IR 05000397/2019010

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NRC Problem Identification and Resolution Inspection Report 05000397/2019010
ML19119A110
Person / Time
Site: Columbia 
Issue date: 04/25/2019
From: Ray Kellar
Division of Reactor Safety IV
To: Sawatzke B
Energy Northwest
Kellar R
References
IR 2019010
Download: ML19119A110 (19)


Text

April 25, 2019

SUBJECT:

COLUMBIA GENERATING STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000397/2019010

Dear Mr. Sawatzke:

On March 21, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Columbia Generating Station. On March 21, 2019, the NRC inspectors discussed the results of this inspection with yourself and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Overall, the team concluded that all work groups at Columbia Generating Station maintained a healthy safety-conscious work environment.

No NRC-identified or self-revealing findings were identified during this inspection. However, the team documented a licensee-identified violation which was determined to be of very low safety significance, in this report. The NRC is treating this violation as a non-cited violation (NCV)

consistent with Section 2.3.2 of the Enforcement Policy. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Ray L. Kellar, P.E., Team Leader Inspection Program and Assessment Team Division of Reactor Safety

Docket No. 05000397 License No. NPF-21

Enclosure:

Inspection Report 05000397/2019010

w/ Attachment: Information Request

dated January 9, 2019

Inspection Report

Docket Number:

05000397

License Number:

NPF-21

Report Number:

05000397/2019010

Enterprise Identifier: I-2019-010-0015

Licensee:

Energy Northwest

Facility:

Columbia Generating Station

Location:

Richland, Washington

Inspection Dates:

March 03, 2019, to March 21, 2019

Inspectors:

I. Anchondo, Reactor Inspector

R. Azua, Senior Reactor Inspector

E. Combs, (Acting) Resident Inspector (RIDP)

N. Greene, PhD, Senior Health Physicist

Approved By:

Ray L. Kellar, P.E., Team Leader

Inspection Program and Assessment Team

Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a problem identification and resolution inspection at Columbia Generating Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

Findings and violations being considered in the NRCs assessment are summarized in the table below. One licensee-identified non-cited violation is documented in report section: 71152

List of Findings and Violations

No findings were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs)in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.

Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

The inspectors performed a biennial assessment of the licensee's corrective action program, use of operating experience, self-assessments and audits, and safety-conscious work environment (SCWE).

Corrective Action Program Effectiveness: The inspectors assessed the corrective action program's effectiveness in identifying, prioritizing, evaluating, and correcting problems and to confirm that the station was complying with NRC regulations and licensee procedures.

The team selected a sample of approximately 250 condition reports for review, out of those that had been generated over the course of the assessment period, beginning at the end of the previous biennial assessment on March 4, 2017. The selection included corrective actions documents associated with 29 findings documented as non-cited violations in NRC inspection reports during the assessment period, and all 7 conditions that had been addressed as root cause evaluations. Included in the sample was an in-depth review of condition reports associated with the residual heat removal system over a 5-year period. A listing of the documents can be found in the documents reviewed section of this report.

Operating Experience, Self-Assessments, and Audits: The team evaluated the station's processes for use of industry and NRC operating experience. The team also evaluated the effectiveness of the station's audits and self-assessment program. The sample included industry operating experience communications including Part 21 notifications and other vendor correspondence, NRC generic communications, and publication from various industry groups including Institute of Nuclear Power Operations (INPO) and Electric Power Research Institute (EPRI), plus associated site evaluations.

Safety-Conscious Work Environment: The team evaluated the station's SCWE. The team interviewed 50 station personnel in seven focus groups. The individuals were selected randomly from operations, radiation protection, mechanical and electrical maintenance, and instrumentation and controls. In addition, the team also interviewed the employee concerns program manager.

INSPECTION RESULTS

Observation 71152B - Problem Identification and Resolution Corrective Action Program Assessment

Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the staff's performance in this area adequately supported nuclear safety. Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety. On average, the licensee was identifying and documenting approximately 580 Action Request-Condition Reports (AR-CRs) per month.

Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team found that the licensee correctly characterized each condition report as to whether it represented a condition adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance. However, the team did identify several examples where the licensee made determinations that they knew the cause of an event without any additional evaluation. This resulted in some causal determinations that precluded broader considerations and corrective actions that were narrowly focused.

Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. However, as described above, the team identified several examples where the licensee's corrective actions were too narrowly focused. This had a negative effect in one area, specifically, delaying the licensee's ability to identify a growing concern related to procedural compliance at the facility.

Corrective Action Program Assessment: Based on the samples reviewed, the team determined that the licensee's corrective action program complied with regulatory requirements and self-imposed standards, and that the licensee's implementation of the corrective action program adequately supported nuclear safety. The team found that management's oversight of the corrective action program process was effective.

Observation 71152B - Problem Identification and Resolution Operating Experience: The team reviewed a variety of sources of operating experience including Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups including INPO and EPRI. The team determined that Columbia Generating Station is adequately screening and addressing issues identified through operating experience that apply to the station and that this information is evaluated in a timely manner once it is received.

Self-Assessments and Audit Assessment: The team reviewed a sample of the licensee's departmental self-assessments and audits to assess whether they regularly identified performance trends and effectively addressed them. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team concluded that the licensee had an adequate departmental self-assessment and audit process.

As part of the inspection, the team focused on the radiation protection (RP) program. The team's overall assessment aligned with the results of the licensees audits and trend assessments reviewed. The inspectors reviewed numerous documents that focused on audits and trend analysis. This included multiple quality service audit reports focused on RP and related activities, a focused self-assessment on radiological hazard assessment and exposure controls, and numerous functional area scorecard (FAS) reports in RP between 2017 and 2019. This also included five trend condition reports in various areas of RP. Overall, the team found that the licensee had experienced significant issues in the radioactive waste shipping program, as well as a significant amount of high radiation area deficiencies. Trends also showed adverse results in electronic dosimeter alarms, both dose and dose rate, throughout the period. Most of these issues were due to human performance errors, such as failing to adhere to procedural requirements, poor decision making, and weak supervisory oversight. In short, the audits reviewed identified an organizational weakness in radiological waste shipping and associated areas of RP.

The licensee also provided an in-depth audit of the Warehouse in AR 386673386673 In this audit, numerous issues were identified and adequately corrected.

Another example of licensee self-assessments and audits was the quality assurance audit report of the corrective action program. This audit identified the following:

  • the audit team identified a consistently high number of procedure use and adherence events over the 2-year audit period within each of the 19 audits and several surveillancesThis recurring theme has gone unrecognized and unresolved at the station levelthis is a strong indication that behavioral shortfalls exist that could result in more significant procedural non-complianceThe audit team identified this as an Area Requiring Management Attention (ARMA)."

These conclusions mirrored the NRCs conclusions identified during the agencys 2018 End-of-Cycle-Assessment for the Columbia Generating Station and the teams observations made during this inspection. Having said that, even though the team found the audit to be thorough, the licensees response to this concern did not include a wide-ranging evaluation to determine the cause. Instead, the licensee determined that the cause was known and developed corrective actions that were narrowly focused around that determination. Although there is always a chance that the determination was adequate, and that the corrective actions may be effective, the team concluded that an opportunity was being missed with regard to identifying other contributing causes to the procedural compliance failure concern. Licensee management indicated during the exit meeting that they understood the team's concern and committed to perform a more in-depth review of the cause for this identified theme.

Observation 71152B - Problem Identification and Resolution Safety-Conscious Work Environment: The team interviewed approximately 50 individuals in seven group interviews. The purpose of these interviews was to:

(1) evaluate the willingness of your staff to raise nuclear safety issues, either by initiating a CR or by another method; (2)evaluate the perceived effectiveness of the corrective action program at resolving identified problems; and
(3) evaluate your SCWE. The focus group participants included personnel from operations, radiation protection, mechanical and electrical maintenance, and instrumentation and controls. Overall, Columbia Generating Station has an adequate SCWE.

Willingness to Raise Nuclear Safety Issues: In most focus groups, the team found no evidence of challenges to the SCWE. Individuals in these groups expressed a willingness to raise nuclear safety concerns and other issues through at least one of the several means available. However, the team found some work environment challenges in the maintenance department (mechanical, electrical and instrumentation and controls). Through interviews with the staff members, the team identified a significant decline in morale that appears to permeate throughout the maintenance department work environment. This degradation in morale appears to be caused by departmental management decisions that have resulted in several grievances by the staff against their management. The team brought this observation to senior plant managements attention. While not currently affecting the SCWE, the team discussed with station management that continued degradation of staff morale could negatively impact staff performance. Specifically, distracted people make mistakes.

Overall, the team concluded that all work groups at Columbia Generating Station maintained a healthy SCWE.

Licensee-Identified Non-Cited Violation 71152B - Problem Identification and Resolution This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Technical Specification 5.7.2, High Radiation Areas with Dose Rates Greater than 1.0 rem/hour (at 30 cm from the radiation source), paragraph (a), requires, in part, that each entryway to such an area shall be conspicuously posted as a high radiation area and shall be provided with a locked or continuously guarded door or gate that prevents unauthorized entry.

Contrary to the above, on February 4, 2019, the licensee identified an entryway to a high radiation area, with dose rates greater than 1.0 rem per hour (at 30 cm from the radiation source), where the licensee failed to conspicuously post as a high radiation area and provide a locked or continuously guarded door or gate that would have prevented unauthorized entry. Specifically, a health physics technician (HPT) was performing walkdowns of the residual heat removal (RHR) heat exchanger A area, which was controlled as a high radiation area (HRA), and the north pipe space area, controlled as a locked high radiation area (LHRA), on the 548-foot elevation of the reactor building. During the walkdown, the HPT identified a concern that individuals with access to the scaffold in the RHR Heat Exchanger A area could gain access to the North Pipe Space LHRA via an open pipe chase, and nearby solid structures, that connected the two rooms. The scaffold was constructed in 2013 and numerous work activities had occurred in the area between 2013 and 2017. The HPT contacted radiation protection (RP) management and expressed a concern. In response, RP management immediately assessed the area and determined the concerns were valid, and thus, constructed a fencing barrier with LHRA posting to control access to the pipe chase which leads to the north pipe space LHRA. The barrier was constructed at the entry point from the RHR Heat Exchanger A room to the pipe chase. The maximum dose rates in the LHRA were measured at 4.3 rem per hour on contact and 2.0 rem per hour at 30 cm from the source. The newly constructed fenced barrier was locked with a LHRA padlock.

The RP management team then conducted an extent of condition assessment and determined there were no additional areas in the plant subject to the same concerns.

Significance: Green.

Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, the inspectors determined:

(1) the finding was not related to ALARA planning,
(2) the finding did not involve an overexposure or substantial potential for overexposure,
(3) and the ability to assess dose was not compromised. For these reasons, the inspectors concluded that the finding is of very low safety significance (Green).

Corrective Action Reference: CR

EXIT MEETINGS AND DEBRIEFS

On March 21, 2019, the team presented the Columbia Generating Stations biennial problem identification and resolution inspection results to Mr. B. Sawatzke, Chief Executive Officer, Energy Northwest, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71152B

Corrective

Action

Documents

Apparent

Cause

Evaluation

(ACE)

2217, 352504, 353427,

35690, 357593, 358265,

361053, 366193, 366701,

368651, 36215, 373739, 375372

AR-CR-

XXXXX

234254, 279896, 303326,

336352, 348071, 352217,

2504, 353427, 355646,

356390, 356854, 357388,

357593, 357962, 357985,

358027, 358055, 358265,

359059, 359064, 359066,

359162, 359286, 359498,

359731, 360148, 360236,

360447, 360595, 360869,

361029, 361053, 361412,

361652, 362767, 362853,

363774, 364189, 364345,

364765, 364792, 364950,

365390, 365459, 365499,

365523, 365814, 365900,

365903, 365917, 366193,

366567, 366615, 366640,

366701, 366846, 366859,

366869, 366906, 366960,

366967, 367245, 367419,

367483, 367649, 367679,

367723, 367726, 367727,

367730, 367766, 367768,

367770, 367771, 367773,

367774, 367781, 367782,

367783, 367830, 367835,

367873, 368063, 368181,

368222, 368480, 368651,

368734, 368761, 368853,

368872, 368921, 368924,

369137, 369180, 369181,

369215, 369479, 369956,

370193, 370326, 370357,

370460, 370529, 370737,

370813, 370966, 371020,

371085, 371129, 371264,

371429, 371575, 371576,

371577, 371578, 371579,

371580, 371581, 371582,

371583, 371608, 371625,

371627, 371699, 371713,

371867, 372049, 372267,

2423, 372490, 372513,

2615, 372684, 372905,

2932, 373004, 373056,

373141, 373519, 373654,

373739, 373778, 373781,

373849, 373903, 374037,

374115, 374237, 374238,

374320, 374519, 374666,

374705, 375372, 376040,

376119, 376172, 376326,

376476, 376658, 376921,

377003, 377024, 377029,

377305, 377412, 377572,

378237, 378281, 378368,

378835, 378892, 379991,

380054, 380144, 380152,

380236, 380682, 380695,

381017, 381551, 384338,

385226, 385568, 385609,

385691, 386402, 386505,

386670, 386673, 386680,

386750, 386965, 387172,

387202, 387428, 387493,

387494, 387502, 387577,

387653, 387700, 387720,

387768, 387771, 387795,

388037, 388173, 388782,

388941, 389235, 389399,

389632, 389652, 389977,

390075, 390200, 390321,

390662, 390668, 390812,

390819, 391129, 391135,

391147, 391149

HUIT/OPIT

388173, 389652, 390321,

390812

Root Cause

Evaluations

(RCE)

211422, 291250, 303326,

2078, 348071, 360236,

370326

Engineering

Changes

EC 16398

Procedures

1.3.1

Operating Policies, Programs

and Practices

27

1.3.29

Locked Valve Checklist

1.3.81

Maintaining Plant Component

Status Control

1.3.9

Temporary Modifications

CBP-01

Circuit Breaker Program

CDM-01

Cause Determination Manual

EGM-1-8

Technical Issue Resolution

Process

EGM-1-9

Single Point Vulnerability

Review Process

GBP-AIT-01

Action Request - Business

Process for Type Self

GBP-CAP-01

Non-Regulatory Action Program

GBP-CAP-04

Corrective Action Review Board

(CARB)

GBP-HR-18

Performance Improvement

GBP-IRP-02

Event Investigation

GBP-ORG-01

Performance Monitoring

MI-1.8

Conduct of Maintenance

OI-09

Operations Standards and

Expectation

OPEX-01

Operating Experience Program

Implementation Manual

OQADP-01

Operational Quality Assurance

Program Description

PMM 1.11.15

Control of Radioactive Material

11, 12

PPM 10.3.24

Processing of Irradiated Nonfuel

Material

PPM

11.2.13.1

Radiation and Contamination

Surveys

PPM

11.2.14.9

Control and Labeling of

Radioactive Material

PPM

11.2.2.14

Radiological Planning and

Reviews

3, 4

PPM

11.2.23.2

Shipping Radioactive Materials

and Waste

PPM

11.2.23.2

Computerized Radioactive

Waste and Material

Characterization

PPM

11.2.23.39

Operation of the Self Engaging

Dewatering System (SEDS)

1, 2

PPM

11.2.23.4

Packaging Radioactive Material

and Waste

PPM

11.2.23.44

Operation of the Self Engaging

Rapid

4, 5

PPM

11.2.23.45

Management of Spent Fuel Pool

Filters, Irradiated, and Non-

Irradiated Items to Support

Packaging, Transportation, and

Disposal as Low-Level

Radwaste

PPM

11.2.23.9

Packaging, Transportation, and

Disposal of Radioactive Waste

at the US Ecology, Richland

Radioactive Waste Disposal

Facility

1, 3

PPM 11.2.7.1

Area Posting

2, 43, 44

PPM 11.2.7.3

High Radiation Area, Locked

High Radiation Area, and Very

High Radiation Area Controls

PPM 6.1.1

Spent Fuel Pool Inventory

SCSI-5.4

Control and Disposition of Non-

Conforming Material

SOP-DG-

DCW

Emergency Diesel Generator

Jacket Water Cooling

SOP-RFT-

START

Reactor Feedwater Turbine

System Start

SWP-AIT-01

Action Request - Initiation,

Evaluation, and Assignment

SWP-CAP-01

Corrective Action Program

36, 37, 38,

SWP-CAP-06

Condition Report Review

23, 24, 25

SWP-MMP-

Warehousing

SWP-OPX-01

Operating Experience Program

SWP-RPP-01

Radiation Protection Program

15, 16

Self-

Assessments

AR-SA

375035-06

Quality Services Audit Program -

Radiological Hazard

Assessment and Exposure

Controls

07/09/2018

AU-CA-18

Quality Services Audit Report -

Corrective Action Program

01/02/2019

AU-CH-18

Quality Services Audit Program -

Chemistry and Environmental

Monitoring Program

11/08/2018

AU-DC-18

Quality Services Audit Report -

Independent Spent Fuel Storage

Facility (ISFSI) Program

04/26/2018

AU-MN-17

Quality Services Audit Report -

Maintenance Program

03/03/2017

AU-RP/RW-

Quality Services Audit Report -

Radiation Protection and

Process Control Program

2/21/2017

Work Orders

WO 01092501, 01176607,

2007100, 02033672,

2043358, 02061351,

2072924, 02077965,

2082026, 02084627,

2084629, 02105645,

2115933, 02118831, 02130268

WR 29132464, 29137373,

29140364, 29140745,

29140746, 29140747

Information Request

Biennial Problem Identification and Resolution

Inspection Columbia Generating Station

January 9, 2019

Inspection Report: 50-397/2019010

On-site Inspection Dates: March 04-08 & March 18-22, 2019

This inspection will cover the period from March 3, 2017, through March 22, 2019. All

requested information is limited to this period or to the date of this request unless otherwise

specified. To the extent possible, the requested information should be provided electronically

in word-searchable Adobe PDF (preferred) or Microsoft Office format. Any sensitive

information should be provided in hard copy during the teams first week on site; do not

provide any sensitive or proprietary information electronically.

Lists of documents (summary lists) should be provided in Microsoft Excel or a similar sortable

format. Please be prepared to provide any significant updates to this information during the

teams first week of on-site inspection. As used in this request, corrective action documents

refers to condition reports, notifications, action requests, cause evaluations, and/or other

similar documents, as applicable to the Columbia Generating Station.

Please provide the following information no later than February 18, 2019:

i.

Document Lists

Note: For these summary lists, please include the document/reference number, the

document title, initiation date, current status, and long-text description of the issue.

a.

Summary list of all corrective action documents related to significant

conditions adverse to quality that were opened, closed, or evaluated during

the period

b.

Summary list of all corrective action documents related to conditions adverse

to quality that were opened or closed during the period

c.

Summary list of all apparent cause evaluations (or equivalent) performed

during the period; if fewer than approximately 20, provide full documents

d.

Summary list of all currently open corrective action documents associated

with conditions first identified any time prior to January 1, 2017, including

prior to the beginning of the inspection period

e.

Summary lists of all corrective action documents that were upgraded or

downgraded in priority/significance during the period (these may be limited

to those downgraded from, or upgraded to, apparent-cause level or higher)

f.

Summary list of all corrective action documents initiated during the period

that identify an adverse or potentially adverse trend in safety-related or risk-

significant equipment performance or in any aspect of the stations safety

culture.

g.

Summary lists of operator workarounds, operator burdens, temporary

modifications, and control room deficiencies (1) currently open and (2) that

were evaluated and/or closed during the period; this should include the date

that each item was opened and/or closed.

h.

Summary list of all prompt operability determinations or other

engineering evaluations to provide reasonable assurance of operability

i.

Summary list of plant safety issues raised or addressed by the Employee

Concerns Program (or equivalent) (sensitive information should be made

available during the teams first week on sitedo not provide

electronically)

j.

Summary list of all Apparent Cause Evaluations completed during the

period

2. Full Documents with Attachments

a.

Root Cause Evaluations completed during the period; include a list of

any planned or in progress

b.

Quality Assurance audits performed during the period

c.

Audits/surveillances performed during the period on the Corrective

Action Program, of individual corrective actions, or of cause

evaluations

d.

Functional area self-assessments and non-NRC third-party assessments (e.g.,

peer assessments performed as part of routine or focused station self-and

independent assessment activities; do not include INPO assessments) that

were performed or completed during the period; include a list of those that are

currently in progress

e.

Any assessments of the safety-conscious work environment at the

Columbia Generating Station, including any safety culture survey

results; if none performed during the inspection period, provide the most

recent

f.

Corrective action documents generated during the period associated with

the following:

i.

NRC findings and/or violations issued to the Columbia Generating

Station

ii.

Licensee Event Reports issued by the Columbia Generating Station

g.

Corrective action documents generated for the following, if they were

determined to be applicable to the Columbia Generating Station (for those

that were evaluated but determined not to be applicable, provide a summary

list):

i.

NRC Information Notices, Bulletins, and Generic Letters

issued or evaluated during the period

ii.

Part 21 reports issued or evaluated during the period

iii.

Vendor safety information letters (or equivalent) issued or

evaluated during the period

iv.

Other external events and/or Operating Experience evaluated

for applicability during the period

h.

Corrective action documents generated for the following:

i.

Maintenance preventable functional failures which occurred or

were evaluated during the period

ii.

Adverse trends in equipment, processes, procedures, or

programs that were evaluated during the period

iii.

Action items generated or addressed by offsite review committees

during the period

3. Logs and Reports

a.

Corrective action performance trending/tracking information generated during

the period and broken down by functional organization (if this information is

fully included in item 3.b, it need not be provided separately)

b.

Current system health reports, Management Review Meeting package, or

similar information; provide past reports as necessary to include 12 months of

metric/trending data

c.

Radiation protection event logs during the period

d.

Security event logs and security incidents during the period (sensitive

information should be made available during the teams first week on sitedo

not provide electronically)

e.

Employee Concern Program (or equivalent) logs (sensitive information should

be made available during the teams first week on sitedo not provide

electronically)

f.

List of training deficiencies, requests for training improvements, and

simulator deficiencies for the period

Note: For items 3.c-3.d, if there is no log or report maintained separate from the

corrective action program, please provide a summary list of corrective action

program items for the category described.

4.

Procedures

Note: For these procedures, please include all revisions that were in effect at any time

during the period.

a.

Corrective action program procedures, to include initiation and evaluation

procedures, operability determination procedures, cause evaluation

procedures, and any other procedures that implement the corrective action

program at the Columbia Generating Station

b.

Quality Assurance program procedures (specific audit procedures are

not necessary)

c.

Employee Concerns Program (or equivalent) procedures

d.

Procedures which implement/maintain a Safety-Conscious Work Environment

e.

Conduct of Operations procedure (or equivalent) and any other procedures or

policies governing control room conduct, operator burdens and workarounds,

etc.

f.

Operating Experience (OpE) program procedures and any other procedures or

guidance documents that describe the sites use of OpE information

5. Other

a.

List of risk-significant components and systems, ranked by risk worth; if the list

uses system designators, provide a list of the associated equipment/system

names

b.

List of structures, systems and components and/or functions that were in

maintenance rule(a)(1) status or evaluated for (a)(1) status at any time during

the inspection period; include dates and results of expert panel reviews and

dates of status changes

c.

Organization charts for plant staff and long-term/permanent contractors

d.

Electronic copies of the UFSAR (or equivalent), technical specifications,

and technical specification bases, if available

e.

Table showing the number of corrective action documents (or equivalent)

initiated during each month of the inspection period, by screened

significance

f.

For each day the team is on site,

i.

Planned work/maintenance schedule for the station

ii.

Schedule of management or corrective action review meetings (e.g.

operations focus meetings, condition report screening meetings,

CARBs, MRMs, challenge meetings for cause evaluations, etc.)

iii.

Agendas and materials for these meetings

Note: The items listed in 5.f may be provided on a weekly or daily basis after

the team arrives on site.

All requested documents should be provided electronically where possible. Regardless of

whether they are uploaded to an internet-based file library (e.g., Certrecs IMS), please provide

copies on CD or DVD. One copy of the CD or DVD should be provided to the resident

inspector office at the Columbia Generating Station; three additional copies should be provided

to the team lead, to arrive no later than February 18, 2018:

Ray Azua

U.S. NRC Senior Reactor Inspector

Inspection Program and Assessment Team

Division of Reactor Safety, Region IV

1600

E. Lamar Blvd, Arlington, TX 76011

Office: (817) 200-1445

Cell: (817) 319-4376

PAPERWORK REDUCTION ACT STATEMENT

This request does not contain new or amended information collection requirements subject to the Paperwork

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the

Office of Management and Budget, control number 3150-0011.

ML19119A110

SUNSI Review: ADAMS:

Non-Publicly Available Non-Sensitive Keyword: NRC-002

By: RVA Yes No

Publicly Available

Sensitive

OFFICE

IPAT:SRI

RIB:SHP

EB2:RI

PBA:ARI

IPAT:TL

PBA:BC

IPAT:TL

NAME

RAzua

NGreene

IAnchondo

ECombs

RKellar

MHaire

RKellar

SIGNATURE

/RA/

/RA/

/RA/

/RA/

/RA/

/RA/

/RA/

DATE

04/24/2019

04/24/2019

04/24/2019

04/24/2019

04/24/2019

04/25/2019

04/25/2019