IR 05000397/2011006

IR 05000397-11-006, on 08/22/11 - 09/15/11, Columbia Generating Station, Biennial Baseline Inspection of Identification and Resolution of Problems

ML112990156
Person / Time
Site:	Columbia
Issue date:	10/25/2011
From:	Powers D Division of Reactor Safety IV
To:	Reddemann M Energy Northwest
References
IR-11-006
Download: ML112990156 (42)

Text

UNITED STATES NUC LE AR RE G ULATO RY C O M M I S S I O N ber 25, 2011

SUBJECT:

COLUMBIA GENERATING STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000397/2011006

Dear Mr. Reddemann:

On September 15, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed a team inspection at Columbia Generating Station. The enclosed report documents the inspection findings discussed on September 15, 2011, with Mr. Brad Sawatzke, Vice-President and Chief Nuclear Officer, and other members of your staff.

The inspection examined activities conducted under your license as they relate to identification and resolution of problems, safety and compliance with the Commissions rules and regulations, and with the conditions of your operating license. The team reviewed selected procedures and records, observed activities, and interviewed personnel. The team also interviewed a representative sample of personnel regarding the condition of your safety conscious work environment.

The team concluded that Columbia Generating Stations corrective action program adequately identified, evaluated, and corrected problems. However, as described in the attached inspection report, the team identified examples of where your staff failed to properly prioritize and thoroughly evaluate problems to reach appropriate resolution. The team determined that your corrective action program effectively reviewed lessons learned from internal and external operating experience, findings from audits and self-assessments were appropriately entered into the corrective action program for resolution, and a healthy safety conscious work environment existed at your station.

This report documents one self-revealing and two NRC-identified findings. All three findings involved violations of NRC requirements and were determined to have very low safety significance (Green). The NRC is treating these violations as noncited violations consistent with Section 2.3.2 of the NRC Enforcement Policy because of the very low safety significance of the violations and because the violations were entered into your corrective action program.

If you contest these noncited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 E. Lamar Blvd.,

Suite 400, Arlington, Texas, 76011-4125; the Director, Office of Enforcement, U. S. Nuclear

Energy Northwest -2-Regulatory Commission, Washington DC 20555-0001; and to the NRC Resident Inspector at Columbia Generating Station. In addition, if you disagree with the cross-cutting aspect associated with any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV, and the NRC Resident Inspector at Columbia Generating Station.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), 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, or proprietary information so that it can be made available to the Public without redaction.

Sincerely,

/RA/

Dr. Dale A. Powers, Acting Chief Technical Support Branch Division of Reactor Safety Docket: 50-397 License: NPF-21 Enclosure:

NRC Inspection Report 05000397/2011006 w/Attachments: Attachment 1, Supplemental Information Attachment 2, Initial Information Request Attachment 3, Supplemental Information Requests Distribution via Listserve for Columbia Generating Station

Energy Northwest -3-Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Art.Howell@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

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

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Tom.Blount@nrc.gov)

Senior Resident Inspector (Jeremy.Groom@nrc.gov)

Resident Inspector (Mahdi.Hayes@nrc.gov)

Branch Chief, DRP/A (Wayne.Walker@nrc.gov)

Senior Project Engineer, DRP/A (David.Proulx@nrc.gov)

Project Engineer, DRP/A (Christopher.Henderson@nrc.gov)

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

Public Affairs Officer (Victor.Dricks@nrc.gov)

Branch Chief, DRS/TSB (Dale.Powers@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

OEMail Resource ROPreports OEDO RIV Coordinator (Mark.Franke@nrc.gov)

DRS/AA (Loretta.Williams@nrc.gov)

R:REACTORS\CGS 2011006 PI&R-BKT ML SUNSI Rev Compl. X Yes No ADAMS X Yes No Reviewer Initials BKT Publicly Avail X Yes No Sensitive Yes X No Sens. Type Initials BKT RI/STP RI/DRS/EB2 SRI/DRS/TSB SRI/DRS/TSB C:DRP/PBA BTharakan NOkonkwo HFreeman RCohen WWalker

/RA/ /E/ /RA/ /T/ /RA/

10/18/11 10/19/11 10/18/11 10/19/11 10/24/11 C:DRS/TSB DPowers

/RA/

10/25/11 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000397 License: NPF-21 Report: 05000397/2011006 Licensee: Energy Northwest Facility: Columbia Generating Station Location: Richland, Washington Dates: August 22 through September 15, 2011 Team Leader: B. Tharakan, Certified Health Physicist, Resident Inspector, South Texas Project Inspectors: R. Cohen, Senior Reactor Inspector, Technical Support Branch H. Freeman, Senior Reactor Inspector, Technical Support Branch N. Okonkwo, Reactor Inspector, Engineering Branch 2 Approved By: Dr. Dale A. Powers, Acting Chief Technical Support Branch Division of Reactor Safety-1- Enclosure

SUMMARY OF FINDINGS

IR 05000397/2011006; 8/22/2011-9/15/2011; Columbia Generating Station; Biennial Baseline

Inspection of Identification and Resolution of Problems;

A resident inspector, two senior reactor inspectors, and a reactor inspector conducted the team inspection. The team identified three findings of very low safety significance during this inspection. The significance of most findings is indicated by their color (Green, White, Yellow,

Red) using Inspection Manual Chapter 0609, "Significance Determination Process." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG 1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Identification and Resolution of Problems The team reviewed approximately 200 action request/condition reports, work orders, engineering evaluations, root and apparent cause evaluations, and other supporting documentation, to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. In addition, the team reviewed a sample of system health reports, self-assessments, quality assurance reports, corrective action program metrics including backlog and trend reports, and various other documents related to the corrective action program.

The team concluded that Columbia Generating Stations corrective action program was adequately implemented. However, the team identified some examples where the licensee did not accurately classify the significance of a problem or thoroughly evaluate the condition and identify the appropriate resolution.

The team reviewed approximately 15 quality assurance audits and self-assessments performed since September 2009. The team determined that the audits and self-assessments were thorough, self-critical, and identified problems at a low threshold, and subsequently entered into the corrective action program for resolution.

The team reviewed the licensees use of operating experience. The team determined that the licensee appropriately evaluated industry operating experience for relevance to their station and entered applicable items in the corrective action program. During the inspection period, the licensee adequately used industry operating experience when performing root cause and apparent cause evaluations.

Based on 32 interviews about the safety conscious work environment, the team determined that workers at the site felt free to report problems to their management without fear of retaliation.

The team concluded that a healthy safety conscious work environment existed at Columbia Generating Station.

Cornerstone: Mitigating Systems

Green.

The team identified a Green noncited violation of 10 CFR 50, Appendix B,

Criterion XVI, Corrective Action, because Energy Northwest failed to promptly identify and correct degraded flood barrier floor coatings, which protected the Division 2 safety-related electrical switchgear room, remote shutdown room, and main control room from water intrusion. In 2002, flooding above the Division 2 electrical switchgear and remote shutdown rooms resulted in water intrusion into these rooms. The corrective action to prevent recurrence was to apply epoxy paint to the concrete floors above these rooms to ensure the floors would be leak tight. In April 2004, a degraded flood barrier floor coating was identified and operations staff requested an engineering evaluation. An hourly flood watch was established, however, an engineering evaluation was not performed to identify and correct the material deficiency and no justification was provided for establishing an hourly flood watch. The team determined that from April 2004, to September 14, 2011, at least 30 action requests were written that identified degraded epoxy coated flood barriers.

Although the flood barriers were eventually patched, no engineering evaluation was performed to identify and correct the material deficiency. The team determined that the flood barriers were degraded approximately 36 percent of the time. The licensee entered this issue into the corrective action program as Action Request/Condition Report 249288.

The finding was more than minor because it affected the Mitigating Systems Cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences and if left uncorrected, could become a more significant safety concern because a flood in the area could adversely affect safety-related equipment. Using NRC Manual Chapter 0609 Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, dated January 10, 2008, the finding initially screened as potentially risk significant due to the flooding hazard, however, it was determined to be of very low risk significance (Green) because there was no actual loss or degradation of the safety function of the equipment protected by the flood barrier. In addition, this finding had a crosscutting aspect in the area of human performance associated with decision making because the licensee failed to communicate to persons who have the need to know in order to perform work safely, the basis for the decision to implement an hourly flood watch and not perform an engineering evaluation in a timely manner

H.1(c). (Section 4OA2).

Green.

The team identified three examples of a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to follow station procedures. The licensee entered these examples into the corrective action program as Action Request/Condition Report 249287.

The first example was a failure to properly implement the instructions of the stations seismic procedure, PPM 10.2.53, to evaluate and control transient equipment and materials. Specifically, during this inspection, on August 29 through September 1, 2011, the team identified unsecured bookcases, rolling metal ladders, and loose maintenance carts in the main control room, and barrels stored near a high pressure core spray pump that were not evaluated in accordance with seismic procedures.

The second example was the failure to perform a root cause analysis for long standing problems that have had ineffective corrective actions, as required by Procedure SWP-CAP-06, Condition Review Group (CRG), Revision 16,

Specifically, between October 2007, and September 15, 2011, multiple examples of the failure to follow seismic procedures have been identified by past NRC inspection teams and licensee internal follow-up actions. Therefore, the team concluded Energy Northwest failed to recognize that a root cause analysis was required to address this long standing issue.

The third example was a failure to promptly implement interim corrective actions as required by Procedure SWP-CAP-01,"Corrective Actions Program." Specifically, after the team identified the improperly stored items on September 1, 2011, the licensee secured the material, but failed to implement any interim corrective actions to reduce the likelihood that the condition would not be repeated until longer term corrective actions could be implemented. On September 13, 2011, when the team asked the licensee about interim corrective actions, the licensee conducted a site stand-down to inform station personnel about the condition and procedural requirements.

The finding was more than minor because it was a programmatic deficiency, which affected the Mitigating Systems Cornerstone objective, and if left uncorrected, could lead to a more significant safety concern because a seismic event could result in the unavailability of systems used to mitigate the consequences of initiating events.

Using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance (Green) because it did not result in an actual loss of a system safety function, did not result in a loss of a single train of safety equipment for greater than its technical specification allowed outage time, did not involve the loss or degradation of equipment specifically designed to mitigate a seismic, flooding, or severe weather initiating event, and did not involve the total loss of any safety function that contributes to an external event initiated core damage accident sequence. In addition, this finding had a crosscutting aspect in the area of human performance, associated with the work control component, because the licensee failed to appropriately plan work on multiple occasions, resulting in job site conditions which may have impacted plant components H.3(a). (Section 4OA2)

Cornerstone: Occupational Radiation Safety

Green.

The team reviewed a self-revealing noncited violation of 10 CFR Part 20.1501(a), for the failure to survey the residual heat removal pump A room after it was secured from service. Specifically, on August 29, 2011, during a tour with the NRC inspection team, the residual heat removal system engineer received a dose rate alarm. The team left the area and contacted radiation protection. Subsequent surveys identified dose rates were as high as 120 millirem per hour at 30 centimeters from the suction piping of the pump, which required the area to be posted and barricaded as a high radiation area. The licensee appropriately controlled the area, and entered the condition into their corrective action program as Action Request/Condition Report 247542.

The finding was more than minor because it was associated with the Occupational Radiation Safety Cornerstone exposure control attribute of program and process and it affected the cornerstone objective because it resulted in an unposted high radiation area that affected the licensees ability to adequately protect workers' health and safety from exposure to radiation. Using Inspection Manual Chapter 0609,

Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance because it was not an ALARA finding, there was no overexposure or substantial potential for an overexposure, and the ability to assess dose was not compromised. In addition, this finding had a crosscutting aspect in the area of human performance associated with the work control component, because the planned work activities did not incorporate the need for compensatory actions (e.g., surveys) to detect delayed changes in radiological conditions H.3(a). (Section 4OA2)

Licensee-Identified Violations

None

REPORT DETAILS

4OA2 Problem Identification and Resolution

The team based the following conclusions on the sample of corrective action documents that were initiated during the assessment period, which ranged from September 17, 2009, to September 15, 2011.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspection team reviewed approximately 200 action request/condition reports, including the associated corrective actions, root cause evaluations, apparent cause evaluations, and direct cause evaluations, from approximately 40,000 that were issued during the inspection period to determine if problems were properly identified, characterized, and entered into the corrective action program for evaluation and resolution. Team members evaluated the licensees efforts in establishing the scope of problems by reviewing selected logs, work requests, self-assessment and quality assurance audit results, system health reports, operability determinations, trending reports and metrics, surveillance test results, and various other corrective action program documents. The inspectors interviewed station personnel and attended licensee meetings to assess the reporting threshold, prioritization efforts, and evaluation process, as well as, observing the interfaces with the operability assessment and work control processes where applicable. The teams review included verifying that the licensee considered the full extent of cause and extent of condition for problems, as well as how the licensee assessed generic implications and previous occurrences. The team assessed the timeliness and effectiveness of corrective actions, completed or planned, and looked for additional examples of similar problems. Team members conducted interviews with plant personnel to identify other processes that may exist where problems may have been identified and addressed outside the corrective action program.

The team also reviewed corrective action documents associated with past NRC-identified violations to ensure that the corrective actions addressed the issues as described in the inspection reports. The inspectors reviewed a sample of corrective actions closed to other corrective action documents to ensure that corrective actions were still appropriate and timely.

The team considered risk insights from both the NRC and Columbia Generating Station risk assessments to focus the sample selection and plant tours on risk significant systems and components. The team selected the residual heat removal and emergency core cooling systems for this risk-focused review. The teams review was focused on, but not limited to, these systems. The team also expanded their

review to include the last five years of evaluations involving the residual heat removal system, including the associated pumps, valves, and heat exchangers, to determine whether the licensee was addressing repetitive problems effectively.

b. Assessments

1. Assessment - Effectiveness of Problem Identification

The team concluded that, overall, Energy Northwest identified problems at a low threshold and entered conditions adverse to quality into the corrective action program in accordance with their corrective action program guidance and NRC requirements. The team did not identify any conditions adverse to quality that were not entered into the corrective action program. However, during a review of employee concerns program documentation, the team identified several recommendations from investigation reports that did not have an appropriate corrective action identified or assigned within the corrective action program. The licensee wrote Action Request/Condition Report 247605 to address the deficiencies.

The team reviewed the licensees list of control room deficiencies to assess whether the licensee was adequately controlling the problems. The team found that at the start of the 2011 refueling outage, the licensee had 130 deficiencies that could only be worked on during an outage. These deficiencies were characterized as operator workarounds, operator burdens, control room deficiencies, control room alarms, radwaste control room deficiencies, radwaste control room alarms, reactivity management impacts, danger clearances >90 days, caution clearances >90 days, and operator distractions. During the 2011 refueling outage, the licensee added 58 deficiencies for a total of 188 deficiencies. At the time of the inspectors review, the licensee had completed repairs to 135 deficiencies, and an additional 26 were in the process of being completed. Therefore, only 27 of 188 deficiencies remained to be addressed during the outage. The inspectors concluded that the licensee was adequately identifying, tracking, controlling, and resolving control room deficiencies during the inspection period.

2. Assessment - Effectiveness of Prioritization and Evaluation of Issues

The team concluded that the licensee appropriately prioritized and evaluated conditions adverse to quality during this assessment period. The team reviewed the prioritization of action request/condition reports guidance found in Procedure SWP- CAP-06, Condition Review Group, Revision 16. The procedure provides for six levels of severity for a condition: A, B1, B2, C1, C2, and D, in descending order. The team noted the following examples where the prioritization or evaluation of action requests/condition reports did not meet the licensees procedural guidance. However, the problems were appropriately corrected and did not impact plant safety.

• Action Request/Condition Report 224294 documented an NRC noncited violation (NCV 2010004-01) had been issued for the licensees failure to perform an

adequate risk assessment during surveillance testing. The licensee inappropriately classified this condition report as a Severity Level D (broke/fix or trend only). The licensee representative stated that this condition report was being addressed in Severity Level C1 Action Request/Condition Report 223429; however, there was no reference to the other condition report.

• Action Request/Condition Report 223429 addressed a number of identified deficiencies with the risk assessment program (i.e., Sentinel). The reviewer identified a total of 17 deficiencies over a one-year period. There were seven cases where there were either no Sentinel flag (code) on the equipment part number (EPN), on the model work order, or had an incorrect flag. There were three cases where the reviews to identify Sentinel impact were inadequate.

There were two cases where the report was incomplete or incorrect. The remaining five cases were considered isolated issues. The licensee instituted several additional barriers to ensure that incorrectly coded documents would be discovered prior to work being performed. Per Procedure SWP-CAP-06, programmatic issues should be addressed as a Severity Level B condition report; however, the licensee addressed this condition report as a Severity Level C1.

• Action Request/Condition Report 234537 identified cracks on safety-related breaker HPCS-42-4A3B. This action request/condition report was assigned at a Severity Level D and closed to actions taken. The actions performed by the licensee were limited to performing prompt operability determination without investigating the cause and source of the cracks. The licensee initiated Action Request/Condition Report 248457 to upgrade Action Request/Condition Report 234537 from Severity Level D and assign a corrective action to determine the cause of the cracks. The licensee was also re-evaluating the prompt operability determination and had successfully inspected the breaker prior to plant start-up.

• Action Request/Condition Report 231971 documented an NRC noncited violation (NCV 2010005-02) for the licensees failure to include acceptance criteria appropriate to the circumstance in Surveillance Testing Procedure ESP-B11-A101, 12 Month Battery Inspection of 125Vdc E-B1-1, Revision 5.

The evaluation in the condition report stated that this was a first time evolution using a new procedure and those batteries had never been replaced online before. The evaluation does not address why all aspects and design interfaces were not addressed. Specifically, licensee personnel listed a non-conservative inter-tier resistance value as the acceptance criterion, which led to this degraded condition being unanalyzed for three years. The licensee did not address why the acceptance criterion in the procedure was not correctly updated. Consequently, the licensee initiated Action Request/Condition Report 248359 for this oversight.

• Action Request/Condition Report 238032 documents a loss of reactor coolant system inventory during reactor pressure vessel flood-up. NRC resident inspectors determined that the method by which the licensee maintained system

configuration during reactor vessel flood-up was inadequate and documented a finding in NRC Inspection Report 2011003. Plant Procedure Manual (PPM)10.3.22, Reactor Pressure Vessel Reassembly, Revision 29, failed to ensure that the reactor head vent valves were closed in preparation to flood the main steam lines. Additionally, on May 16-17, 2007, operators were performing a similar operation to flood-up the reactor pressure vessel cavity when an estimated 25,000 gallons of reactor coolant system water was inadvertently lost because the reactor vessel head vent valves were open during vessel flood-up. This event had been documented in Problem Evaluation Request 207-0211. This report determined that the apparent cause of the event was the failure to recognize plant configuration during flood-up operations with the potential flow path from the reactor pressure vessel to the under vessel sump via the main steam line system.

The licensee addressed Action Request/Condition Report 238032 as a Severity Level C2, and revised Procedure PPM 10.3.21, Reactor Pressure Vessel Disassembly on June 28, 2011. The inspectors noted that the licensee failed to take advantage of an evaluation in 2007 to identify a similar vulnerability in a similar procedure (disassembly vs. reassembly).

3. Assessment - Effectiveness of Corrective Action Program Overall, the team concluded that the licensee generally developed appropriate corrective actions and effectively addressed problems. However, the team noted the following example where the closure documentation was incomplete, which made it difficult to determine if the corrective actions were implemented.

• Action Request/Condition Report 203348 documented an NRC noncited violation (NCV 2009008-03) of Foreign Material Exclusion (FME) requirements for failure to adequately clean out the drywell. Action 4 of Action Request/Condition Report 203348 directed the creation of a model work order for the FME close-out inspection and provided specific details on what should be included in the work order. Action 4 indicates completion on October 26, 2009, but a review of the work order revealed that none of the actions were included. Instead, the actions were included in Procedure SOP-ENTRY-DW, Personnel Entry into Drywell.

Procedure SWP-CAP-01, Corrective Action Completion, Section 4.15 paragraph 4.15.1.d. states, in part, that if a CA [corrective action] is not going to be implemented as written, closed with no action, or cancelled; then the closure narrative should include a clearly stated justification. Although the documentation was incomplete, the team determined that corrective action was appropriate for the condition.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The team examined the licensees program for reviewing industry operating experience, including reviewing the governing procedure and self-assessments. The team reviewed a sample of industry operating experience evaluations to assess whether the licensee had appropriately evaluated the notifications for relevance to

the facility. The team also reviewed assigned actions to ensure they were appropriate. The team reviewed a sample of root and apparent cause evaluations to ensure that the licensee had appropriately included industry operating experience.

b. Assessment Overall, the team determined that the licensee appropriately evaluated industry operating experience for relevance to the facility. The team determined that the licensee had entered all applicable items into the corrective action program in accordance with station procedures. The team noted that the licensee had an effective methodology for entering and tracking items into the site operating experience database and into the corrective action program as Action Request/Operational Experience Reports. The licensee used the same timeliness and management review requirements as those used for action request/condition reports. The team concluded that the licensee evaluated industry operating experience when performing root cause and apparent cause evaluations. The licensee appropriately incorporated both internal and external operating experience into lessons-learned for training and pre-job briefs.

In addition, the team reviewed six NRC information notices issued during the inspection period and found that in all cases, the licensee wrote a condition report to document the assessment and the applicability of the information notice to their facility. The team found the assessments were clearly documented and appropriate for the circumstances.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The team reviewed a sample of licensee self-assessments and audits to assess whether the licensee was regularly identifying performance trends and effectively addressing them. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. The specific self-assessment documents and audits reviewed are listed in the attachment.

b. Assessment Over the inspection period, the licensee produced dozens of self-assessments and quality assurance audits. The team reviewed 15 audits and self-assessments. The licensee was effective in utilizing experts from outside the company, to help assess performance, and appropriately entered deficient conditions into the corrective action program for resolution. The team concluded that the licensees self-assessments and audits were effective in early identification of problems. The team concluded that the licensee had a thorough and self-critical self-assessment and audit process.

.4 Assessment of Safety conscious Work Environment

a. Inspection Scope

The inspection team conducted individual and group interviews consisting of 32 station personnel. The interviewees represented various functional organizations and ranged across contractor and station staff. The team also conducted individual interviews as part of their interaction with plant staff during the inspection. These sessions were designed to elicit a qualitative assessment of the degree to which the participants believed the Energy Northwest had established and maintained a safety conscious work environment at Columbia Generating Station and were based upon the NRCs definition of a safety conscious work environment. The NRC defines safety conscious work environment as:

An environment in which employees feel free to raise safety concerns, both to their management and to the NRC, without fear of retaliation and where such concerns are promptly reviewed, given the proper priority based on their potential safety significance, and appropriately resolved with timely feedback to employees.

b. Assessment The team determined that the licensee maintained a safety conscious work environment. Based upon the responses received during the interviews, the team concluded that the licensee had established and was maintaining an environment where workers felt free to raise safety concerns both to their management and to the NRC without fear of retaliation. Most employees indicated that they would raise safety concerns to their immediate supervisor. Most employees indicated they would use the chain of command or contact the NRCs resident inspectors if their concerns were not being adequately addressed. None of the individuals could recall any occasions where they, or another employee, had been subjected to discrimination.

None of the individuals could provide examples where plant management had failed to take actions to prevent retaliation against individuals who raised safety concerns.

Several employees mentioned that they would write action request/condition reports, in addition to raising concerns to their supervisors.

However, the NRC inspection team noted that there seemed to be a lack of awareness of the Employee Concerns Program, and that it may be underused as an asset for raising safety concerns. Most employees expressed that they were not aware that the Employee Concerns Program was an avenue to raise safety concerns. Some employees commented that they believed it was for human resource issues only. Also, about 20 percent of the employees interviewed were either not aware that Energy Northwest had a safety conscious work environment policy or could not describe what the policy stated. The inspectors informed station management about this observation, and Energy Northwest was considering providing recurring training on the stations safety conscious work environment policy.

.5 Specific Issues Identified During This Inspection

a. Failure to Promptly Identify and Correct Degraded Flood Barriers

Introduction.

The team identified a Green noncited violation of 10 CFR 50, Appendix B Criterion XVI, Corrective Action, because Energy Northwest failed to promptly identify and correct degraded flood barrier floor coatings, which protected the Division 2 safety-related electrical switchgear room, remote shutdown room, and main control room from water intrusion. Specifically, from April 2004, to September 14, 2011, at least 30 action requests were written that identified degraded epoxy coated flood barriers; however, no engineering evaluation was performed to identify and correct the deficiency.

Description.

In May 2002, as documented in Problem Evaluation Report 202-1408, a flood occurred in the cable spreading room of the Radwaste Building 484-foot elevation during testing of the fire suppression system. Approximately 20 gallons of water were spilled on to the floor, and about 15 minutes later, the main control room received a ground alarm for a 125-volt DC safety-related battery. Investigation of the alarm by station personnel identified that water leaked through cracks in the concrete floor slab into the Division 2 critical 4160-volt AC electrical switchgear and remote shutdown rooms. These rooms are opposite post fire safe shutdown areas. Leakage into these rooms was through shrinkage cracks in the reinforced concrete floor slab that resulted either from initial curing of the concrete or from reinforcement anchors drilled into the concrete. This condition also existed for the entire 525-foot elevation (the elevation directly above the main control room). This event was described by the licensee as a significant condition adverse to quality. The corrective action to prevent recurrence was to apply epoxy to the floors to make them leak tight.

In April 2004, a credited flood barrier coating delaminated and cracked as documented in Action Request/Condition Report 21840. The floor coating was subsequently repaired; however, operations staff requested that an engineering evaluation be performed to ensure operability.

In July 2010, NRC resident inspectors identified degraded flood barriers in the cable spreading room of the Radwaste Building 484-foot elevation and brought it to the attention of station management. Shortly after the licensee repaired the flood barrier, the area was flooded. The licensee indicated this event was a near miss. Part of the licensees corrective actions included more frequent inspections of the area and quicker repairs when degraded barriers were identified. However, no engineering evaluations were performed that justified the adequacy of the floor coatings, operability of the equipment, or the basis for establishing an hourly flood watch.

During this inspection, the team toured the radwaste building, reviewed documentation, and interviewed station personnel with knowledge of the conditions. The team identified that the licensee categorized each degraded flood barrier at a Severity Level D - Broke Fix. Severity Level D is for conditions not adverse to quality and is the lowest of six (A, B1, B2, C1, C2, D) severity levels within the licensees corrective action program. The team determined that degradation of a credited flood barrier warranted a higher severity

level classification because it was a condition adverse to quality. Considering the repetitive nature of the material deficiency, the team determined that the licensee should have identified this condition at a severity level B2 or higher and initiated an apparent cause evaluation or root cause evaluation per Procedure SWP-CAP-06, Condition Review Group (CRG), Revision 16. Energy Northwest initiated Action Request/Condition Report 249288 to address this concern.

The team also questioned the licensees operability determination for the degraded flood barrier, and the basis for the implementation of a barrier impairment and flood watch.

The team noted that licensee corrective action program Procedure SWP-CAP-01, Step 4.2.4, required that the material deficiencies resulting in the degraded flood barrier be evaluated for operability or functionality issues in accordance with PPM 1.3.66. An operability determination is also required in accordance with Procedure PPM OI-09, Operations Standards and Expectations, paragraph 6.2.1, Revision 47. This paragraph states that, Operations SROs (senior reactor operators) determine equipment operability by evaluating equipment problems to determine if the problem affects the capability of the equipment to perform its design basis function and/or its capability to satisfy required surveillances and testing. Assistance is obtained from engineering and other organizations as necessary to complete the evaluation.

Operations staff implemented compensatory measures by issuing barrier impairments and establishing an hourly flood watch to maintain operability. The team requested to review the engineering evaluation that justified the barrier impairment, flood watch, and operability determination. However, the licensee could not locate an engineering evaluation, and concluded that it had not been done.

The team determined that from April 2004, to September 14, 2011, there were no engineering evaluations that supported the barrier impairment, flood watch frequency, or the operability of the plant equipment in the affected area. Over that same time period, the team identified 30 condition reports written about degraded floor coatings that resulted in the flood barriers being degraded approximately 36 percent of the time. The inspection team concluded that the licensee missed multiple opportunities to evaluate the adequacy of the epoxy floor coatings, hourly flood watch, barrier impairment, and operability determination. The team determined that not performing the evaluation was a performance deficiency, and resulted in a failure to promptly identify and correct a condition adverse to quality.

Energy Northwest initiated Engineering Change EC10475 on September 14, 2011, to address the inspectors concerns and evaluate the effects of degraded floor coatings on credited flood barriers. The team reviewed the evaluation and determined that further evaluation was required because EC10475 did not identify and correct the material deficiency, determine the effects of a flood on a degraded barrier, determine the adequacy of the floor coatings, justify the frequency of the flood watch, prioritize repairs, or determine the threshold for operability of any equipment protected by the flood barriers. Although, the licensee had not thoroughly evaluated the problems with the floor coating, the team observed that the repair time had decreased significantly from 85 days in 2007 to one day in 2011. Energy Northwest wrote Action Request/Condition Reports 247702 and 249288 to address this finding.

Analysis.

The failure to promptly identify (properly classify and evaluate degraded flood barriers) and correct conditions adverse to quality (degraded flood barriers) was a performance deficiency. The finding was more than minor because it affected the Mitigating Systems Cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences and that if left uncorrected, could become a more significant safety concern because a flood in the area could adversely affect safety-related equipment. Using NRC Manual Chapter 0609 Attachment 4, Phase 1 - "Initial Screening and Characterization of Findings, dated January 10, 2008, the finding initially screened as potentially risk significant due to the flooding hazard, however, it was determined to be of very low risk significance (Green)because there was no actual loss or degradation of the safety function of the equipment protected by the flood barrier. In addition, this finding had a crosscutting aspect in the area of human performance associated with the decision making component because the licensee failed to communicate to persons who have the need to know in order to perform work safely, the basis for the decision to implement an hourly flood watch and not perform an engineering evaluation in a timely manner [(H.1(c).

Enforcement.

Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion XVI Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Contrary to this requirement, from April 2004, to September 14, 2011, the licensee failed to promptly identify and correct a condition adverse to quality when credited flood barriers were degraded. Because this finding was determined to be of very low safety significance and was entered into the licensees corrective action program as Action Request/Condition Reports 247702 and 249288, this violation is being treated as a noncited violation consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000397/2011006-01, Failure to Promptly Identify and Correct Degraded Flood Barriers.

b. Failure to Follow Procedures Resulted in Unsecured Transient Equipment and Ineffective Corrective Actions

Introduction.

The team identified three examples of a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to follow the stations corrective action program and seismic procedures for the control of transient equipment and materials.

Description.

On August 29 through September 1, 2011, the team performed walkdowns of the emergency core cooling system pump rooms and the main control room. During these walkdowns, the inspectors identified violations of Energy Northwest Procedure PPM 10.2.53, Seismic Requirements For Scaffolding, Ladders, Man-Lifts, Tool Gang Boxes, Hoists, Metal Storage Cabinets, and Temporary Shielding Racks, Revision 37.

This procedure authorizes the location of transient equipment in close proximity to safety-related equipment.

The team identified two 55 gallon barrels that were stationed in close proximity to the high pressure core spray pump (HPCS-P-1). The license evaluated the condition, and determined that it would be an overturning hazard because it was placed too close to the pump berm. The barrels could fall over during a seismic event, and potentially impact pump operation. Although the plant was in an outage at the time and the HPCS-P-1 pump was not required, it was available and the staging of the equipment was not evaluated or understood by the work craft before placing the barrels near the pump.

In the main control room, the team identified the following inappropriate storage of transient equipment:

• maintenance test cart that could slide during a seismic event because the chocked wheels were ineffective in preventing sliding since the cart could move with little force

• a four case book case with an improper aspect ratio

• electrical test equipment cases

• a large rolling metal ladder

• tool boxes After the team brought these concerns to Energy Northwest management, the licensee either secured or removed the transient equipment, and entered this issue into their corrective action program as Action Request/Condition Reports 247524 and 247710.

The licensee evaluated these conditions and found that although these items were in violation of the station seismic procedure, equipment operability had been maintained.

In 2009, a NRC inspection team noted similar issues when they reviewed the licensees corrective action program. They found 26 examples during the inspection period where station personnel failed to properly store or restrain items near safety-related equipment.

Of the 26 examples, 21 were identified by either the NRC or station quality assurance inspectors. This indicated that station operations and maintenance personnel were not identifying transient equipment storage deficiencies and entering them into the corrective action program at a low threshold. The 2009 team concluded that the multiple failures of plant personnel to follow the requirements to properly secure or to perform an engineering evaluation of equipment in close proximity to sensitive equipment were indicative of a significant programmatic deficiency.

The following are examples where Energy Northwest failed to meet the requirements of Procedure PPM 10.2.53, Seismic Requirements For Scaffolding, Ladders, Man-Lifts, Tool Gang Boxes, Hoists, Metal Storage Cabinets, and Temporary Shielding Racks, Revision 37. Since the last apparent cause evaluation to determine why the failures occurred, 13 additional issues have been identified, four of which were NRC identified.

• Problem Evaluation Report 207-0443, described an NRC-identified noncited violation documented in Inspection Report 2007005 in which Work Order 01130428-20 placed scaffolding within two inches of safety related equipment.

• Action Request/Condition Report 193537 described an NRC-identified noncited violation documented in Inspection Report 2009002 that identified equipment routinely positioned next to safety-related equipment.

• Action Request/Condition Report 204514, dated September 16, 2009, described house-keeping issues in which NRC inspectors identified equipment located near safety-related systems.

• Action Request/Condition Report 230872 described an NRC-identified noncited violation documented in Inspection Report 2010005 that identified 55 gallon drums positioned next to the standby liquid control system.

• Action Request/Condition Report 244730 documented another occurrence of failing to meet Procedure PPM 10.2.53. In July 2011, an NRC inspection team performed a walkdown of the emergency diesel generator EDG-1 room, and identified that a wheeled toolbox and a lifting beam were stored near safety-related conduits. The safety-related conduits contained power cables for many emergency diesel generator EDG-1 auxiliary systems and service water pump SW-P-1A.

The second example of a failure to follow procedures was for not implementing Station Procedure SWP-CAP-06, Corrective Action Review Group (CRG), Revision 16.

7.1, area L, of the procedure, stated Severity Level A criteria include long standing problems that have had ineffective corrective actions. Severity Level A conditions required root cause evaluations. As described above, the team identified multiple examples of failures to follow the seismic procedure over a long period of time without effective corrective actions. Therefore, the team determined that this was a performance deficiency because Energy Northwest failed to properly classify this issue as a Severity Level A condition and perform a root cause evaluation.

The third example of a failure to follow procedures occurred when Energy Northwest failed to implement interim corrective actions. Specifically, while evaluating the conditions identified in Action Request/Condition Report 247524 and 247710, and completing the apparent cause evaluation for Action Request/Condition Report 244730, described above, the licensee failed to implement the following requirements of Station Procedure SWP-CAP-01, Corrective Action Program, Revision 24:

• 3.2.2.c, ensures that identified immediate and/or interim corrective actions are promptly implemented.

• 3.2.2.e, ensures corrective action plan includes a corrective action for each identified immediate or interim corrective action.

• 4.11.1.f, if CAP actions cannot be implemented in a timely manner, then the plan should include interim actions as necessary.

On September 13, 2011, when the team asked about interim corrective actions, Energy Northwest conducted a station-wide safety stand-down to communicate the requirements for the proper storage of transient equipment as an interim corrective action until longer term corrective actions could be implemented. This finding was added to Action Request/Condition Report 245159 for resolution.

In addition to Action Request/Condition Report 245159, the licensee wrote Action Request/Condition Reports 248381 and 249287 to address these findings.

Analysis.

The failure to:

(1) properly stage and evaluate if transient equipment positioned in close proximity to safety related equipment was acceptable,

(2) to classify the condition as a Severity Level A and perform a root cause evaluation, and (3)implement interim corrective actions to reduce the likelihood of recurrence, are three examples of a failure to follow procedures and is a performance deficiency. The finding was more than minor because it was a programmatic deficiency, which affected the Mitigating Systems Cornerstone objective, that if left uncorrected, could lead to a more significant safety concern because a seismic event could result in the unavailability of systems used to mitigate the consequences of initiating events. Using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance (Green) because it did not result in an actual loss of a system safety function, did not result in a loss of a single train of safety equipment for greater than its technical specification allowed outage time, did not involve the loss or degradation of equipment specifically designed to mitigate a seismic, flooding, or severe weather initiating event, and did not involve the total loss of any safety function that contributes to an external event initiated core damage accident sequence. In addition, this finding had a crosscutting aspect in the area of human performance associated with the work control component because the licensee failed to appropriately plan work on multiple occasions, resulting in job site conditions which may have impacted plant components H.3(a).

Enforcement.

Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be accomplished in accordance with documented procedures appropriate to the circumstances. Contrary to this requirement, on September 1 - 15, 2011, and other dates, Energy Northwest failed to:

(1) properly stage and evaluate the seismic interaction of equipment placed next to safety related components as required by Station Procedure PPM 10.2.53, Seismic Requirements For Scaffolding, Ladders, Man-Lifts, Tool Gang Boxes, Hoists, Metal Storage Cabinets, and Temporary Shielding Racks, Revision 37;

(2) classify this issue as a Severity Level A condition and perform the required root cause evaluation as required by Station Procedure SWP-CAP-06, Corrective Action Review Group (CRG), Revision 16; and

(3) implement interim corrective actions to reduce the likelihood the condition would be repeated before longer term actions could be implemented as required by Station Procedure SWP-CAP-01, Corrective Action Program, Revision 24. Because this finding was of very low safety

significance and was entered into the licensees corrective action program as Action Request/Condition Reports 245159, 247710, 248381, and 249287, this violation is being treated as a noncited violation, consistent with Section 2.3.2 of the Enforcement Policy:

NCV 05000397/2011006-02, Three Examples of a Failure to Follow Procedures Results in Unsecured Transient Equipment and Ineffective Corrective Actions.

c. Failure to Survey

Introduction.

The team reviewed a self-revealing noncited violation of 10 CFR Part 20.1501(a), for the failure to survey the residual heat removal pump A room after it was secured from service. Specifically, on August 29, 2011, during a tour with the NRC inspection team, the residual heat removal system engineer received a dose rate alarm.

Dose rates in the area were as high as 120 millirem per hour at 30 centimeters from the suction piping of the pump, which required the area to be posted and barricaded as a high radiation area.

Description.

On August 29, 2011, the team toured the residual heat removal A (RHR-A)pump room with the system engineer. A few minutes after the team entered the pump room the system engineers electronic dosimeter alarmed. The group exited the area and contacted the radiation protection staff. Subsequent surveys of the area by the radiation protection staff indicated dose rates in excess of 100 millirem per hour at 30 centimeters from the source, which required the area to be controlled as a high radiation the area. Detailed surveys indicated that dose rates between the RHR suction piping and the pump were as high as 120 millirem per hour at 30 centimeters. Once the high radiation area was identified, the licensee appropriately controlled the area.

On August 20, 2011, RHR-A pump was secured and RHR-B pump was started for shutdown cooling. The team interviewed radiation protection and operations personnel, reviewed plant logs and surveys, and determined that miscommunication between operations and radiation protection technicians led to a misunderstanding of exactly what time the RHR-A pump would be secured. At 7:30 a.m., on August 20, 2011, the Radiologically Controlled Area Control Point was notified by operations that shutdown cooling would be transferred from RHR-A to RHR-B. At 8:15 a.m., radiation protection technicians performed a survey of both RHR-A and RHR-B pump rooms. This survey was not documented because the swap had not occurred. At approximately 9:45 a.m.,

radiation protection technicians received another call from operations informing them of the RHR-B pump start, however the exact start time was not provided. Operations did not contact radiation protection technicians again after this time. Radiation protection technicians performed another survey of the pump rooms, and concluded that since the radiological conditions had not changed the swap had not occurred. This survey was not documented.

Control room logs indicate that RHR-B was started at 11:41 a.m., and RHR-A pump was secured at 11:48 a.m. No documented surveys could be located after the pumps were swapped. Station Procedure PPM 11.2.13.1, Radiation and Contamination Surveys, Revision 28, requires surveys following changes to the RHR system. However, the procedure did not direct surveys to be performed at any particular time after changes to

the RHR system. As a result, the licensee concluded that after some time had elapsed, settling of radioactive particles in the system piping caused radiation levels in the RHR-A pump room to increase resulting in the unidentified high radiation area. Prior to the swap of RHR pumps, the area was surveyed and posted as a radiation area with dose rates in range of 40 - 60 millirem per hour. Therefore, between August 20 and August 29, 2011, survey information for this area was incorrect because there was an unposted high radiation area present with dose rates up to 120 millirem per hour at 30 centimeters from the suction piping of RHR-A pump. The inspectors concluded that the failure to survey violated Energy Northwest and NRC requirements. The licensee entered this condition into their corrective action program as Action Request/Condition Reports 247454 and 247572.

Analysis.

The failure to perform a survey to evaluate the magnitude and extent of radiation levels in the residual heat removal A pump room is a performance deficiency.

The finding was more than minor because it was associated with the Occupational Radiation Safety Cornerstone exposure control attribute of program and process, and it affected the cornerstone objective because it resulted in an unposted high radiation area that affected the licensees ability to adequately protect worker health and safety from exposure to radiation. Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance because it was not an ALARA finding, there was no overexposure or substantial potential for an overexposure, and the ability to assess dose was not compromised. In addition, this finding had a crosscutting aspect in the area of human performance associated with the work control component because the planned work activities did not incorporate the need for compensatory actions (e.g., surveys) to detect delayed changes in radiological conditions H.3(a).

Enforcement.

Title 10 of the Code of Federal Regulations Part 20.1501(a) requires, in part, that each licensee shall make surveys that evaluate the magnitude and extent of radiation levels. Contrary to the above, between August 20 and August 29, 2011, Energy Northwest failed to make surveys that evaluated the magnitude and extent of radiation levels in the RHR-A pump room. Because this finding was of very low safety significance and was entered into the licensees corrective action program as Action Request/Condition Reports 247454 and 247572, this violation is being treated as a noncited violation, consistent with Section 2.3.2 of the Enforcement Policy:

NCV 5000397/2011006-03, Failure to Survey.

4OA6 Meetings

Exit Meeting Summary

On September 15, 2011, the team presented the inspection results to Mr. Brad Sawatzke, Vice-President and Chief Nuclear Officer, and other members of the licensee staff. The licensees staff acknowledged the issues presented. The team confirmed that no proprietary information was provided to the team.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

S. Ackley, Supervisor, Maintenance Support

B. Abduljalil, Component Engineer

J. Bekhazi, Manager, Maintenance

I. Borland, Supervisor, Organizational Effectiveness

K. Calibo, Engineer, Design Engineering

S. Christianson, Root Cause Analyst, Organizational Effectiveness

M. Davis, Manager, Radiation Protection

Z. Dunham, Supervisor, Licensing

D. Gregoire, Manager, Regulatory Affairs

W. Harper, Fire Protection Engineer

M. Huiatt, Principal Licensing Engineer, Regulatory Affairs

C. King, Assistant Plant General Manager

B. MacKissock, Plant General Manager

D. Mand, Manager, Design Engineering

R. McQuioid, Principal Engineer

C. Moon, Manager, Training

T. Mustafa, Senior Engineer, Electrical

R. Parmelee, Manager, System Engineering

B. Sawatzke, Chief Nuclear Officer

R. Seidel, Principal Engineer, System Engineering

A. Sperling, Principal Engineer

D. Swank, General Manager, Engineering

R. Torres, Manager, Quality Assurance

R. Walton, Support Specialist, Operations

J. Watt, Program Specialist, Maintenance

S. Wood, Manager, Organizational Effectiveness

NRC Personnel

J. Groom, Senior Resident Inspector

M. Hayes, Resident Inspector

Attachment 1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

05000397/2011006-01 NCV Failure to Promptly Identify and Correct Degraded Flood Barriers (Section 4OA2)

05000397/2011006-02 NCV Three Examples of a Failure to Follow Procedures Results in Unsecured Transient Equipment and Ineffective Corrective Actions (Section 4OA2)

05000397/2011006-03 NCV Failure to Survey (Section 4OA2)

Closed

None

Discussed

None Attachment 1