UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

REGION II 

245 PEACHTREE CENTER AVENUE NE, SUITE 1200 

ATLANTA, GEORGIA 30303-1257

August 11, 2016 

EA-16-173 

Mr. Bruce Phillips 

Interim Vice President, Columbia Fuel Operations 

Westinghouse Electric Company 

5801 Bluff Road 

Hopkins, SC 29061 

SUBJECT: CONFIRMATORY ACTION LETTER – WESTINGHOUSE ELECTRIC 

COMPANY, COLUMBIA FUEL FABRICATION FACILITY 

Dear Mr. Phillips: 

The purpose of this letter is to confirm the commitments made by Westinghouse Electric 

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

August 9, 2016 (ML16223A003), and during a telephone call between the U.S. Nuclear 

Regulatory Commission (NRC) management, and yourself, Mr. Precht and others on August 8, 

2016, regarding additional actions Westinghouse will take in response to the uranium buildup 

reported to the NRC in July 2016. These actions are intended to ensure that the causes of the 

uranium buildup have been adequately identified and evaluated and that appropriate corrective 

actions have been implemented to improve the performance of the Nuclear Criticality Safety 

program. 

On July 14, 2016, Westinghouse reported to the NRC (EN 52090) that it had exceeded the 

uranium mass limit for the S-1030 scrubber transition section. This was based on the clean-out 

of material discovered in the S-1030 scrubber transition section during an annual maintenance 

shutdown in May 2016. Subsequently, on July 31, 2016, Westinghouse updated the report to 

the NRC indicating that the S-1030 scrubber packing also exceeded the uranium mass limit of 

the scrubber criticality safety evaluation. The NRC chartered an augmented inspection team 

(AIT) to review the facts and circumstances surrounding the uranium mass buildup. 

The NRC has concerns with the extent of condition, extent of cause, and the implementation of 

items relied on for safety (IROFS) associated with the uranium buildup. In addition, the process 

of identifying, evaluating, and correcting potential risk significant deficiencies may have resulted 

in missed opportunities to prevent this issue, and a perceived lack of a questioning attitude may 

have resulted in delays in identifying these conditions. 
B. Phillips 2 

Pursuant to the August 9, 2016, letter, and previously discussed telephone call on August 8, 

2016, it is our understanding that you have taken, or will take, the following actions: 

1. Suspend all NRC licensed operations of the S-1030 scrubber system and conversion 

process equipment until Westinghouse has completed those actions necessary to assure 

safety prior to restart, as documented in the August 9, 2016 letter (Items 1 – 5). The 

commitments included in the August 9, 2016 letter are restated as an enclosure to this 

Confirmatory Action Letter (CAL). 

2. Obtain written consent from the NRC permitting the resumption of NRC licensed operations 

specified in Item 1 above. 

Pursuant to Section 182 of the Atomic Energy Act, 42 U.S.C. 2232, you are required to: 

1. Notify me immediately if your understanding differs from that set forth above; 

2. Notify me if for any reason you cannot complete the actions within the specified schedule 

and advise me in writing of your modified schedule in advance of the change; 

3. Notify me, in writing, if for any reason you intend to change, deviate from or not complete 

any of the documented commitments set forth above, and advise me, in writing, of the 

changes or deviations; and 

4. Notify me in writing when you have completed the actions addressed in this CAL. 

Issuance of this CAL does not modify or amend the Westinghouse license, and does not 

preclude issuance of an Order making the above commitments legally binding requirements or 

requiring other actions on the part of the licensee. However, if any commitments or further 

actions identified by Westinghouse meet criteria for amending the license, Westinghouse shall 

submit an amendment request to the NRC in accordance with 10 CFR Parts 70.34 and 70.65. 

In addition, the NRC is not precluded from taking enforcement action for violations of NRC 

requirements that may have prompted the issuance of this letter. 

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, “Public 

Inspections, Exemptions, Requests for Withholding,” of the NRC's "Rules of Practice and 

Procedure," a copy of this letter and your response will be made available electronically for 

public inspection in the NRC Public Document Room or in the NRC’s Agencywide Documents 

Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at 

http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not 

include any personal privacy, proprietary, security-related or safeguards information, so that it 

can be made available to the Public without redaction. If personal privacy or proprietary 

information is necessary to provide an acceptable response, then please provide a bracketed 

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

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

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

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

information will create an unwarranted invasion of personal privacy or provide the information 

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

financial information). 
B. Phillips 3 

If you have any questions concerning this matter please contact Eric Michel of my staff. 

Mr. Michel can be reached at (404) 997-4555. 

 Sincerely, 

 /RA/ 

 Catherine Haney 

 Regional Administrator 

Docket No. 70-1151 

License No. SNM-1107 

Enclosure: Westinghouse Electric Company 

 Commitments 

cc: (See page 4) 
B. Phillips 3 

If you have any questions concerning this matter please contact Eric Michel of my staff. 

Mr. Michel can be reached at (404) 997-4555. 

 Sincerely, 

 

 /RA/ 

 

 Catherine Haney 

 Regional Administrator 

Docket No. 70-1151 

License No. SNM-1107 

Enclosure: Westinghouse Electric Company 

Commitments 

cc: (See page 4) 

DISTRIBUTION: 

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P. Startz, RII 

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G. Tracy, EDO 

M. Dapas, NMSS 

C. Erlanger, NMSS 

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ADAMS: Yes ACCESSION NUMBER:ML16224B082 SUNSI REVIEW COMPLETE FORM 665 ATTACHED 

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

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2\WESTINGHOUSE\REACTIVE INSPECTIONS\REACTIVE INSPECTION WEST 2016 - 

SCRUBBER\CAL\DRAFT CAL FOR WEST SCRUBBER REV 4.DOC 
B. Phillips 4 

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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. 

Enclosure 
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.