IR 05000397/2020003
| ML20356A030 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/21/2020 |
| From: | Jeffrey Josey NRC/RGN-IV/DRP/RPB-A |
| To: | Sawatzke B Energy Northwest |
| References | |
| IR 2020003 | |
| Download: ML20356A030 (35) | |
Text
December 21, 2020
SUBJECT:
COLUMBIA GENERATING STATION - REVISED INTEGRATED INSPECTION REPORT 05000397/2020003
Dear Mr. Sawatzke:
On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Generating Station. The results of this inspection were originally issued in a report, dated October 28, 2019 (Agencywide Document Access and Management System (ADAMS) Accession No. ML20302A231).
The NRC staff subsequently determined that due to an administrative oversight, the inspection activities associated with Inspection Procedure 71153, Follow-up of Events and Notices of Enforcement Discretion, were documented as one sample each under event follow-up (IP Section 03.01) and personnel performance (IP Section 03.03), when in fact it should have been documented as two samples under personnel performance. The revised inspection report correcting this error is enclosed. This change had no impact on the findings documented in this report, but consistent with NRC processes, this report is being reissued in whole. 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Jeffrey E. Josey, Chief Reactor Projects Branch A Division of Reactor Projects
Docket No. 05000397 License No. NPF-21
Enclosure:
As stated
Inspection Report
Docket Number:
05000397
License Number:
Report Number:
Enterprise Identifier: I-2020-003-0011
Licensee:
Energy Northwest
Facility:
Columbia Generating Station
Location:
Richland, WA
Inspection Dates:
July 1, 2020 to September 30, 2020
Inspectors:
A. Patz, Senior Resident Inspector
C. Roettgen, Senior Resident Inspector
L. Merker, Resident Inspector
N. Greene, Senior Health Physicist
J. ODonnell, Senior Health Physicist
D. Antonangeli, Health Physicist
B. Tharakan, Technical Assistant
Approved By:
Jeffrey E. Josey, Chief
Reactor Projects Branch A
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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.
List of Findings and Violations
Failure to Perform an Adequate Radiation Survey to Identify and Control a High Radiation Area Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000397/2020003-01 Open/Closed
[H.14] -
Conservative Bias 71124.01 The inspectors reviewed a self-revealed, Green, non-cited violation of 10 CFR 20.1501(a), for the licensees failure to perform an adequate radiological survey and identify a high radiation area. Specifically, on May 30, 2019, Radiation Protection personnel were notified by a radiation worker about an unanticipated self-reading dosimeter dose rate alarm while the worker was decontaminating equipment within a posted high contamination area (HCA) on the refuel floor (606-foot elevation of the reactor building). Radiation Protection personnel did not perform a survey to verify the radiological conditions in the work area and allowed the work to continue. The workers were later asked to exit the area when it was determined that the work could not be completed within the allotted dose limit set point.
Failure to Follow ALARA Planning Procedures Resulting in Unplanned Dose on a Work Activity Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000397/202003-02 Open/Closed
[H.5] - Work Management 71124.02 The inspectors reviewed a self-revealed, Green, non-cited violation Technical Specification (TS) 5.4.1 because the licensee failed to follow their as low is reasonably achievable (ALARA)planning procedures resulting in unplanned dose while performing the control rod drive mechanism (CRDM) replacement work. Specifically, the licensees procedure instructed them to obtain data on the actual radiological conditions in the work area prior to commencement of the job and determine the effective dose rate using corrected historical data for the current scope and radiological conditions in the radiation work permit (RWP) planning phase. The licensee initially planned the job for approximately 6.850 person-Rem, including under vessel work, whereas the actual dose accrued to complete the work activity was 10.752 person-Rem.
Additional Tracking Items
None.
PLANT STATUS
The reactor unit began the inspection period at 40 percent power per economic dispatch. On July 5, 2020, reactor power was raised to 85 percent power. On July 6, 2020, the reactor was returned to 100 percent power. On July 7, 2020, reactor power was reduced to 85 percent for a control rod pattern adjustment and then returned to 100 percent power. On September 15, 2020, plant power was reduced to 81 percent due to a high level trip of feedwater heater 2B with subsequent trips of feedwater heaters 2C, 3C, 4A, 4B, and 4C. On September 16, 2020, the reactor was returned to 100 percent power. On September 26, 2020, plant power was reduced to 80 percent to perform a control rod sequence exchange and maintenance on an adjustable speed drive channel before returning to 90 percent power; plant power was again reduced to 79 percent to recover the adjustable speed drive channel and then returned to 100 percent power where it stayed for the remainder of the inspection period.
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. Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted. As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed onsite portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site.
The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) High pressure core spray system following annual maintenance on August 3, 2020
- (2) Diesel generator 2 during diesel generator 1 annual maintenance on August 13, 2020
- (3) Standby service water system A during standby service water system B annual maintenance on September 21, 2020
- (4) Reactor core isolation cooling system following annual maintenance on September 24, 2020
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of diesel generator 1 following annual maintenance on August 6, 2020.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Fire Area RC-10/U, main control room, on July 14, 2020
- (2) Fire Areas DG-3/2, DG-5/2, and DG-9/2; diesel generator 2 room, diesel oil storage tank access room, and day tank room; on July 27, 2020
- (3) Fire Area R-3/#, high pressure core spray system pump room, on July 28, 2020
- (4) Fire Area DG-2/1, diesel generator 1 room, on August 4, 2020
- (5) Fire Area RC-3/1, vertical cable chase room, on September 11, 2020
- (6) Fire Areas DG-1/1 and DG-10/#, diesel generator 3 room and deluge valve equipment room, on September 22, 2020
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated fire brigade performance during an annual fire drill on August 26, 2020.
71111.07A - Heat Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness and performance of diesel generator 2 heat exchangers DCW-HX-1B1 and DCW-HX-1B2 on September 30, 2020.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during reactor power changes for an unexpected loss of feedwater level controller 5A on September 15, 2020, and to perform a control rod sequence exchange and maintenance on an adjustable speed drive channel on September 26, 2020.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a licensed operator requalification training drill (Crew E) on July 27, 2020.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (4 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) High pressure core spray system on July 31, 2020
- (2) Diesel generator 1 on August 13, 2020
- (3) Reactor core isolation cooling system on September 21, 2020
- (4) Standby service water system B on September 28, 2020
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Yellow risk for backup transformer maintenance, week of July 20, 2020
- (2) Yellow risk for high pressure core spray system maintenance, week of July 27, 2020
- (3) Yellow risk for diesel generator 1 maintenance, week of August 5, 2020
- (4) High risk for transformer E-TR-8A/1 replacement on September 13, 2020
- (5) Yellow risk for reactor core isolation cooling system maintenance, week of September 14, 2020
- (6) Yellow risk for standby service water system B maintenance, week of September 21, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensees justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Low oil pressure and metal shavings in oil filter of control room emergency chiller 1B on August 4, 2020
- (2) Containment vacuum breaker 1EF abnormal indication on August 6, 2020
- (3) Inverter 3B abnormal indication and voltage transient following attempted transfer from inverter 3A on August 13, 2020
- (4) Annual standby service water flow balance out of specification on August 25, 2020
- (5) Isolation capability of motor-operated valves RHR-V-9 and RCIC-V-22 on August 27, 2020
- (6) Electrical power panel E-PP-8AE low voltage on September 1, 2020
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Control room emergency chiller 1B low oil pressure on July 28, 2020
- (2) High pressure core spray system on July 31, 2020
- (3) Diesel generator 1 on August 5, 2020
- (4) Control room emergency chiller 1B low oil pressure on August 26, 2020
- (5) Reactor core isolation cooling system on September 21, 2020
- (6) Standby service water system B on September 22, 2020
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Work Orders 02140807 and 02140808, condensate storage tanks A and B inspection for license renewal, on September 28, 2020
- (2) OSP-FLEX-Q704, diesel generator 4 quarterly surveillance, on September 30, 2020
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) OSP-SGT/IST-Q701, standby gas treatment valve quarterly surveillance, on August 10, 2020
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated the emergency planning drill (Emergency Response Organization Team B) on August 25,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
COVID-19 pandemic conditions impacted the NRCs ability to conduct the inspection as scheduled. As a result, onsite inspection of appropriately risk-informed samples was not available. Therefore, IP 71124.01 is considered complete in accordance with IMC 0306, Section 06.08.f.3.
Radiological Hazard Assessment (IP Section 03.01) (1 Partial)
(1)
(Partial)
The inspectors remotely evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Partial)
(1)
(Partial)
The inspectors remotely evaluated radiological protection-related instructions to plant workers.
Contamination and Radioactive Material Control (IP Section 03.03) (1 Partial)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.
(1)
(Partial)
Inspectors reviewed condition reports, procedures, inventory, and surveys remotely for items stored in the spent fuel pool.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (2 Partials)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
(1)
(Partial)
Inspectors remotely reviewed monitoring data, procedures, and radiation work permits. The radiation work permits associated with Refueling Outage 24 in-vessel work, wet work, spent fuel pool work, and Rx Cavity work were reviewed.
(2)
(Partial)
The inspectors remotely reviewed electronic alarming dosimeter set points for radiation work permits associated with Refueling Outage 24 and verified set points were based on operating experience or historical outage data.
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (2 Partials)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
(1)
(Partial)
Inspectors remotely reviewed high radiation area condition reports relative to areas on the 606-foot elevation of the Reactor Building.
(2)
(Partial)
Inspectors remotely reviewed high radiation area condition reports relative to areas on the 441-foot elevation of the turbine building.
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Partial)
(1)
(Partial)
Inspectors remotely reviewed job coverage procedures, surveys, and radiation work permits.
71124.02 - Occupational ALARA Planning and Controls
Radiological Work Planning (IP Section 03.01) (5 Samples)
The inspectors evaluated the integration of as low as is reasonably achievable planning into the following work activities:
- (1) RWP 30004256, R24 Wet Work/Reactor Dive Inspection (Divers) - LHRA/High Risk
- (2) RWP 30004318, R24 Control Rod Drive Mechanism (CRDM) Undervessel Remove and Replace - LHRA/High Risk
- (5) RWP 30004347, R24 Drywell Main Steam Relief Valve (MSRV) Maintenance - LHRA
Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (5 Samples)
The inspectors evaluated dose estimates and exposure tracking.
- (1) RWP 30004256, R24 Wet Work / Reactor Dive Inspection (Divers) - LHRA/High Risk
- (2) RWP 30004318, R24 Control Rod Drive Mechanism (CRDM) Undervessel (UV)
Remove and Replace - LHRA/High Risk
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01)
The inspectors were unable to evaluate the configuration of permanently installed ventilation systems.
Temporary Ventilation Systems (IP Section 03.02)
The inspectors were unable to evaluate the configuration of temporary ventilation systems.
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors remotely evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors remotely evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign occupational dose.
Internal Dosimetry (IP Section 03.03) (1 Sample)
The inspectors evaluated the following internal dose assessments for actual internal exposures:
- (1) Dose assessment for an individual potentially exposed to airborne radioactivity while working on bleed steam valves in the TG 471-foot building on June 8, 2019. The licensee documented the issue I AR 00395101.
Special Dosimetric Situations (IP Section 03.04) (3 Samples)
The inspectors evaluated the following special dosimetric situations:
- (1) EDEX dose assessment and redacted NRC Form 5 for individuals using multipack dosimetry during the following RWP activity:
- RWP 30004258, R24 Wetwork/Reactor Dive Inspection (Divers) - LHRA/High Risk
- (2) EDEX dose assessment and redacted NRC Form 5 for individuals using multipack dosimetry during the following RWP activity:
- RWP 30004447, 2018 Reactor 606 Badger Testing
- (3) EDEX dose assessment and redacted NRC Form 5 for individuals using multipack dosimetry during the following RWP activity:
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
(1)
(07/01/2019 - 06/30/2020)
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
(1) (07/01/2019 - 06/30/2020)
MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)
(1) (07/01/2019 - 06/30/2020)
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
(1) (07/01/2019 - 06/30/2020)
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
(1) (07/01/2019 - 06/30/2020)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
(1)
(04/01/2019 - 06/30/2020)
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
(1)
(04/01/2019 - 06/30/2020)
71153 - Followup of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)
- (1) The inspectors evaluated licensee response to an inverter 3B abnormal indication and voltage transient following attempted transfer from inverter 3A and resultant 8-hour and 12-hour technical specification shutdown action statement entries on July 10, 2020.
- (2) The inspectors evaluated operator response to a rapid downpower due to a high level trip of feedwater heater 2B with subsequent trips of feedwater heaters 2C, 3C, 4A, 4B, and 4C on September 15,
INSPECTION RESULTS
Failure to Perform an Adequate Radiation Survey to Identify and Control a High Radiation Area Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety
Green NCV 05000397/202003-01 Open/Closed
[H.14] -
Conservative Bias 71124.01 The inspectors reviewed a self-revealed, Green, non-cited violation of 10 CFR 20.1501(a), for the licensees failure to perform an adequate radiological survey and identify a high radiation area. Specifically, on May 30, 2019, radiation protection personnel were notified by a radiation worker about an unanticipated self-reading dosimeter dose rate alarm while the worker was decontaminating equipment within a posted high contamination area (HCA) on the refuel floor (606-foot elevation of the reactor building). Radiation protection personnel did not perform a survey to verify the radiological conditions in the work area and allowed the work to continue. The workers were later asked to exit the area when it was determined that the work could not be completed within the allotted dose limit set point.
Description:
On May 30, 2019, two laborers were assigned the task of decontaminating a highly contaminated component removed from the reactor vessel. The component was a ring track used for mounting a specialty camera used to perform in-vessel visual inspections.
During the dayshift, the ring track was removed from the reactor cavity and placed in a high contamination area (HCA) within a posted radiation area (RA) on the refuel floor (606-foot elevation of the reactor building). At approximately 5:30 pm, dayshift radiation protection personnel began turnover to nightshift; however, a face-to-face turnover between the dayshift and nightshift Refuel Lead Techs (RLTs) did not occur. A telephone discussion was held instead. The postings around the ring track were not discussed during the telephone turnover. The nightshift RLT assumed the ring track was within a posted high radiation area, but did not attempt to validate this assumption.
At approximately 6:30 pm, the nightshift RLT briefed the two laborers about the ring track decontamination work. The Radiation Work Permit (RWP) authorized entry into posted high radiation areas (HRAs) and HCAs; however, the laborers were not briefed on area dose rates exceeding 100 millirem per hour and the briefing did not cover the potential for decontamination rags to generate significant dose rates. Prior to the decontamination work, surveys of the HCA indicated dose rates up to 60 millirem per hour at 30 cm from the ring track. The RWP established self-reading dosimeter (SRD) alarm setpoints at 40 millirem for dose and 200 millirem per hour for dose rate. The laborers were instructed to use multiple radioactive material (RAM) bags to ensure that the rags did not aggregate and create a dose concern; however, previous operating experience where aggregated decontamination rags created unposted HRAs was not discussed. At the briefing, the RLT did not specify which technician on the refuel floor would be providing coverage in the field, and no one on the refuel floor was assigned this responsibility. Initially, there were two radiation protection technicians (RPTs A&B) assigned to the refuel floor and later a second crew (RPTs C&D)arrived to relieve RPTs A&B.
When the laborers arrived at the refuel floor to prepare for the decontamination work, RPT B helped them don the proper protective clothing and equipment, including powered air-purifying respirators. After gathering additional supplies, the decontamination work commenced and RPT B left to attend to another job. The dose accrued by the laborers was also being monitored remotely by the RPTs.
At approximately 8:06 pm, as the laborers worked to decontaminate the ring track and placed the decontamination rags into a RAM bag, one of the laborers lanyards came undone, falling with the SRD and badge inside of the protective clothing to their knee. During this motion, the SRD experienced a dose rate alarm for approximately three seconds. The alarm, vibration, and SRD movement went unnoticed by the laborer. The alarm was not locked in long enough to register on the remote monitoring system. Around this same time is when the RAM bag became an HRA.
At approximately 8:14 pm, the laborer noticed the SRD was vibrating against his leg. He informed the other laborer and informed RPT A that he believed his SRD was alarming.
RPT A escorted the laborers to the step-off pad and contacted the RPTs at the remote monitoring station to check if a dose rate alarm occurred. No locked in alarms were noted, so it was relayed there was no alarm present. RPT A discovered the laborers SRD had fallen and assumed the vibration was caused by the dropped SRD. The laborers SRD and lanyard were relocated to the pocket of the inner set of his protective clothing and work was allowed to continue without validating that an alarm occurred by logging out the SRD or performing a survey of the work area to verify dose rates had not increased.
Work continued until about 8:50 p.m., when RPT C notified the laborers to exit based on the dose accrued and amount of decontamination work that remained to be done on the ring track. Upon exiting, the laborer who believed he had received an alarm, informed an RPT that was not involved in the work about the alarm he received. The licensee performed a follow-up survey that identified an unposted HRA with dose rates up to 1,600 millirem per hour on contact and 180 millirem per hour at 30 centimeters from the source, which happened to be the RAM bag where the laborers were disposing of the decontamination rags. The RAM bag was subsequently taped, labeled, and relocated to a posted HRA.
The inspectors reviewed the condition report, RWPs, surveys, and investigation details associated with this event and determined that the failure to perform a survey to verify radiological conditions prior to allowing work to continue was a violation of 10 CFR 20.1501(a).
Corrective Actions: The licensee counseled the radiation protection technicians involved and developed a preferred process for decontamination of highly contaminated items for the refuel floor, wetwell, and undervessel to be used during the outage. Specific precautions were added to identify and monitor RAM bags containing cleaning rags and mop heads that can quickly become high radiation areas.
Corrective Action References: Action Request (AR) 00394579 and AR 00409248
Performance Assessment:
Performance Deficiency: Failure to perform a survey on the refuel floor to identify an unposted High Radiation Area and evaluate the magnitude and extent of radiation levels as required by 10 CFR 20.1501(a) was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the failure to perform a survey resulted in an unposted HRA where an uninformed worker was allowed to continue working with an SRD dose rate alarm setpoint that was not sufficiently low enough to allow the worker to take appropriate action before encountering dose rates exceeding 100 millirem per hour.
Significance: The inspectors assessed the significance of the finding using Appendix C, Occupational Radiation Safety SDP. The finding was of very low safety significance (Green) because it was not an as low as reasonably achievable (ALARA) planning issue, there was no overexposure nor potential for an overexposure (due to availability of alarming dosimetry being worn), and the licensees ability to assess dose was not compromised.
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, the licensees decision making-practices that allowed work to continue without performing an adequate radiation survey to verify the magnitude and extent of radiation dose rates had not increased is not reflective of an organization with a bias for conservative decision-making.
Enforcement:
Violation: 10 CFR 20.1003, defines a survey as an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation.
10 CFR 20.1501(a), requires in part, that each licensee make or cause to be made surveys of areas that may be necessary for the licensee to comply with the regulations in Part 20 and that surveys are reasonable under the circumstances to evaluate the magnitude and extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present.
As provided in paragraph 20.1601(c) of 10 CFR Part 20, the following controls shall be applied to high radiation areas in place of the controls required by paragraph 20.1601(a) and
- (b) of 10 CFR Part 20.
Technical Specification 5.7.1 requires, in part, that for High Radiation Areas with Dose Rates not Exceeding 1.0 rem/hour (at 30 centimeters from the radiation sources or from any surface penetrated by the radiation), each entryway to such an area shall be barricaded and conspicuously posted as a high radiation area, and entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them.
Contrary to the above, on May 30, 2019, for High Radiation Areas with Dose Rates not Exceeding 1.0 rem/hour (at 30 centimeters from the radiation sources or from any surface penetrated by the radiation), the licensee failed to ensure that each entryway to such an area was barricaded and conspicuously posted as a high radiation area, and entry into such areas was made only after dose rates in the area have been determined and entry personnel are knowledgeable of them. Specifically, 1) the entryway to an HRA near a RAM bag containing the ring track decontamination rags on the refuel floor was not barricaded and conspicuously posted and 2) entry into the area near a RAM bag containing the ring track decontamination bags on the refuel floor was made before dose rates in the area had been determined and without entry personnel being made knowledgeable of them.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Follow ALARA Planning Procedures Resulting in Unplanned Dose on a Work Activity Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety
Green NCV 05000397/202003-02 Open/Closed
[H.5] - Work Management 71124.02 The inspectors reviewed a self-revealed, Green, non-cited violation Technical Specification (TS) 5.4.1 because the licensee failed to follow their as low is reasonably achievable (ALARA) planning procedures resulting in unplanned dose while performing the control rod drive mechanism (CRDM) Replacement work. Specifically, the licensees procedure instructed them to obtain data on the actual radiological conditions in the work area prior to commencement of the job and determine the effective dose rate using corrected historical data for the current scope and radiological conditions in the radiation work permit (RWP)planning phase. The licensee initially planned the job for approximately 6.850 person-Rem, including under vessel work, whereas the actual dose accrued to complete the work activity was 10.752 person-Rem.
Description:
From May to June 2019 during Refueling Outage 24, numerous jobs led to exceeding their overall dose estimate of 139.896 person-Rem, and goal of 130 person-Rem, with an actual dose accrued of 161.474 person-Rem. One of the primary work activities that led to this dose exceedance was the CRDM Replacement job to exchange a total of 20 CRDMs from under vessel. This job commenced on May 19, 2019. The licensee identified they were having issues maintaining doses ALARA and in alignment with their planned dose estimate. In AR 00395843, the licensee documented that some of the primary issues resulting in additional unplanned dose were problems with their O-rings leaking and not properly seating, issues with their use of the special equipment used to more effectively manipulate the CRDM removals, rework on some equipment, and perhaps most significantly, elevated dose rates in the work areas. Survey M-20190514-5, DW 501 Under-Vessel Post H2O Fill-Up, dated May 14, 2019, and characterized as a verification of dose rates survey, identified the maximum dose rates in the work area as 910 millirem per hour on contact and 320 millirem per hour at 30 cm. The Refueling Outage 24 (R24) Nightshift Logs, dated May 15, 2019, stated that HP Planning has indicated that U/V (under vessel) dose rates in Drywell are 75% higher than R23 (Refueling Outage 23). In addition, the licensee noted that the average dose rates for the CRDMs went from approximately 25 Rem/hour in R23 to approximately 47 Rem/hour during R24. The licensee noted that the primary reason for the elevated dose rates were attributed to the iron excursion event experienced in August 2017, and residually caused issues with the O-rings and overall dose increases. To their credit, the licensee did attempt numerous measures of dose reduction initiatives, but they were not effective enough to reduce the dose to a planned level of exposure. In response to a request for information, the licensee stated the following, The work had been planned and it was decided to follow the contingency plan rather than revise the estimate. This process did not follow the instructions provided in their ALARA planning procedures.
Procedure PPM 11.2.2.14, Radiological Planning and Reviews, Revision 4, Section 4.1.10, stated, in part, the following:
- Obtain data on the actual or anticipated radiological conditions in the work area using one of more of the following methods:
o Pre-job surveys o Recent surveys of the work area o Historical surveys. Radiological conditions in the work area should be verified prior to allowing work to commence.
o Data from job history files for similar tasks. Radiological conditions shall be determined prior to allowing work to commence.
Section 4.1.11 of PPM 11.2.2.14 stated, in part, the following:
- Based on the following, DETERMINE AND ENTER an effective dose rate for each craft on the H213 Panel (of the Passport Computer Program), after considering the following:
o Current and historical radiological conditions in the work area o Estimated locations and body positions of the workers during the task o Review of historical dose information corrected for current scope and conditions o Information obtained in Step 4.1.10
PPM 11.2.2.14, Section 6.1, defined Effective Dose Rate as An estimated dose rate based on the actual work area dose rates, worker position, worker movement with the work area, and planned dose reduction measures. It also stated the historical information may be used to determine the Effective Dose Rate, but these conditions were explained further in Section 4.1.10 and 4.1.11, as stated above.
The inspectors determined that the licensee failed to implement the steps in Section 4.1.11 during their planning and implementation process for the CRDM Replacement job, which included various radiological work permits. Specifically, the licensee determined that the current radiological conditions were much higher than the historical radiological data from R23, but the licensee did not use the current higher radiological conditions in the work area to properly determine an effective dose rate, which is used to determine or revise the dose estimate, for the craft on the job prior to commencement of the work. Instead, the licensee stated they decided to follow the contingency plan rather than revise the estimate.
Section 3.9 of PPM 11.2.2.14 stated, in part, that instructions and contingency plans in work instructions, ALARA plans, and the RWP should be specific and clearly stated with limited use if as directed by RP. The aim is to help workers focus on the job and respond appropriately to emergent or changing conditions. Thus, the contingency plans are inferred for use during the work activity in progress, for emergent or changing conditions, and not for decisions made prior to the job commencing. The inspectors determined that the failure to follow these instructions and implement the current radiological conditions into the ALARA planning permit prior to commencement of the work resulted in not effectively managing the radiological risk due to the short time span of the job and continuing with work in the midst of elevated radiological conditions. This ultimately resulted in unplanned dose to the workers for the CRDM Replacement job and under vessel work.
The NRC reviewed the dose estimate of 6.850 person-Rem for the job, as commenced, and credited an additional 0.251 person-Rem for credible emergent work, resulting in an NRC revised dose estimate of 7.101 person-Rem. This NRC revised dose estimate exceeds the approved revised dose estimate by the licensee, via their in-progress review, of 7.036-person-Rem for the CRDM work. Thus, the actual dose accrued of 10.752-person Rem exceeded the NRC revised dose estimate by 51.4 percent (51.4%).
Corrective Actions: The licensee documented the issues associated with the CRDM replacement job in their corrective action program as AR 00395843. The licensee also evaluated the performance of this job in their Refueling Outage 24 post job review package.
Additionally, the licensee initiated AR 00409249 to address the proposed violation and assess any additional corrective actions relative to the performance deficiency.
Corrective Action References: AR 00395843 and AR 00409249
Performance Assessment:
Performance Deficiency: The licensees failure to follow their ALARA planning procedures and properly determine the effective dose rate prior to commencement of the CRDM Replacement job is a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Additionally, the finding was similar to Example 6(i) in Appendix E to Manual Chapter 0612, Power Reactor Inspection Reports - Examples of Minor Issues.
Significance: The inspectors assessed the significance of the finding using Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding had very low safety significance (Green) because, although the finding involved ALARA planning and work controls, the licensees latest three-year rolling average collective dose was less than 240 person-Rem (i.e., 135.44 person-Rem).
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the licensee failed to execute the work with the appropriate planning commensurate with the radiological risk identified, while coordinating and managing all relative under vessel work activities.
Enforcement:
Violation: Technical Specification 5.4.1, Procedures, states, in part, that written procedures shall be established, implemented, and maintained covering the following activities:
- (a) the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Appendix A, Section 7(e), recommends Radiation Protection procedures.
Procedure PPM 11.2.2.14, Revision 4, Section 4.1.11, states, in part, that the licensee is to DETERMINE AND ENTER an effective dose rate for each craft on the H213 Panel (of the Passport Computer Program), based on the following:
- Current and historical radiological conditions in the work area
- Estimated locations and body positions of the workers during the task
- Review of historical dose information corrected for current scope and conditions
- Information obtained in Step 4.1.10 (obtain data on the actual or anticipated radiological conditions in the work area)
Contrary to the above, from May to June 2019 during Refueling Outage 24, the licensee failed to determine an effective dose rate for each craft based on information obtained in PPM, Step 4.1.10, and the historical data corrected for current scope and conditions.
Specifically, the licensee performed a validation radiological survey five days prior to commencement of the CRDM Replacement job and determined that dose rates were significantly higher than the historical data but did not base the effective dose rate for the job on these current radiological conditions by appropriately revising the dose estimate and work scope. The licensee specifically stated in their response to the NRC that they, decided to follow the contingency plan rather than revise the estimate, which does not align with the appropriate use of the contingencies, as stated in Section 3.9 of PPM 11.2.2.14, Revision 4.
At the time, it appears as though the licensee believed they were operating within the scope of their procedures.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On October 15, 2020, the inspectors presented the integrated inspection results to Mr. W.G. Hettel, Chief Nuclear Officer/Vice President Nuclear Generation, and other members of the licensee staff.
On July 27, 2020, the inspectors presented the Occupational Radiation Safety inspection results to Mr. R. Schuetz, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Action Requests
(ARs)
409261, 409457, 403099, 400090, 404607, 405359, 407757,
408822, 409196, 409593, 409594, 401237, 401287, 404112,
411017
Drawings
M512-1
Flow Diagram Diesel Oil & Miscellaneous Systems
048
M512-3
Flow Diagram Diesel Oil & Miscellaneous Systems Diesel
Generator Building
041
M519
Flow Diagram: Reactor Core Isolation Cooling System
103
M520
Flow Diagram HPCS and LPCS Systems
105
M524-1
Flow Diagram Standby Service Water System
139
Procedures
10.27.87
RCIC Keepfill Instruments RCIC-PIS-1 and RCIC-PIS-34 -
CFT/CC
2
3.1.6F
Instrument Rack Valve Line-Up Reactor Building 422 and
471 Elevations
007
PPM 1.3.29
Locked Valve Checklist
086
PPM 1.3.62
Use of Cable Ties (Tie Wraps)
007
PPM 1.3.81
Maintaining Plant Component Status Control
016
SOP-DG-DSA
Diesel Starting Air Operations
016
SOP-DG1-LU
Emergency Diesel Generator (DIV 1) Valve and Power
Supply Lineup
006
SOP-DG2-LU
Emergency Diesel Generator (DIV 2) Valve and Power
Supply Lineup
007
SOP-DG2-
START
Emergency Diesel Generator (DIV 2) Start
033
SOP-DG2-STBY
Emergency Diesel Generator (DIV 2) Standby Lineup
23
SOP-DG3-LU
High Pressure Core Spray Diesel Generator Valve and
Power Supply Lineup
009
SOP-DG3-STBY
High Pressure Core Spray Diesel Generator Standby Lineup
019
SOP-HPCS-LU
HPCS Valve and Breaker Lineup
004
SOP-HPCS-
STBY
Placing HPCS in Standby Status
004
SOP-RCIC-LU
RCIC Valve and Breaker Lineup
004
SOP-RCIC-STBY
Placing RCIC in Standby Status
2
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
SOP-SW-LU
Standby Service Water System Valve & Breaker Lineup
013
Work Orders
2162153, 02126439, 02135644, 02155492, 02156217,
2160505, 02132544
Calculations
FP-02-85-03
Combustible Loading Calculation
010
Corrective Action
Documents
Action Requests
(ARs)
384793, 409481, 409497, 409505, 403382, 403385, 403450,
403610, 403748, 405319, 405384
Fire Plans
PFP-DG-
BUILDING
Diesel Generator Building
004
Reactor 422
006
Radwaste 467
005
Radwaste 501-507
005
Turbine Generator 441-456
009
Miscellaneous
Crew B Unannounced Backshift Drill 6/19/20
06/19/2020
Drill Report: Unannounced Backshift Drill 6/19/20 Scenario
OS-002 Crew B
06/19/2020
Drill Report: Unannounced Backshift Drill 8/26/2020
Scenario TG-004 Crew E
08/26/2020
Procedures
1.3.10C
Control of Combustibles
2
1.3.57
Barrier Impairment
039
13.1.1
Classifying the Emergency
049
13.1.1A
Classifying the Emergency - Technical Bases
034
4.FCP.1
FCP.1 Annunciator Panel Alarms
23
4.FCP.2
FCP.2 Annunciator Panel Alarms
016
ABN-FIRE
Fire
041
Work Orders
2163070
Calculations
ME-02-92-231
Evaluation of Heat Exchanger Performance Data - DCW
001
ME-02-92-244
Minimum Heat Transfer Rate Required for DCW Heat
Exchangers A & B
000
ME-02-92-245
RHR Heat Exchanger Tube Side Flowrate and Inlet
Temperature Evaluation
000
Corrective Action
Documents
Action Requests
(ARs)
391148, 391160, 391175, 398502, 411270, 411411
Engineering
17432, 12442
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Changes
Miscellaneous
MOT-HX-1-1
Maintenance Optimization Template: Heat Exchangers
013
Procedures
8.4.62
Thermal Performance Monitoring of DCW-HX-1B1 and
DCW-HX-1B2
009
Work Orders
2059477, 02059478, 02103773, 02103774, 02132409
71111.11Q Corrective Action
Documents
Action Requests
(ARs)
408746, 408747, 409496, 410023, 410112, 410534, 410833,
411186, 411193, 411194, 411197, 410801
Miscellaneous
AOM-T Roll-up Comments: Cycle 20-04
000
Crew E 4.0 Critique Summary LR002492
07/27/2020
Reactivity Control Plan September 26, 2020, Sequence
Exchange and Scram Time Testing
09/15/2020
Control Rod Withdrawal Deviation Sheet
09/03/2020
LR002492
Cycle 20-4 Evaluated Scenario
000
Procedures
13.1.1
Classifying the Emergency
049
13.1.1A
Classifying the Emergency - Technical Bases
034
3.2.6
Power Maneuvering
015
3.3.1
Reactor Scram
066
5.1.1
RPV Control
2
5.1.2
26
ABN-FWH-
HILEVEL/TRIP
Feedwater Heater High Level Trip
007
ABN-POWER
Unplanned Reactor Power Change
016
ABN-ROD
Control Rod Faults
031
OI-09
Operations Standards and Expectation
079
SOP-CR-
MOVEMENT
Control Rod Movement
004
SOP-RRC-
FLOW-QC
Reactor Power Change with RRC Flow Controllers - Quick
Card
005
TSP-CRD-C101
CRD Scram Timing with Auto Scram Timer System
29
Work Orders
2146065, 02159885
Corrective Action
Documents
Action Requests
(ARs)
408595, 409141, 409156, 409175, 409181, 409215, 409224,
409252, 409260, 409261, 409303, 409313, 408822, 406409,
407757, 409196, 332149, 336395, 410488, 410779, 410800,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
410835, 410865, 410882, 410883, 410913, 410831, 410880,
410981, 411002, 411017, 411019, 411024, 411044, 411050,
411052
Miscellaneous
Instrument Master Data Sheet: RCIC-PS-9B
007
BIP 19-0389
Barrier Impairment Permit for ISP-HPCS-X302 (Calibrate
HPCS-FIS-6)
07/29/2020
BIP 20-0344
Barrier Impairment Permit for Inspection of HPCS-FT-5
Penetration Seal
07/27/2020
ISP 20-0136
Ignition Source Permit for Work Order 02140140
09/17/2020
Procedures
1.3.57
Barrier Impairment
039
1.5.11
016
10.16.1
Standby Service Water Pump Overhaul
017
10.2.10
Fastener Torque and Tensioning
28
10.25.4
Lubrication and Inspection of Limitorque MOVS
29
10.27.85
RCIC Turbine Trip on High Turbine Exhaust Pressure B
Calibration
2
HPCS Flow Rate Low Minimum Flow - CC
009
HPCS Diesel Generator Monthly Operability Test
069
OSP-HPCS/IST-
Q701
HPCS System Operability Test
059
HPCS Service Water Valve Position Verification
26
SOP-RCIC-FILL
RCIC Fill and Vent
20
SOP-RCIC-OIL
RCIC Turbine or Pump Oil Fill and Prime
010
SYS-4-22
015
Work Orders
2080473, 02126090, 02120692, 02128969, 02054567,
2089993, 02045665, 02123430, 02153118, 02131518,
2162153, 02156590, 02160239, 02135829, 02136041,
2152183, 02156156, 02156217, 02160285, 02160286,
2134251, 02134544, 02135557, 02140140, 02149943,
2152938, 02153201, 02158395, 02122134, 02139803,
2140165, 02143796, 02146121, 02146129, 02153512
Corrective Action
Documents
Action Requests
(ARs)
409466, 409497, 409505
Miscellaneous
FPF-2.4-28
Standpipe and Hose Systems, Evaluation of Long Hose
000
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Lengths Using a PROTEK #379 Nozzle
FPSI 20-0169
Fire Protection System Impairment Permit for Inst. Rack E-
IR-P027 Door R415
08/02/2020
FPSI 20-0170
Fire Protection System Impairment Permit for Inst. Rack E-
IR-P021 Door R316
08/02/2020
FPSI 20-0171
Fire Protection System Impairment Permit for Inst. Rack E-
IR-P009 Door R216
08/02/2020
FPSI 20-0172
Fire Protection System Impairment Permit for SW B
Pumphouse Door G201
08/02/2020
FPSI 20-0173
Fire Protection System Impairment Permit for Door C408
Upper Corridor Outside CR
08/02/2020
FPSI 20-0174
Fire Protection System Impairment Permit for Door C223
Vital Island General Area
08/02/2020
FPSI 20-0175
Fire Protection System Impairment Permit for Emergency
Chiller Room Door C502
08/02/2020
FPSI 20-0176
Fire Protection System Impairment Permit for Comm. RM
RM C503 Door C505
08/02/2020
FPSI 20-0177
Fire Protection System Impairment Permit for Instrument
Shop RM RM C510 Door C511
08/02/2020
FPSI 20-0178
Fire Protection System Impairment Permit for Div 2 HVAC
Room Door C508
08/02/2020
FPSI 20-0179
Fire Protection System Impairment Permit for Remote
Shutdown Room Door C240
08/02/2020
FPSI 20-0180
Fire Protection System Impairment Permit for SM-8
Switchgear Room Door C242
08/02/2020
FPSI 20-0181
Fire Protection System Impairment Permit for Div 2 RPS RM
Door C222
08/02/2020
FPSI 20-0182
Fire Protection System Impairment Permit for Div 2 Battery
Charger RM C224 Door C238
08/02/2020
FPSI 20-0183
Fire Protection System Impairment Permit for Div 2 Battery
Room Doors C217 or C238
08/02/2020
FPSI 20-0184
Fire Protection System Impairment Permit for Waste Tank
Floor Area RM C106 Door C109
08/02/2020
FPSI 20-0185
Fire Protection System Impairment Permit for South Valve
08/02/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
RM RM R405 Door R407
FPSI 20-0186
Fire Protection System Impairment Permit for MCC Div 2
South RM R410 Door R408
08/02/2020
FPSI 20-0187
Fire Protection System Impairment Permit for RCIC Room
Door R5 RM R015
08/02/2020
FPSI 20-0188
Fire Protection System Impairment Permit for Div 2 MCC
ROOM Room R612 Door R607
08/02/2020
FPSI 20-0189
Fire Protection System Impairment Permit for Inside Door
R217
08/03/2020
FPSI 20-0190
Fire Protection System Impairment Permit for B RHR Pump
Room Doors R7/7A Room R006
08/03/2020
FPSI 20-0191
Fire Protection System Impairment Permit for DFO Day Tank
08/02/2020
FPSI 20-0192
Fire Protection System Impairment Permit for DG 3 Div 2
DFO TK Door D110 Room D102
08/03/2020
FPSI 20-0193
Fire Protection System Impairment Permit for DG2 Diesel
Room Door D104 RM D110
08/02/2020
Procedures
1.3.10
Plant Fire Protection Program Implementation
034
1.3.76
Integrated Risk Management
060
1.3.83
Protected Equipment Program
031, 032
1.3.85
On-line Fire Risk Management
006
Monthly Battery Testing 125VDC E-B1-2
007
Weekly Battery Testing
016
OSP-ELEC-W101 Offsite Station Power Alignment Check
2
Work Orders
2156332, 02156554, 02163069, 02168650
Calculations
E/I-02-87-07
Calculation for Load Flow Voltage for Main Buses in AC
Distribution Systems
2
E/I-02-90-01
Low Voltage System Loading, Security System Loading and
Voltage Calculation
016
ME-02-92-43
Flow Reduction Factors Reactor Building
013
ME-02-95-25
Evaluation of Standby Service Water Capability
2
Corrective Action
Documents
Action Requests
(ARs)
407977, 407978, 408057, 315816, 408422, 408487, 408559,
408560, 408543, 408697, 409219, 408616, 408618, 408620,
408622, 408724, 408741, 407092, 409590, 409591, 409833,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
409851, 409937, 410056, 410399, 408029
Drawings
E504-1
Vital One Line Diagram
006
EWD-22E-039A
Electrical Wiring Diagram Primary Containment Atmospheric
Control System CVB-V-1ST Front Disk
003
EWD-22E-048A
Electrical Wiring Diagram Primary Containment Atmospheric
Control System CVB-V-1ST Rear Disk
003
M543-1
Flow Diagram - Reactor Bldg. Primary Containment Cooling
and Purging Systems
2
Engineering
Changes
8818
Critical Instrument Bus and Alternate Source Power
11/28/2011
Miscellaneous
Position Paper for Operator Convenience
07/10/2020
Operations and Maintenance Manual 399.5.1, York
Centrifugal Turbopak R-11
09/22/2004
Technical position paper associated with AR 40802940802907/14/2020
NRC Inspection Reports 05000327/2020010 and
Operations Log: July 1 - August 6, 2020
08/06/2020
Operator Logs: July 10 - 11, 2020
07/11/2020
213-05,7
Vacuum Relief Valve and Auxiliaries Owners Manual
005
MOT-CKV-1-1
Check Valves Maintenance Optimization Template
017
Procedures
1.10.11
Technical Assessments Supporting Reportability and
Reportability Evaluations
2
1.16.6B
Voluntary Entry into Technical Specification Action
Statements, Licensee Controlled Specifications
Requirements for Operability
018
1.3.16
Issue Management
2
1.3.66
034, 035
1.3.9
056
10.25.85
Repair of Wet Well Vacuum Breaker Position Switches
2
4.800.C1
800.C1 Annunciator Panel Alarms
031
ABN-ELEC-INV
20 VAC Critical Distribution System Failures
017
OSP-CVB/IST-
M701
Vacuum Breaker Operability
016, 017,
018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
OSP-ELEC-W102 Electrical Distribution Subsystem Breaker Alignment and
Power Availability Verification
031
SOP-CN-CONT-
VENT
Containment Vent, Deinert, Purge, and Ventiliating
27
SOP-CN-OPS
Containment Nitrogen System Operations
010
SOP-ELEC-IN3-
IN3 Operations
013
SWP-OPX-01
Operating Experience Program
001
Work Orders
2155686, 02164937, 02156935, 29155613, 02131744,
2145562, 02042666, 02043384, 02156764, 02157084,
2157376, 02157626, 02167660, 29156112, 29156133
Corrective Action
Documents
Action Requests
(ARs)
408595, 409141, 409156, 409175, 409181, 409215, 409224,
409252, 409260, 409261, 409303, 409313, 407977, 407978,
408057, 408466, 408525, 408604, 408639, 408654, 408708,
408761, 408842, 408890, 408947, 408976, 409068, 409107,
409697, 409726, 409842, 409899, 403782, 404272, 404607,
406649, 354988, 355024, 342466, 400409, 410882, 410927,
410928, 410929, 410930, 410931, 410934, 410947, 410949,
410951, 410964, 410965, 410966, 411107
Miscellaneous
Operations Department Narrative Logs for 08/05/2020
BIP 19-0389
Barrier Impairment Permit for ISP-HPCS-X302 (Calibrate
HPCS-FIS-6)
07/29/2020
BIP 20-0344
Barrier Impairment Permit for Inspection of HPCS-FT-5
Penetration Seal
07/27/2020
Procedures
1.3.57
Barrier Impairment
039
10.2.13
Approved Lubricants
077
ABN-HVAC
HVAC Trouble
017
HPCS Flow Rate Low Minimum Flow - CC
009
OSP-CCH/IST-
M702
Control Room Emergency Chiller System B Operability
045
OSP-CONT-C101 Suppression Pool Average Water Temperature Surveillance
2
Diesel Generator 1 -Monthly Operability Test
060
HPCS Diesel Generator Monthly Operability Test
069
OSP-HPCS/IST-
HPCS System Operability Test
059
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Q701
RCIC Fill, Flow Controllers, and Valve Lineup Verification
019
OSP-RCIC/IST-
Q701
RCIC Operability Test
063
OSP-RCIC/IST-
Q702
RCIC Valve Operability Test
044
OSP-SW-IST-
Q702
Standby Service Water Loop B Operability
035
Standby Service Water Loop B Valve Position Verification
043
HPCS Service Water Valve Position Verification
26
PPM 1.5.1
Surveillance Testing Program
043
SOP-HVAC/CR-
SHUTDOWN
Control, Cable, and Critical Switchgear Rooms HVAC
Shutdown
005
SOP-HVAC/CR-
START
Control, Cable, and Critical Switchgear Rooms HVAC Start
017
SOP-RHR-SPC
Suppression Pool Cooling/Spray/Discharge/Mixing
008
SOP-SW-
SHUTDOWN
Standby Service Water System Shutdown
2
SOP-SW-START
Standby Service Water System Start
008
SOP-SW-STBY
Placing Standby Service Water in Standby Status
003
SWP-TST-01
Post Maintenance Testing Program
017
Work Orders
2080473, 02126090, 02120692, 02128969, 02054567,
2089993, 02045665, 02123430, 02153118, 02131518,
2162153, 02156590, 02160239, 02164274, 02138105,
2124750, 02154772, 02159891, 02915593, 02124750,
2157518, 02167155, 02150225, 02156936, 02160285,
2161982, 02134544, 02134781, 02135563, 02140140,
2147071, 02158410, 02140165, 02153512
Calculations
E/I-02-91-03
Calculation for Division 1 and 2 and 3 Diesel Generator
Loading
21
Corrective Action
Documents
Action Requests
(ARs)
291562, 382935, 410110, 410392, 410513, 410610, 410611,
410618, 410724, 410735, 410803, 410823, 409695, 409856,
409857, 409866, 411040, 411419
Drawings
204-00,88,1
Condensate Storage Tank 1A General Plan Detail and Parts
007
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
List
204-00,89,1
Condensate Storage Tank 1B General Plan Detail and Parts
List
007
Engineering
Changes
17708
Miscellaneous
Condensate Storage Tanks A & B Inspection Videos
09/24/2020
Operations Department Narrative Logs for 08/10/2020
Procedures
10.25.48
Testing Molded Case Circuit Breakers
017
FLEX-01
FLEX Program
003
Diesel Generator 4 Quarterly Surveillance
000
OSP-SGT/IST-
Q701
SGT Valve Operability (System A)
010
PPM 1.5.1
Surveillance Testing Program
043
PPM 13.10.1
Control Room Operations and Shift Manager Duties
035
SWP-IST-01
ASME Inservice Testing
004
Work Orders
2160246, 02140807, 02140808, 02145984, 02168133
Corrective Action
Documents
Action Requests
(ARs)
410143, 410180, 410323
Procedures
13.1.1
Classifying the Emergency
049
13.1.1A
Classifying the Emergency - Technical Bases
034
13.10.2
TSC Manager Duties
035
13.10.6
Plant / NRC Liaison Duties
25
13.10.9
Operations Support Center Manager and Staff Duties
050
Corrective Action
Documents
Action Request
(AR)
00320829, 00394339, 00394466, 00394579, 00395232,
00401615, 00403475, 00404828, 00405114, 00405278,
00409019, 00409248
Procedures
4.840.A3
840.A3 Annunciator Panel Alarms
20
HPI-0.19
Radiation Protection Standards and Expectations
019
HPI-12.96
RCA Access Restriction and Reinstatement
009
PPM 11.2.13.1
Radiation and Contamination Surveys
043
PPM 11.2.6.7
Special Dosimetry
019
Radiation
Surveys
M-20190517-34
RB 606 SFP Inventory Following R24 Fuel Inspections
05/17/2019
M-20190523-28
RB 606 SFP Inventory Following LPRM And Dry Tube
05/23/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Replacement
M-20190530-20
RB 606 Removal Of Framatome Hawkeye Ring From Cavity
05/30/2019
M-20190531-4
RB 606 Hawkeye ring post decon/dose rate alarm followup
05/30/2019
M-20191024-7
RB 572 Monthly
10/24/2019
Radiation Work
Permits (RWPs)
30004256
R24 RF Wetwork, Invessel, SFP, DSP *HR*
and Associated Tasks, Pre-Job Briefing, ALARA Plan
001
Self-Assessments 388465-02
CFR 20 Annual Program Review Snapshot Self-
Assessment Report
03/15/2019
401808-01
NRC Inspection Procedure 71124.01 Snapshot Self-
Assessment Report
03/05/2020
Work Orders
2109577-01
Calibrate/Repair Outage HP Portable Air Samplers
03/26/2019
2137805-01
Calibrate/Repair HP Portable Air Samplers
04/19/2019
Corrective Action
Documents
Action Request
(AR)
00371557; 00373396; 00374279; 00389652; 00393863;
00393987; 00394579; 00395197; 00395232; 00395371;
00395843; 00396076; 00398464; 00401910; 00404386;
00405192; 00405201; 00409249
Miscellaneous
2019 CGS Refueling Outage 24 CRE Report
2019
2017 CGS Refueling Outage 23 CRE Report
2017
EDEX Assessments for RWPs 30004258, 30004447,
30004470
Procedures
GEN-RPP-01
ALARA Program Description
009
GEN-RPP-02
Radiological Planning and Control Process
034
GEN-RPP-13
Senior Site ALARA Committee
013
PPM 11.2.2.11
Exposure Evaluations for Maintaining TEDE ALARA
009
PPM 11.2.2.14
Radiological Planning and Reviews
004
PPM 11.2.2.7
ALARA Procedure Analysis
2
PPM 11.2.2.8
ALARA Engineering Analysis
007
PPM 11.2.8.2
Radiation Work Permit Preparation and Use
2
Radiation Work
Permits (RWPs)
30004256
R24 Refuel Floor Wetwork Invessel, Spent Fuel Pool, and
DSP - High Risk
001
30004258
R24 Wetwork/Reactor Dive Inspection (Divers) - LHRA/High
Risk
000
30004318
R24 CRDM Undervessel Remove and Replace - LHRA/High
000
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Risk
30004319
R24 CRDM Undervessel Support - LHRA
001
30004328
R24 ST/VR/DCA/Rebuild Room Miscellaneous Work - High
Risk
000
30004336
R24 Drywell/Steam Tunnel Shielding Install/REM and
Support Tasks - LHRA
000
30004340
R24 DW/ST/VR OPS HC/LC, LLRT and Valve Lineups -
001
30004347
R24 Drywell MSRV Maintenance - LHRA
000
30004350
R24 Steam Tunnel MSIV Maintenance and Refurb Tasks -
2
Self-Assessments 00388465-02
Annual Review of the Columbia Generating Station
Radiation Protection Program that Fulfills the Requirements
of 10 CFR 20.1101(c) for CY2018
03/15/2019
401806
Pre-Inspection (71124.02) ALARA Snapshot Self-
Assessment
2/28/2020
2838
Annual Review of the Columbia Generating Station
Radiation Protection Program to Meet 10 CFR 20.1101(c)
Requirements
03/25/2020
Corrective Action
Documents
Action Request
(AR)
00386503, 00387127, 00387272, 00387564, 00388740,
00390148, 00400231, 00401759, 00403834, 00404159,
00404572, 00404573, 00404716, 00404977, 00405381,
00405882
Drawings
SD000195
Radwaste Building HVAC
011
SD000201
Control Room, Cable Room, and Critical Switchgear Rooms
- HVAC
016
Miscellaneous
CAM Locations and Potential Sources
Breathing Air Sample Analysis - SCBA Compressor
03/18/2020
Personal
Qualification Data
(PQD)
Self-Contained Breathing Apparatus qualified personal with
qualification dates
03/17/2020
Procedures
GEN-RPP-05
Respiratory Protection Program Description
015
GEN-RPP-10
Use of Respiratory Equipment
2
HPI-15.1
Inspection and Storage of Respirators and Attachments
2
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
HPI-15.5
Set-up and Use of Bullard Air Line Filters
003
HPI-8.2
Quantitative Respirator Fit Testing Using the PortaCount
System
29
PPM 11.2.11.3
Issuance of Respiratory Equipment
017
PPM 11.2.15.11
Use and Certification of Portable Air Handling Units
015
PPM 12.5.36
Service Air Sampling
005
Self-Assessments 378162
Respiratory Protection Program Self -Assessment
03/12/2020
2740
71124.03 SnapShot Self-Assessment
Work Orders
211048501
Sample Plant Breathing Air
01/30/2019
211048601
Sample Plant Breathing Air
04/25/2019
SCBA Inspections 02142336, 02147151, 0215236, 02133230
Corrective Action
Documents
Action Request
(AR)
00339377; 00374271; 00382896; 00393990; 00393998;
00394156; 00394272; 00395067; 00395101; 00397889
Miscellaneous
Summary of Internal Exposure (5/21/2018 to Present)
06/22/2020
Columbia Generating Station Scaling Factors
03/12/2018
Columbia Generating Station Scaling Factor
03/12/2018
Columbia Generating Station CRE/Source Term Reduction
5-Year Plan
20
100518-0
NVLAP Ionizing Radiation Dosimetry Accreditation
01/01/2020
Declared Pregnant Workers Annual Dose Forms
2018-2019
Procedures
11.2.13.8
Airborne Radioactivity Surveys
019
11.2.15.13
Control of Personnel Skin and Clothing Contamination
004
11.2.4.5
Whole Body Counts and Daily Checks Using the
Renaissance FASTSCAN
016
11.2.4.6
In Vitro Bioassay Sampling and Analysis
003
GEN-RPP-06
Dosimetry Program Description
013
HPI-0.19
Radiation Protection Standards and Expectations
019
HPI-5.9
Evaluation of In-Vivo Bioassay Results Following a Potential
Intake
014
SWP-RPP-01
Radiation Protection Program
016
Radiation Work
Permits (RWPs)
30004447
2018 Reactor 606 Badger Testing
000
30004470
2019 Reactor 522 and Reactor 548 RWCU Flow -
LHRA/High Risk
000
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Self-Assessments 00401801
Pre-Inspection Self-Assessment of the Columbia Generating
Station Internal and External Dosimetry Programs
04/09/2020
71151
Miscellaneous
MSPI Cooling Water System Derivation Reports
09/02/2020
MSPI Emergency AC Power System Derivation Reports
09/02/2020
MSPI Heat Removal System Derivation Report
09/02/2020
MSPI High Pressure Injection System Derivation Reports
09/02/2020
MSPI Residual Heat Removal System Derivation Reports
09/02/2020
Control Room Operator Logs for 7/1/2019 to 6/30/2020
Procedures
HPI-0.14
Assessing and Reporting NRC Occupational Exposure
Control Effectiveness Performance Indicator Data
006
Self-Assessments 387312
RETS/ODCM PI Verification Snapshot Self-Assessment
Report
05/11/2019
401807
Occupational Exposure Control Performance Indicator
Snapshot Self-Assessment Report
2/11/2020
Corrective Action
Documents
Action Requests
(ARs)
408616, 408618, 408620, 408622, 408724, 408741, 404829,
410817
Drawings
E504-1
Vital One Line Diagram
006
Engineering
Changes
8818
Critical Instrument Bus and Alternate Source Power
11/28/2011
Miscellaneous
Operator Logs: July 10 - 11, 2020
07/11/2020
Position Paper for Operator Convenience
07/10/2020
Procedures
1.3.16
Issue Management
2
4.800.C1
800.C1 Annunciator Panel Alarms
031
ABN-ELEC-INV
20 VAC Critical Distribution System Failures
017
ABN-FWH-
HILEVEL/TRIP
Feedwater Heater High Level Trip
007
ABN-POWER
Unplanned Reactor Power Change
016
SOP-ELEC-IN3-
IN3 Operations
013
Work Orders
2131744, 02169264, 02169265