to assure that under credible normal and abnormal conditions, all nuclear processes 

were subcritical including use of an approved margin of subcriticality, (3) failure to establish 

adequate management measures to ensure that IROFS to perform their function when needed, 

and (4) failure to make a 1 hour report.

Inspection Scope:

The objective of the Confirmatory Action Letter (CAL) restart inspections was to verify the 

commitments made in the CAL required prior to restarting the S-1030 scrubber system and 

conversion process equipment were completed, and ensure the actions taken provided

reasonable assurance of Westinghouse’s ability to safely operate the Columbia Fuel Fabrication 

Facility (CFFF). The inspection included a review of operating procedures, criticality safety 

evaluations (CSEs), integrated safety analyses (ISAs), configuration management and 

maintenance documents, modifications to the S-1030 scrubber system, training, and operational 

decision making. Areas examined during the inspection are identified in each charter item listed 

below. For each CAL restart commitment, the inspection consisted of a selective examination 

of procedures and records, interviews with personnel, and observation of activities to determine 

if they were in accordance with Nuclear Regulatory Commission (NRC) requirements and met 

the requirements for restart as identified in the CAL. 

A. Confirmatory Action Letter Restart Requirements (Inspection Procedure 92703)

1. CAL Item 1: Complete a Root Cause Analysis (RCA) investigation for this event. In 

accordance with the RCA Charter, the RCA will include an assessment of the nuclear 

safety culture (NSC) contributors to the event and identify necessary corrective actions 

to address gaps noted in the NSC at Columbia.

a. Inspection Scope and Observations

The inspectors reviewed the RCA for adequacy of scope, depth, identification of 

contributing causes, and proposed corrective actions. In addition to configuration 

management issues, the RCA identified that there was a long-standing weakness in 

the safety culture at Westinghouse. The inspectors performed their own “miniMORT” and arrived at similar conclusions regarding safety culture concerns as 

CFFF’s RCA. Corrective actions were identified by the RCA, including the need to 

develop a CFFF leadership assessment and coaching program. The inspectors 

noted that an employee-wide NCS survey had been performed and the survey 

results would provide input for site management to assess the safety culture at the 

site. 
3

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

2. CAL Item 2: If the RCA investigation identifies additional actions necessary to assure 

safe operations, then Westinghouse will revise its restart plan to include those actions. 

Additional immediate or compensatory actions will be identified and put in place for any 

corrective action to prevent recurrence that is not completed prior to restart.

a. Inspection Scope and Observations

The S-1030 Scrubber Event Recovery Plan (Recovery Plan) detailed the required 

restart actions as a result of the RCA and as required by the CAL. The RCA 

identified six corrective actions to prevent reoccurrences (CAPRs). Of these six 

CAPRs, three required interim compensatory measures to meet the restart 

requirements outlined in the CAL. The inspectors reviewed the interim corrective 

actions and noted that they met the requirements of the CAPRs as they pertain to 

the S-1030 scrubber system. Longer-term corrective actions to complete the 

remaining CAPRs are being tracked in Westinghouse’s corrective action program 

(CAP) and will be reviewed for completeness in subsequent NRC inspections.

Corrective actions to prevent recurrence for this event included: 

• Revision of the configuration control procedure to require up-front planning 

between project, area, and criticality safety engineering.

• Revisions of the electronic training system to implement a formal review for 

process changes with impact to safety aspects.

• Revision of the configuration control procedure to require an independent 

technical review if a system or component that is described in a CSE is 

modified.

• Conduct of a performance based assessment to identify needed 

improvements in design calculations and design packages.

• Revision of the S-1030 scrubber inspection and cleanout procedure to clearly 

specify the recording of data needed to confirm the effectiveness of IROFS in 

maintaining uranium mass below the limits and to provide clear guidance for 

timely review and evaluating the data.

• Development or revision of applicable procedures to identify personnel who 

need training on the safety basis for CSEs.

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

3. CAL Item 3.a: The design, operating and maintenance history of the S-1030 scrubber 

system, including changes to influents to the scrubber system, will be reviewed to 

understand the impacts on the mass build up noted in this event. Based upon this 

review, the safety basis for the scrubber system will be revised. 
4

a. Inspection Scope and Observations

The inspectors reviewed the operating and maintenance history of the S-1030 

scrubber to verify that the licensee understood the impacts and potential causes of 

the mass accumulation. The inspectors reviewed the revised NCS safety basis as 

well as physical modifications to limit future uranium (U) accumulations within the S1030 scrubber.

The inspectors reviewed the revised NCS safety basis for the S-1030 scrubber to 

verify that the licensee identified all normal and credible abnormal conditions, applied 

sufficient controls to limit the likelihood of criticality to “highly unlikely” and ensure 

subcriticality with an approved margin under these conditions, and applied sufficient 

factors of safety to ensure that at least two unlikely, independent, and concurrent 

changes in process conditions are required before criticality is possible. Additionally, 

the inspectors verified that no un-validated assumptions were present in the revised 

NCS safety basis.

The inspectors inspected the physical modifications made to the S-1030 scrubber, 

and evaluated the adequacy of the controls identified in the revised NCS safety 

basis, including both administrative and engineered controls, credited to limit the 

likelihood of inadvertent criticality. The administrative controls evaluated included:

• weekly visual inspection of the inlet transition under NCS oversight (VENTS1030-126)

• six week clean-out and mass quantification of the packing section under NCS 

oversight (VENT-S1030-127, 128, and 129)

• visual inspection of the spray nozzle pressure (VENT-S1030-105)

• control on the feed rate for the liquid blowdown system (VENT-S1030-147)

• periodic visual inspection and gamma survey of ductwork greater than 10 

inches in diameter (VENT-S1030-111 and VENT-901)

• weekly inspection of the differential pressure across the packing section 

(VENT-S1030-136)

• use of a filter in the Blue-M oven plenums capable of capturing at least 95% 

of any entrained U mass particulate (VENT-S-1030-130)

• feed and bleed system (VENT-S1030-141)

The engineered controls evaluated included the sizing and placement of the drains to 

ensure that a safe solution slab height is not exceeded (VENT-S1030-131 and 132). 

The inspectors reviewed the applied management measures to verify that they were 

adequate to maintain the availability and reliability of both administrative and 

engineered items relied on for safety (IROFS). The inspectors reviewed new and 

revised procedures and training to implement the administrative IROFS discussed 

above to verify that the IROFS could be effectively implemented as designed. The 

inspectors reviewed surveillance procedures and other applied management 

measures to ensure the availability and reliability of the associated engineered 

IROFS.
5

The inspectors observed the licensee’s newly developed training regarding new and 

revised controls applied to the S-1030 scrubber. This training included operatorspecific training, as well as training for management.

In addition to reviewing the revised NCS safety basis for the S-1030 scrubber, the 

inspectors reviewed new and revised NCS safety bases for various systems sitewide to verify that review and approval of corrective actions were performed by 

independent NCS experts, and that the licensee maintained external NCS oversight.

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

4. CAL item 3.a.i: Review and revise procedures that implement administrative IROFS to 

ensure administrative limits are properly defined and to ensure inspection methods that 

validate compliance to the administrative IROFS can be effectively implemented to meet 

its safety function.

a. Inspection Scope and Observations

The inspectors reviewed new and revised procedures and training to implement the 

administrative IROFS, described in CAL item 3.a above, to verify that the IROFS 

could be effectively implemented as designed. The inspectors reviewed surveillance 

procedures and other applied management measures to ensure the availability and 

reliability of engineered IROFS.

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

5. CAL item 3.a.ii: Review the adequacy of the management measures applied that 

support the availability and reliability of the administrative IROFS and correct any 

identified deficiencies.

a. Inspection Scope and Observations

The licensee conducted a focused self-assessment to evaluate whether the 

management measures and implementation controls were available and reliable as 

prescribed in the license application. The focus was on management measures 

supporting administrative IROFS, which included a review of procedure use and 

adherence related to the implementation of the safety basis. The inspectors 

reviewed the self-assessment and noted that it was led by an off-site independent 

team leader, and that the identified findings, deficiencies, and recommendations 

were being tracked in the licensee’s CAP for resolution. The inspectors noted that 

the licensee had expanded this CAL item beyond the ventilation system to include 

management measures applied to support the availability and reliability of IROFS 

throughout the facility.
6

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

6. CAL item 3.a.iii: Review and approval of the above actions and the identified corrective 

actions will be performed by independent criticality safety experts.

a. Inspection Scope and Observations

The inspectors noted that an independent criticality safety team reviewed all the 

revised CSEs and provided recommendations for improvement, which the licensee 

incorporated into the revised CSEs. The independent criticality safety team 

approved changes to the CSEs and management measures applied to ensure 

compliance with the safety basis.

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

7. CAL item 3.a.iv: Complete the installation of physical modifications needed to support 

the revised safety basis.

a. Inspection Scope and Observations

The inspectors reviewed the physical modifications needed to support the revised 

safety basis. The scope of the modifications included: 

• installation of a passive overflow

• existing drain line modifications

• installation of scrubber basket system

• installation of a scrubber liquid level alarm system

• scrubber blowdown line flow transmitter installation

• connection of sifter enclosures to Torit system

• new Blue M hood filters

• new scrubber inlet transition 

• new inlet transition spray header 

• scrubber spray pH display and trending

• scrubber spray makeup water level modifications

Specifically, the inspectors reviewed the Change Control Forms (CCFs) associated 

with the physical modifications to verify that the scope of the modifications was 

consistent with the requirements of the CSEs and ISA. The inspectors reviewed the 

CCFs to determine if they met the requirements of the licensee’s change control 

procedure. Specifically, the inspectors determined whether CCFs received proper 

review and approval by the Environmental, Safety, and Health (ES&H) organization, 

contained an adequate technical basis for the change, and contained pertinent 

design information and work instructions to implement the change. The inspectors 
7

reviewed the associated Title 10 of the Code of Federal Regulations (10 CFR) 70.72 

evaluations to determine if the licensee adequately reviewed the changes to 

determine if NRC pre-approval was required. 

The inspectors conducted walk downs to determine if the physical modifications were 

installed in accordance with the associated CCFs. The inspectors reviewed the 

CSEs and ISA Summary to determine if the licensee adequately flowed down safety 

requirements into the detailed design. With respect to the implementation of 

management measures, the inspectors reviewed post-modification test records to 

determine if the licensee adequately tested modifications prior to placing them into 

service. The inspectors reviewed drawings and procedures to determine if they were 

updated in accordance with their configuration management program. The 

inspectors observed training and reviewed training records to verify that training for 

physical modifications designated as IROFS was completed prior to restart.

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

8. CAL item 3.a.v: Conduct training on the changes with personnel impacted or involved in 

the revised IROFS and management measures for this system.

a. Inspection Scope and Observations

The inspectors observed portions of the training, and confirmed that its focus was on 

the changes to the CSEs, the revised IROFS, and management measures.

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

9. CAL item 3.a.vi: Develop a post-startup monitoring plan to validate the effectiveness of 

the above actions.

a. Inspection Scope and Observations

The post-startup monitoring plan was reviewed and the inspectors noted that the 

plan includes the requirements associated with the ISA and implements the safety 

basis in the CSE. The inspectors noted that the plan included pre-operational 

checks and detailed the testing requirements and inspections as listed in the CSE 

and the ISA. 

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.
8

10. CAL item 3.b: Review CSE accident sequences for wet scrubber ventilation systems 

with non-favorable geometry (NFG) components to ensure double contingency 

protection and proper IROFS implementation. For each, perform inspections to validate 

system design and operating parameters as well as items (i) through (iii) described 

above and for items (iv) through (vi) as needed.

a. Inspection Scope and Observations

The inspectors reviewed the NCS safety bases for other NFG wet scrubbers at the 

CFFF, which included: 1) the Ammonia Fume Ventilation System (CSE-1-D), 2) the 

Acid Scrubber S-2A/2B (CSE-1-G), 3) the IFBA Scrubber (CSE-1-AE), 4) and the S958 Solvent Extraction Scrubber (CSE-1-H). Specifically, the inspectors verified that 

the licensee identified all normal and credible abnormal conditions; applied sufficient 

controls to limit the likelihood of criticality to “highly unlikely” and ensure subcriticality 

with an approved margin under these conditions; and applied sufficient factors of 

safety to ensure that at least two unlikely, independent, and concurrent changes in 

process conditions are required before criticality is possible. Additionally, the 

inspectors verified that the licensee performed inspections to validate system design 

and operating parameters as well as the adequacy of the management measures 

applied to any administrative IROFS for these systems. The inspectors verified that 

an independent NCS expert provided a review.

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

11. CAL item 3.c.i and 3.c.ii: For ventilation systems with NFG components that are 

permanently removed from service:

i. Verify the adequacy of isolation to ensure the potential does not exist for special 

nuclear material (SNM) mass accumulation or the potential for moderator addition. 

Any identified deficiencies will be corrected.

ii. The following systems will be inspected and cleaned as necessary to ensure no 

mass build up exists in them: S-1056 Scrubber, Ventilation systems 3A, 3B and 7A 

filter housings.

a. Inspection Scope and Observations

The inspectors reviewed documentation, conducted walk downs, and interviewed 

personnel associated with ventilation systems with NFG components to determine if 

the licensee had completed actions necessary to verify the adequacy of isolations to 

prevent SNM mass accumulation or moderator addition. The samples selected by 

the inspectors included the S-1056 Scrubber and 3A/3B filter housings and 

associated ductwork. Specifically, the inspectors reviewed special procedures used 

for inspection and cleanout of SNM to verify that the licensee implemented adequate 

safety controls IROFS used for the prevention of nuclear criticality. The inspectors 

conducted walk downs to determine if the equipment and ductwork was adequately 

sealed to prevent moderator intrusion. The inspectors reviewed objective evidence 

such as photos and sample results to verify that inspections and cleanout were 

performed as required by the procedure. 
9

The inspectors reviewed documentation and conducted interviews to determine if 

NCS staff participated in pre-job briefs, hold points, and inspections as specified in 

the special procedure. The inspectors reviewed the CSE developed for storage of 

ventilation cleanout containers to determine if the analysis was compliant with 

license requirements and American Nuclear Society (ANS) standards. The 

inspectors reviewed completion of inspection records to verify that the licensee 

implemented safety controls related to the storage of ventilation cleanout containers. 

The inspectors conducted walk downs of material storage areas to determine if the 

containers were properly stored in accordance with the CSE and proper postings 

were in place to communicate criticality controls such as specified spacing, array 

size, and a requirement to prevent container stacking.

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

12. CAL item 3.d: For CSEs with NFG components that have mass limits, ensure IROFS 

have been flowed down to ISA, sketches and implementing documents. Identified 

deficiencies will be entered into the CAP and corrected as necessary to meet the safety 

basis prior to returning the system to operation. Perform a sample of the remaining 

CSEs.

a. Inspection Scope and Observations

The inspectors reviewed the NCS safety bases, applicable sections of the ISA, 

sketches, and other implementing documents for NFG wet scrubbers with mass 

limits to verify proper flow-down. The inspectors verified that any identified 

deficiencies were entered into the licensee’s CAP.

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

13. CAL item 3.e: For administrative IROFS satisfied by inspection, review and revise 

procedures that implement the inspections to ensure administrative limits are properly 

defined and to ensure inspection methods can be effectively implemented to meet its 

safety function. Identified deficiencies will be entered in the CAP and corrected.

a. Inspection Scope and Observations

The inspectors reviewed the procedures associated with administrative controls 

satisfied by inspection to verify that limits were properly defined and that inspection 

methods could be effectively implemented to meet their intended safety function. 

The inspectors verified that any identified deficiencies were entered into the 

licensee’s CAP.
10

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

14. CAL item 3.f: Perform a historical review (previous 10 years) of the corrective action 

program and Red book/Green book entries to identify any recurring or longstanding 

issues that identify potential challenges to the safety basis of any CSE. Identified issues 

will be entered into the corrective action program and will either be corrected prior to 

restart or adequate compensatory measures put in place.

a. Inspection Scope and Observations

The inspectors reviewed the licensee’s historical review of the CAP and Red 

book/Green book entries to identify any recurring or longstanding issues that identify 

potential challenges to any NCS safety basis. The inspectors verified that any 

identified issues were entered into the licensee’s CAP.

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

15. CAL item 3.g: Implement procedure changes to provide an internal escalation protocol 

to plant management for IROFS violations, including guidance for situations involving 

uncertainty in compliance to limits.

a. Inspection Scope and Observations

The inspectors reviewed RA-121, “Redbook Internal Reporting System,” and verified 

it was revised to provide an internal escalation protocol in the event of a failed or 

degraded system, structure or component (SSC). The revised procedure requires 

plant personnel to immediately contact their supervision (positive contact must be 

made) upon identification of a failed or degraded SSC.

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

16. CAL item 3.h: Revise the "Columbia Plant Safety Event Response Guidelines" to 

strengthen critical decision making based upon event significance by requiring 

independence of membership on the Safety Event Management Review Team.

a. Inspection Scope and Observations

The inspectors reviewed RA-134, “Columbia Plant Safety Event Response 

Guidelines,” and noted it was revised to require independent membership on the 

Safety Event Management Review Team, which would have required an additional 

layer of review prior to S-1030 restart.
11

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

17. CAL item 3.i: Retain an external nuclear criticality safety expert who will remain on site 

at Columbia to assist in the oversight of nuclear criticality safety (NCS) functions until 

corrective actions from the RCA related to this function are complete and an 

effectiveness review is performed to ensure sustainability of corrective actions. 

Additionally, Columbia has initiated a search for a permanent new manager for the NCS 

organization.

a. Inspection Scope and Observations

The inspectors verified that an external NCS expert was retained by Westinghouse 

to provide oversight of NCS functions. In addition, CFFF has initiated actions to 

retain a new permanent NCS Manager.

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

18. CAL item 3.j: Develop and present training on the lessons learned from this event, 

including the results of the NSC evaluation, to leadership (front line supervisors and 

above) and to workers impacted or involved in the control of IROFS and management 

measures. In addition to this training, senior management of the Columbia Fuels 

Operations will conduct briefings with each work group to reinforce desired standards, 

behaviors and expectations regarding their role in nuclear safety.

a. Inspection Scope and Observations

Through observation and documentation review, the inspectors verified the S-1030 

scrubber lessons learned training was provided to leadership (front line supervisors 

and above) and to workers impacted or involved in the control of IROFS and 

management measures. The inspectors noted that the employees were encouraged 

to ask questions and provide input to enhance or change behaviors at the site. 

Senior management reinforced the desired standards, behaviors, and expectations 

regarding the employees’ role in nuclear safety during working group briefings. In 

addition, the inspectors observed Nuclear Safety Culture Training as it was 

administered to a mixed grouping of employees including managers, supervisors, 

engineers, and production workers. The training included discussions of the most 

recent event and previous events at fuel facilities. The training linked these events to 

the “Traits of a Healthy Nuclear Safety Culture,” using INPO 12-012 as guidance.

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.
12

19. CAL item 4: For the NCS organization, conduct a work environment assessment and 

develop needed corrective actions. Additionally, the Interim Vice President, Columbia 

Fuels Operations will reinforce desired standards, behaviors, expectations and the 

lessons learned from this event with all personnel in the NCS organization.

a. Inspection Scope and Observations

The inspectors interviewed the Interim Vice President, CFFF, to discuss and 

evaluate the reinforcement of standards, behaviors, expectations, and lessons 

learned from the event that was conducted with all personnel within the NCS 

organization. Additionally, the inspectors reviewed the work environment 

assessment conducted for the NCS organization.

b. Conclusion

No violations of significance were identified. The inspection team determined that 

the requirements of this CAL item were met.

B. Restart Conclusion

No violations of significance were identified during the CAL restart inspections. The NRC 

concluded that the corrective actions implemented to date by Westinghouse are reasonable and 

have sufficient likelihood of being effective to support a determination that the conversion 

process equipment and S-1030 scrubber can be operated safely in accordance with the facility 

license. 

C. EXIT MEETING

During the course of the inspection, the team provided members of the plant staff and 

management summaries of inspection findings on a daily basis. During these discussions, 

licensee representatives identified some of the material examined during the inspection as 

proprietary. All proprietary information was returned to the licensee. The team presented the 

inspection results to B. Phillips and other members of the plant staff and management at a 

meeting conducted on October 19, 2016, in Columbia, SC.
SUPPLEMENTAL INFORMATION

Key Points of Contact

B. Phillips Interim Vice-President

B. Waskey Analytical Services and Chemical Quality Control Manager

C. Gantt Senior Engineer, Pellet Operations

C. Miller Senior NCS Engineer

F. Jackson Director of Manufacturing, Standardization and Major Products

G. Byrd Licensing Engineer

G. McGehee Senior NCS Engineer

H. Whitaker Principal Quality Engineer, Product Assurance Chemical Operations

J. Coleman Measurement Control Coordinator

J. Howell Environment, Health and Safety (EH&S) Manager

J. Huggett Senior Manufacturing Engineer

J. Jones Technical Training Manager

J. Nimmo Conversion Team Manager

J. Vining Senior NCS Engineer

K. Barber Project Engineer

M. Annacone Vice President, Columbia Recovery

M. Burns Reliability Engineer

M. Krissinger Senior Chemist

M. Trayers Reliability Engineering Manager

N. Parr Licensing Manager 

R. Likes Safeguards Coordinator

R. Rodriguez Process Engineer

R. Stutts Principal Engineer

S. Weathers Conversion Engineer

T. Graves Conversion Engineer

T. Gregg URRS Area Manager

Other licensee employees contacted included engineers, technicians, production staff, and 

office personnel.

Items Opened or Closed

None

Inspection Procedures Used

IP 88003 Reactive Inspection for Events at Fuel Cycle Facilities

IP 88015 Nuclear Criticality Safety

IP 88020 Operational Safety

IP 88070 Plant Modifications

IP 92703 Follow-up of Confirmatory Action Letters or Orders

IP 93800 Augmented Inspection Team

Attachment
2

Key Documents Reviewed

Procedures:

85002-1, Revision (Rev.) 40, Chemical Operating Procedure Sketch Erbia Area

COCL-T18, Rev. 0, S-974 Cleaning and Inspection

COP-80107, Cleanout of Roof Ventilation Boroscope Viewports, Rev. 0

COP-811001, Rev. 56, Fitzmill

COP-814201, Rev. 37, Resampling of Line Product Materials

COP-815010, Conversion BLU-M Oxidation, Rev. 24

COP-815020, Scrap Recovery Scrubber S-1030, Rev. 13

COP-815021, S-1030 Inspection and Clean Out, Rev. 10

COP-815412, Changing Wet Filters in the Conversion/Scrap Area (CSA), Rev. 23

COP-816025, Revision 3, Analytical Services Laboratory Scrubber S-974

COP-850453, Revision 8, Blue-M Oxidation System (Clean Scrap)

COP-850463, Revision 7, Blue-M Oxidation Systems (Dirty Scrap)

CSE-19-A, Revision 3, Oxidation Ovens and Hoods

FA-114, Independent Technical Reviews, Rev. 5

ISA-5, ISA Summary, ADU Bulk Blending System, Rev. 11

ISA-16, ISA Summary, Storage of Uranium Bearing Materials, Rev. 10

ISA-18, ISA Summary, Laboratory System, Rev. 10

ISA-19, ISA Summary, Hoods and Containment System

MCP-108218, Inspection of Roof Ventilation Ducts with Boroscope, Rev. 7

MCP-203526, Verification of Interlock VENT-S1030-124: S-1030 Scrubber High Level, 

QCF-1177, Rev. 1 Chemical Lab Standards Cabinet U235 Inventory

QCI-119907, Rev. 10, Analytical Services Laboratory Storage of U-235

QCI-310905, Rev. 14, Inspection of Items Relied On For Safety (IROFS) – Common Containers

RA-104, Regulatory Review of Configuration Change Authorizations, Rev. 28

RA-108-8, Revision 51, Storage of Uranium Bearing Material Safety Significant Controls

RA-108-9, Revision 64, Ventilation and Scrubbing Safety Significant Controls

RA-120-20, Rev. 7, Regulatory Policy – Safety Significant Controls – Inspection of Procured 

Items Relied On For Safety, Rev. 0

ROP-05-062, Rev. 15, Radiation Survey of Ventilation Equipment

SOI-C-0670, Out of Service (O/S) S-1056 Inspection and Cleanout, Rev. 0

SOI-C-0670, Out of Service (O/S) S-1056 Inspection and Cleanout, Rev. 0

SOI-C-0672, Out of Service (O/S) 3A and 3B System Inspection and Clean Out, Rev. 0

SOI-C-0672, Out of Service (O/S) 3A and 3B System Inspection and Clean Out, Rev. 0

T20, Revision 1, Annual Special Nuclear Material Inventory

TA-500, Columbia Manufacturing Plant Configuration Control, Rev. 30

Records:

CCF 09516, Scrap Cage Filter Press FP1058 Vent to S1030 for Filter Press Plates

CCF 16482, Install new level probes in Scrubber S-1030

PSEDoc-0003226, Independent Technical Review 16482-1, Rev. 0

PSEDoc-0003241, ADU Common Services Safety Instrumented System (SIS) Safety 

PSEDoc-0003280, CCF-16509 – Independent Technical Review, Rev. 0

PSEDoc-0003348, Calculation – Maintain the Level in the Scrubber S-1030 Below 4” from the 

Bottom, Rev. 0

PSEDoc-0003389, Calculation – Capacity of 8” Drain Line, Rev. 0

Requirement Specification (SRS), Rev. 0

VR-005 (3A/3B), Verification Review of Out of Service Ventilation Systems with NFG 

Components Permanently Removed from Service, Rev. 0

VR-005 (S-1056), Verification Review of Out of Service Ventilation Systems with NFG 

Components Permanently Removed from Service, Rev. 0
3

Condition Report Written as a Result of the Inspection:

100421674, Documented Comments Identified by NRC inspectors during IP 92703 inspection, 

dated October 14, 2016.

Condition Reports Reviewed:

100416419, SE RC-SYS: Process Ventilation Gamma Scan Program Improvements

100418489, RC-DI: Floor Storage of SNM, 

100418662, SE RC: Process Ventilation Visual Inspection Program Improvements

100420832, SE RC-DI: Inspection and Clean-Out of Out of Service 3A/3B Filterhouse

Work Orders:

741759 [S-1030 Scrubber SIS Controllers – Electrical Installation Instructions]

742752 [Verification of Proper Operation of the new S-1030 level probes]

Diagrams:

Electrical DWG No. 333A02LS03, Sheet No. 11, Rev. C3, Loop No. LSH-S-1030-1

Electrical DWG No. 333A02LS03, Sheet No. 12, Rev. C3, Loop No. LSH-S-1030-2

Electrical DWG No. 333A02LS03, Sheet No. 13, Rev. C3, Loop No. LSH-S-1030-3

P&ID No. 333F02P103, Scrubber S-1030 & Filter House Systems 1030A & 1030B, Rev. C1

Sketch No. 815417-9, Chemical Operating Procedure Sketch Conversion Area, Rev. 63

Nuclear Criticality Safety Evaluations:

CSE-1-AE, “CSE for the IFBA Scrubber,” Rev. 4

CSE-1-D, “CSE for the Ammonia Fume Ventilation System,” Rev. 9

CSE-1-E, “CSE for the S-1030 Scrubber System,” Revs. 9 and 10

CSE-1-G, “CSE for the Acid Scrubber S2-A/2B,” Rev. 7

CSE-1-H, “CSE for the S-958 Solvent Extraction Scrubber,” Rev. 7

CSE-1-I, “Critical Safety Analysis for Analytical Services Laboratory Scrubber,” Rev. 4

CSE-3-I, “CSE for the CFFF ADU Conversion Calciner,” Rev. 6

CSE-16-1, Criticality Safety Evaluation (CSE) for Ventilation Clean-Out Containers, Rev. 1

CSE-16-B, “Critical Safety Evaluation for Storage of Uranium Bearing Materials,” Rev. 7

CSE-18-B, “Critical Safety Evaluation for the Analytical Services Laboratory,” Rev. 15

CSE-19-A, “CSE for the Oxidation Ovens and Hoods,” Rev. 3

Calc Notes:

CN-CRI-16-006-001

CN-CRI-16-007-000

CN-SB-11-012-007

Other Documents:

ATKINS-NS-ANH-16-01, September 1, 2016, Independent Criticality Safety Engineer Review of 

Columbia Fuel Fabrication Facility (CFFF) Chemical Laboratory Scrubber CSE-1-I

CAF-206-4, “Management Measures Self Assessment”

CAPAL 100413751, Improper Removal from Service for Wet Scrubber Ventilation Systems at 

CFFF

CCF 05334, Blue – M Vent Mod, Rev. 0

CCF 07282, S-1030 Clean Out Port, Rev. 0

CCF 08059, ADU Line 5 “M” Vent, Rev. 0

CCF 09307, Ventilation View Ports on Roof Mounted Systems, Rev. 0

CCF 09471, S-1030 Additional Inspection Port

CCF 09505, Scrap Cage Blue M Oven, Rev. 0

CCF 09516, Scrap Cage Filter Press FP1058 Vent to S-1030 for Filter Press Plate, Rev. 0

CCF 16459, Add Drain holes in Baffles Inside Scrubber S-1030, Rev. 0
4

CCF 16482, Install New Level Probes in Scrubber S-1030, Rev. 0

CCF 16486, S-1030 Scrubber Body Demo Work, 

CCF 16487, S-1030 Scrubber Body Mods, Rev. 0

CCF 16493, Passive Overflow for 1030 Scrubber, Rev. 0

CCF 16500, S-1030 Scrubber Inlet Transition Replacement, Rev. 0

CCF 16509, S-1030 Modify Blowdown Line, Rev. 0

CCF 16509-0-CCR-03, Air gap S-1030 to V-1016 blowdown line, Rev. 0

CCF 16510, Install 8” Drain on S-1030 Scrubber, Rev. 0

CCF 16522, Scrubber 1030 Inlet Transition Spray Nozzle Installation, Rev. 0

FSS-012, Control System Design for Safety Significant Control Applications, Rev. 7

PSEDOC-3270, “S-1030 Chemistry Analysis,” Rev 0

Root Cause Analysis, Uranium Mass Exceedance in S-1030 Scrubber at Columbia Fuel 

Fabrication Facility (CFFF), dated October 5, 2016

S-1030 Scrubber Event Recovery Plan, dated October 12l, 2016
Enclosure 2

WESTINGHOUSE ELECTRIC COMPANY COMMITMENTS

Pursuant to the letter from Westinghouse dated August 9, 2016, and the telephone call between 

Nuclear Regulatory Commission (NRC) management and Westinghouse management (David J. 

Precht and Bruce Phillips) on August 8, 2016, it is our understanding that Westinghouse has 

taken, or will complete the following actions prior to restart:

1. Complete a Root Cause Analysis (RCA) investigation for this event. In accordance with the 

RCA Charter, the RCA will include an assessment of the nuclear safety culture (NSC) 

contributors to the event and identify necessary corrective actions to address gaps noted in 

the NSC at Columbia.

2. If the RCA investigation identifies additional actions necessary to assure safe operations, 

then Westinghouse will revise its restart plan to include those actions. Additional immediate 

or compensatory actions will be identified and put in place for any corrective action to 

prevent recurrence that is not completed prior to restart.

3. The following immediate actions will be taken:

a. The design, operating and maintenance history of the S-1030 scrubber system, including 

changes to influents to the scrubber system, will be reviewed to understand the impacts 

on the mass build up noted in this event. Based upon this review, the safety basis for 

the scrubber system will be revised. Additionally, the following will be performed for the 

S- I030 scrubber system:

i. Review and revise procedures that implement administrative items relied on for 

safety (IROFS) to ensure administrative limits are properly defined and to ensure 

inspection methods that validate compliance to the administrative IROFS can be 

effectively implemented to meet its safety function.

ii. Review the adequacy of the management measures applied that support the 

availability and reliability of the administrative IROFS and correct any identified 

deficiencies.

iii. Review and approval of the above actions and the identified corrective actions will be 

performed by independent criticality safety experts.

iv. Complete the installation of physical modifications needed to support the revised 

safety basis.

v. Conduct training on the changes with personnel impacted or involved in the revised 

IROFS and management measures for this system.

vi. Develop a post-startup monitoring plan to validate the effectiveness of the above 

actions.

b. Review Criticality Safety Evaluation (CSE) accident sequences for wet scrubber 

ventilation systems with non-favorable geometry (NFG) components to ensure double 

contingency protection and proper IROFS implementation. For each, perform 

inspections to validate system design and operating parameters as well as items (i) 

through (iii) described above and for items (iv) through (vi) as needed.
2

c. For ventilation systems with NFG components that are permanently removed from 

service:

i. Verify the adequacy of isolation to ensure the potential does not exist for special 

nuclear material (SNM) mass accumulation or the potential for moderator 

addition. Any identified deficiencies will be corrected.

ii. The following systems will be inspected and cleaned as necessary to ensure no 

mass build up exists in them: S-1056 Scrubber, Ventilation systems 3A, 3B and 

7A filter housings.

d. For CSEs with NFG components that have mass limits, ensure IROFS have been 

flowed down to Integrated Safety Analyses (ISA), sketches and implementing 

documents. Identified deficiencies will be entered into the corrective action program 

(CAP) and corrected as necessary to meet the safety basis prior to returning the 

system to operation. Perform a sample of the remaining CSEs.

e. For administrative IROFS satisfied by inspection, review and revise procedures that 

implement the inspections to ensure administrative limits are properly defined and to 

ensure inspection methods can be effectively implemented to meet its safety 

function. Identified deficiencies will be entered in the CAP and corrected.

f. Perform a historical review (previous 10 years) of the corrective action program and 

Red book/Green book entries to identify any recurring or longstanding issues that 

identify potential challenges to the safety basis of any CSE. Identified issues will be 

entered into the corrective action program and will either be corrected prior to restart 

or adequate compensatory measures put in place.

g. Implement procedure changes to provide an internal escalation protocol to plant 

management for IROFS violations, including guidance for situations involving 

uncertainty in compliance to limits.

h. Revise the "Columbia Plant Safety Event Response Guidelines" to strengthen critical 

decision making based upon event significance by requiring independence of 

membership on the Safety Event Management Review Team.

i. Retain an external nuclear criticality safety expert who will remain on site at 

Columbia to assist in the oversight of nuclear criticality safety (NCS) functions until 

corrective actions from the RCA related to this function are complete and an 

effectiveness review is performed to ensure sustainability of corrective actions. 

Additionally, Columbia has initiated a search for a permanent new manager for the 

NCS organization.

j. Develop and present training on the lessons learned from this event, including the 

results of the NSC evaluation, to leadership (front line supervisors and above) and to 

workers impacted or involved in the control of IROFS and management measures. In 

addition to this training, senior management of the Columbia Fuels Operations will 

conduct briefings with each work group to reinforce desired standards, behaviors and 

expectations regarding their role in nuclear safety.
3

4. For the NCS organization, conduct a work environment assessment and develop needed 

corrective actions. Additionally, the Interim Vice President, Columbia Fuels Operations will 

reinforce desired standards, behaviors, expectations and the lessons learned from this 

event with all personnel in the NCS organization.

5. Upon completion of items (1) through (4) above, the Interim Vice President, Columbia Fuels 

Operations will determine readiness for restart of the S-1030 scrubber system, with 

concurrence by the Recovery Manager and approval by the Oversight Board. 

Westinghouse will then request restart approval from the NRC Region II Administrator.

In addition, to ensure continued safe operations after restart, Westinghouse further commits to 

take the following actions:

1. Complete all corrective actions to prevent recurrence identified in the RCA that are not 

completed prior to restart.

2. Implement the remaining corrective actions identified in the RCA or the recovery plan, 

including those resulting from the evaluation of NSC contributors to this event.

3. In accordance with Westinghouse CAP procedures, conduct effectiveness reviews of 

corrective actions specified in the RCA.

4. Complete corrective actions identified in the NCS organization work environment 

assessment.

5. Within nine months, an independent third party nuclear safety culture assessment will be 

performed at Columbia and any identified deficiencies will be entered into the CAP to track 

to completion.

6. Implement the post-startup monitoring plan described in item (3) of the list of actions to be 

taken prior to restart.

7. Upon completion of the foregoing actions, Westinghouse will notify the NRC Region II 

Administrator.